PNP 2020-039, 10 CFR 71.95 Report Involving 3-608 Cask

10 CFR 71.95 Report Involving 3-608 Cask

ML20325A052
Person / Time
Site:	Palisades
Issue date:	11/20/2020
From:	Hardy J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
PNP 2020-039
Download: ML20325A052 (8)

Text

• ~ Entergy Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, Ml 49043 Tel 269 764 2000 Jeffery A. Hardy Regulatory Assurance Manager PNP 2020-039 November 20, 2020 10 CFR 71.95 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards Washington, DC 20555-0001

SUBJECT:

10 CFR 71.95 Report Involving 3-608 Cask Palisades Nuclear Plant Docket 50-255 Renewed Facility Operating License No. DPR-20 Entergy Nuclear Operations, Inc., (ENO) hereby submits the enclosed report pursuant to 10 CFR 71.95(a)(3) regarding instances in which the conditions of approval in Certificate of Compliance #71-9321 for the 3-608 cask may not have been observed when making shipments from Palisades Nuclear Plant (PNP). This report is based on a 10 CFR 71.95 report dated October 20, 2020, by the certificate holder, EnergySolutions, to the Nuclear Regulatory Commission (NRC). The EnergySo/utions report to the NRC is provided in Attachment 1.

The attached report is applicable to use of the 3-60B cask by PNP. ENO records show that PNP made a total of two Class B shipments using the 3-608 cask between June 2018 and July 2018. The shipments are listed in Attachment 2.

Energy Solutions failure to perform periodic maintenance inspections has no safety consequence because such inspections were performed prior to each use of 3-60B cask. This letter contains no new commitments and no revisions to existing commitments.

Should you have any questions concerning this report, please contact Mr. Jeffery Hardy, Regulatory Assurance Manager, at (269) 764-2011.

Respectfully, Attachments: 1. EnergySolutions 10 CFR 71.95 Report on the 3-60B cask.

2. Palisades Nuclear Plant List of Class B shipments using the 3-60B cask.

CC NRC Region Ill Regional Administrator, Region Ill NRC Project Manager, Palisades NRC Senior Resident Inspector, Palisades

ATTACHMENT 1 PALISADES NUCLEAR PLANT EnergySo/utions 10 CFR 71.95 REPORT ON THE 3-608 CASK 4 Pages Follow

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ENERGYSOLUTIONS October 20, 2020 ESCD-2020-6

Subject:

IO CFR 71.95 notifications for 3-608 cask (Docket 71-9321) associated with failure to observe certificate of compliance conditions for the 3-608 cask periodic maintenance inspection

Dear Valued Customer:

During a recent NRC audit completed on October 2,2020 assessing implementation of I0CFR71 program at EnergySolutions Barnwell Logistics Facility (BLF), the NRC inspection team identified that periodic maintenance performed for 3-608 casks (units #1 and #2) did not comply with Chapter 8 of the 3-608 cask Safety Analysis Report (SAR) requirements invoked by the effective revision of the Certificate of Compliance 71-932l(CoC).

Specifically, packaging markings (lid alignment markings), fasteners/threaded holes, exposed packaging interior and exterior surfaces were not inspected periodically as required by Table 8-1 of Chapter 8 of the 3-608 cask SAR.

Failure to perform periodic maintenance inspection of these items has no safety consequence because such inspections were performed prior to each use of 3-608 cask. Although, such inspections were performed prior to each use, EnergySolutions failed to inspect these items periodically as required in condition of approval in the CoC 71-9321. As such, condition of approval in the Certificate of Compliance was not observed in making a shipment which is addressed by I0CFR71.95 (a)(3}.

Due to the condition above, EnergySolutions suspended the use of the 3-60B casks until appropriate periodic inspections are performed. EnergySo/utions generated a Condition Report associated with this issue on September 21, 2020.

EnergySolutions filed the attached report with the NRC containing the information required by 10 CFR 71.95 on October 19, 2020. In the report, EnergySolutions describes the cause of the occurrence and provides information that supports that there is no safety significance associated with this condition. The circumstances described in this report are applicable to EnergySolutions (as a license holder and periodic maintenance inspection provider) and may be applicable to all licensed users (licensees) of 3-60B cask. We expect that the information required for individual

• users to make their own notifications is contained in this report. Reference to this report in individual user reports would be appropriate, if you so choose.

We sincerely apologize for any inconvenience this issue may have caused within your organization. Our corrective actions as a result of this issue are intended to prevent recurrence of similar issues and to ensure the highest quality of products and services that we provide. Should you have any questions regarding this notice, please contact me at (803)591-9074 or axgelfond@enerwsolutions.com.

Sincerely, Aleksandr Gelfond Cask Division Engineering/Licensing Manager Appendix A: ES/NRC 20-004 (3 pages) cc: Gerard van Noordennen (EnergySo/utions) cc: Rod Turner (EnergySo/utions)

Appendix A to ESCD-2020-6

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ENERGYSOLUTIONS October 20, 2020 ES/NRC 20-004 ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

10CFR 71.95 Report on the 3-60B cask (Docket 71-9321)

EnergySolutions hereby submits the attached report (Attachment 1) providing the information required by 10CFR71.95(a)(3) for instances in which conditions of approval in the Certificate of Compliance for the 3-60B cask have not been observed in making shipments.

