ML13149A279

Independent Spent Fuel Storage Installation, 212 Interim Report Change 13-01 for Revision 7 to 10 CFR 72.212 Evaluation Report

ML13149A279
Person / Time
Site:	Salem, Hope Creek
Issue date:	05/16/2013
From:	Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
LS-AA-108-F1, Rev. 0
Download: ML13149A279 (7)

Text

Document Transmittal Form To: NRC ATTN:DOC. CONTROL ID: 0148 ONE WHITE FLINT NORTH WASHINGTON, DC 20555-001 Date: 5/16/2013 Please update your controlled set of documentation with the following documents:

Document ID Revision Status Ouantitv Format RecNo 212 INTERIM REPORT CHANGE 13-01 0 APPROVED 1 H MB05161305 For questions concerning distributions, please contact Records Management @ (856) 339-1063 0 kss'-ý-(p

LS-AA-108-Fl Revision 0 Page 1 of 2 PSEG 10 CFR 72.212 EVALUATION REPORT CHANGE COVER SHEET 212 Report Change No. 13-01

1. Type of. Change (check one): Interim Change Z Full Revision U

2. Nature of Change (check one or both): Editorial/Administrative E] Technical Z

3. 72.48 Review No.: H 13 -01 50.59 Review No.: N/A

4. Current 212 Report Revision: 7 (Interim Change 7B)

5. Sections(s) of the 212 Report affected by the change(s) (use additional sheets as necessary)

1. An interim change is being made to Revision 7 of the 212 Report to add new Subsection 5.4.1.12.1, which addresses two nonconforming conditions that were accepted as-is for a number of Hope Creek and Salem dry spent fuel storage canisters in service at the ISFSI. The accept-as-is dispositions represent deviations from the cask FSAR and require a review under 10 CFR 72.48. See the enclosed mark-up for the specific changes to the 212 Report. The changes are labeled as follows for the purposes of this 72.48 review:

a) Thirteen Hope Creek MPC.s currently in service did not have the water in the MPC-HI-TRAC annulus continuously flushed during vacuum drying as was required by the thermal analysis supporting the FSAR and TS.

b) Nine Salem and four Hope Creek MPCs currently in service did not have the minimum required amount of helium backfilled into the fuel cavity as was required by the thermal analysis supporting the FSAR and TS.

Four MPCs are affected by both nonconformances for a total of 22 MPCs affected 6,00 c-,/

II. Associated references are added to SectionJ7-G-tupporting this change. This is editorial.

6. Reason for Change(s)

The change summarizes the accept-as-is disposition for 22 nonconforming dry spent fuel storage canisters that resulted in FSAR deviations. The deviations constitute changes to the cask FSAR.

The technical issues that created the non-conforming conditions were resolved within the PSEG corrective action program shortly after the conditions were discovered. Those resolutions were consistent with actions required by the cask technical specifications and supported by the cask vendor's technical evaluations. This interim revision to the PSEG Nuclear 212 Report is being performed as a follow-up action for completeness.

7. Source Documents (e.g., DCP, Procedure, CoC Amendment, etc.)

1. PSEG Notifications 20478677 and 20489632, "Hope Creek MPC Annulus Flushing."

2. PSEG Notifications 20530707, 20532615, and 20532467, "Dry Cask Helium Backfill Not Meeting Tech Spec."

3. Nuclear Fuels Incoming Correspondence NFSI 12-011, Holtec Report H1-2115051, "Thermal Analysis of MPC with Lower Helium Backfill Pressure at Salem," Revision 0

4. Nuclear Fuels Incoming Correspondence NFSI 10-115, "Heat Load Limits Applicable to Vacuum Drying without Annulus Flushing - Analysis Results and Technical Position."

5. Nuclear Fuels Incoming Correspondence NFSI 11-074, "RRTI-1332-001, Responseto Request for Technical Information."

LS-AA-108-Fl Revision 0 Page 2 of 2 PSEG 10 CFR 72.212 EVALUATION REPORT CHANGE COVER SHEET 212 Report Change No. 13-01 7

Preparer: ~44,.-' 2,~- - __

Date: 3* //e71/3 Salem Rx Engineering Mgr/Designee: N/A Date:

Hope Creek Rx Engineering Mgr/Designee:. U k.3/ y ( 6 *" *( Date: 3 0.5 Nuclear Fuels MgrlDesignee*: I L. 't Date:__________

Salem Plant Engineering: NIA Date:

Hope Creek Plant Engineering: i &oýJ66+L'w Date: 3,0,c 11

---

I Salem Reg. Assurance Mgr/Designee: N!A Date:

Hope Creek Reg. Assurance Mgr/Designee*: K*L4 L 7. . (.1 /4,,,.Date I&./3..

4-)0, Ntp5on Other Reviewer: N/A Date:

Other Reviewer: N/A Date:

DCS Task Mgr/Designee -',, .. c.. )ate:.04 ,08 D"-a b a11 Licensing Mgr/Designee*:?. 0"h Y! KII2

./*"-( Date:0 40 OS (7-0V 3 PORC Meeting No. (required for full 72.48 evaluations) [19 -c~ 6-,2 '

• Required of~

Salem/Hope Creek Generating Station

/Ij PIndependent Spent Fuel Storage Installation NUCLEAR LLC 10 CFR 72.212 Evaluation Report 5.4.1,1231 MPC Dc, v lleat-Related FSI R Deviationts 71w' FS. deviati*."ns reiuvd I(? ;IIP( d hate been identified und accepled cs-i.N fijr ct.kv h-cwteat arca hleade. R,.**e'rences 660, aInd 66 provide h1 .cicncntiia and .nppor'tint ;/*renc'cs fbir thle accept-as-is dispositions. Ecwh L, vhtnio i.s s.umrncrized below. Rq/Ur to Appncndix 2./br a compilete Iswtinrg /all AlPCs loaided at the Sa/m.l/Hope (. reek IS.Sl.