The circumstances described in this report is applicable to Energy Solutions (as a license holder and periodic maintenance inspection provider) and may be applicable to all licensed users (licensees) of 3-60B cask.

Should you have any questions regarding this notice, please contact me at (803)591-9074.

This letter is submitted electronically via the NRC Electronic Information Exchange (EIE) system.

Sincerely, Aleksandr Gelfond Cask Division Engineering/Licensing Manager Attachment I: Failure to Observe Certificate of Compliance Condition for the 3-60B cask periodic maintenance inspection, October 20, 2020 cc) Pierre Saverot, NRC Gerard van Noordennen, EnergySolutions 740 Osborn Road, Barnwell, SC 29812 www.energysolutions.com

Attachment I to ES/NRC 20-004

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ENERGYSOUJTJONS Failure to Observe Certificate of Compliance Condition for the 3-60B cask periodic maintenance inspection October 20, 2020 I) Abstract During a recent NRC inspection of EnergySolutions' Barnwell Logistics Facility (BLF), the inspection team identified that periodic maintenance perfonned for 3-608 casks (units #I and #2) did not comply with Chapter 8 of the 3-608 cask Safety Analysis Report (SAR) requirements invoked by the latest revision of the Certificate of Compliance 71-9321 (CoC). Specifically, packaging markings (lid alignment markings), fasteners/threaded holes, exposed packaging interior and exterior surfaces were not inspected periodically as required by Table 8-1 of Chapter 8 of the 3-608 cask SAR.

Failure to perfonn periodic maintenance inspection of these items has no safety consequence because such inspections were performed prior to each use of 3-60B cask. Although, such inspections were performed prior to each use, EnergySolutions failed to inspect these items periodically as required in condition of approval in the CoC 71-9321. As such, condition of approval in the Certificate of Compliance was not observed in making a shipment which is addressed by I 0CFR7 I .95 (a)(3).

2) Narrative Description of the Event a) Status of Components 3-608 cask units # I and # 2 have been removed from service until required periodic inspections (in accordance with Chapter 8 of the SAR) are completed.

b) Dates of Occurrences The dates of occurrences for affected packaging's are as follows:

3-608 cask Dates of Occurrences (shipments) Number of Shipments

1. I March 20 I 6 to June 2020 27

1. 2 Julv- September 2019 3 c) The cause of each component or system failure or personnel error, if known.

EnergySolutions Cask Book Procedure (TR-OP-052) provides a subset of operational, inspection, test and maintenance procedures for 3-608 cask operations. Among these procedures are:

• EnergySolutions Procedure No. CS-FP-PR-016, 3-60B Shipping Cask: Periodic Inspection and Maintenance ofFastener and Threaded Holes

• EnergySolutions Procedure No. CS-FP-PR-017, 3-60B Shipping Cask: Periodic Maintenance of Exposed Surfaces.

These procedures were inadvertently omitted from the use by the cask maintenance personnel during periodic maintenance inspections.

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Attachment 1 to ES/NRC 20-004

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ENERGYSOWTIONS d) Failure Mode, Mechanism, and Effect of each failed component, if known Not applicable; no 3-60B packaging components failed.

e) Systems or Secondary Functions Affected Not applicable.

f) Method of Discovery of the Error The error/condition was identified by the NRC inspection team during an audit of EnergySolutions 's Barnwell Logistics Facility (Barnwell, SC).

3) Assessment of Safety Consequences Failure to perform periodic inspection of packaging markings (lid alignment markings),

fasteners/threaded holes, exposed packaging interior and exterior surfaces has no safety consequence because such inspections were performed prior to each use of 3-60B cask.

4) Planned Corrective Actions The following corrective actions are planned by EnergySolutions:

• EnergySolutions has removed 3-60B cask units# I and #2 from service until appropriate annual inspections are performed.

• EnergySolutions has evaluated the condition for reportability under I0CFR 71.95 and has concluded that it is reportable.

• EnergySo/utions (as the 3-60B cask license holder and periodic maintenance provider) will submit this report to NRC.

• EnergySolutions will contact licensees (cask users) that have made shipments using the affected 3-608 cask units with request to evaluate reportability under I0CFR71.95 process.

• EnergySo/utions will perform an apparent cause analysis and identify additional corrective actions to prevent reoccurrence.

• All required inspections will be performed on the affected casks prior to placing them back into service.

5) Previous Similar Events Involving the 3-60B casks No previous similar events have been identified.

6) Contact for Additional Information Aleksandr Gelfond EnergySolutions Cask Division Engineering/Licensing Manager (803)591-9074 axgelfond@energysolutions.com

7) Extent of Exposure oflndividuals to Radiation or Radioactive Materials None 2

ATTACHMENT 2 PALISADES NUCLEAR PLANT LIST OF CLASS B SHIPMENTS USING THE 3-608 CASK Shipment# Cask Used Destination Date Shipped Time PLP-2018-RW- # 3-60B-1 Waste Control 06/20/2018 09:30 departed 004 Specialists, Compact Covert, Ml Waste Disposal Facility Andrews, TX PLP-2018-RW- # 3-60B-1 Waste Control 07/13/2018 16:30 departed 005 Specialists, Compact Covert, Ml Waste Disposal Facility Andrews, TX Page 1 of 1