The 16 /P1(: c>ntaitun.Ing (..S lpn. lfuel wth e inm .yer'vc a the /,S/! us, 7) tho,..

.ofRevision.

1L,011 we edth a id lariwc g the/ vutn dQvint /p.W'cess. The fII-ST(R.*FbN.IR requiredthe w1ater in the ,min.lls hetwen the :W/iPc. outer s.hel/ cad the HIAM-T A"tran.s/er cask inner shcll to he cciittiteuoic/yfiu.ic die'mg v 'Loa drying Ith .,:cp" ' IW'1/ exceededl u certain vatle. Ao lirat in. i;,vclad fitt c.-/ALVI iar ark!d was iher the TSAIfR or the ;C. I Because tlw in e.vtablisb:d

.Mi"C twtal h/ed hIid ,,exhksiio.l f cinnaniots ,r annul,,. u hiu,, wls nwo exceeded. thu ann/,ts

,ms w/a1 rteIin i/t contous/y./lushed ev / Af.Y. duringIvacinum chrv'0".

faltec later inf/*rnted its cliOWs thai the thermal a*ri*a'! ibr- vacu-m clrctin',, as.swned a a,.lbrn/i, distributed heat taad across all 68./teI CelI W ckcatin's (the mu xiium I/Cat /uecd /mit ecl without cuziilnlots..u.ld*ng dAided by rhe nunthbr qf/'.i/eel! iocaiuhmv. I/ (utp ine fWe ce/I Idca/iim cxceeded the avercage dccoy heat value, then the a*t7lus' 111,cr shotld have been cotltimioisly

.fitshed to preserve the assl.mptions in the thermal cfl',iS. ( the h 16 .1111 -65I loudcd with HC,(S Spent fieand in cerrice ait the LS'/1. all excevp seial numbhers 1021-145. -/46. cou/ -/53 were determined to Itci'S idivihidltd.ibel ce/I deccy heats e v eeecding the a ecra-ge vadue limit fiu 1:aeunum irvine'.

In responsve to li"e ft rccfire action nati/cctbxis issue*d t IoSE'G, flu/iec perbr),ridan cv.intiuii

'R Ti cnVLn 6. 79 .fi)/r t*he 13 q//ec'd Hope (.reck VPC( 0'-,;cn .fi:and. in all c.se.', 1ii1c fi/d cladduerileniperaiure during, vuctint i did no/i ,cvcd ith aheplicable fieI Iudclading 1

temperature limit fin shhorterm cmr ut1WmUU. Dh n'i a lim chlirg , f t " :tP /, .Jui ihe presence (,/' water in the unnulus 1WU5 S'V!Cieat to etn'ue thet the .4l(' shell entpercitn'e reiwanted he/ow its MiAi. Based on these results, tho T S,4R deviation wast (cIcipied de.5-c for t/tese 13 WA(.

T/tiu ek ,/iatini dcl mol a/t ,t/y1y to Sale/ Aiti'cl, b mcit.eull prerit1s'y-loed c// IleIn K AUP!i were driedIusing theforced hi:,lium ckelikclation (I-lI, system, nut vctcnunt dlrci/n.

So/cteco.t_ Hope. ek :\l/(..'s withs M.an the R ni-ýred Helium BackhH /Rei'rcrn'e 6.661 In 2011, tt/tec non!/ied a!! f their cycts users thca hr tase users ere inco'rreclt" cctctdclntzg the AI/P(,C decctV heal to d/letewrne the helium hac#ill irequireenets in accordance with /1/--STORM

('oC .Iniendinett 5, -T'ec/nical/Speiificc.ionLC'O 3. 1. 1. Simih.n' the camauhts. w-aer f/lus hing ft tSue disclut'tc (above. the cask thermal uIaItaIVis assumed the AlP(/.. /ecd luid watN evenldy distribwedcioniwng a/ ftiel cell locations in the .1.PC. If any .singlefitel cell location decay heatl was higher. c m.pur.ed bca.5s"d on the ticiaxitiim perini.sible total W1'C heat loaud fbi the lower bact/ill pressutre rtzvre, a higher minimum hel/mn backfill was required to ensuire the thermal ancdi.v. is remained bouncinvg.

Pag 41P of 6Rv Page 41 of 8 8 Rev. 7

Salem/Hope Creek Generating Station Independent Spent Fuel Storage Installation NUCLEAR LLC 10 CFR 72.212 Evaluation Report PSEG Nuclear determined that the helium backfill Surveillance Requirement (LCO 3.1.1, SR 3.1.1.2) was not met for MPC-32s 1023-93 through -96 and 1023-128 through -132, previously loaded with SGS Unit I spent fuel, and MPC-68s 1021-155 through -158, previously loaded with HCGS spent fuel. PSEG subsequently declared the LCO not met for these MPCs and initiated the LCO 3.1.1, Required Action C.2.2: "Develop and initiate corrective actions necessary to demonstrate through analysis, using models and methods from the HI-STORM FSAR, that all limits for cask components and contents will be met."

Holtec provided a technical evaluation to support the required action under LCO 3.1.1, Required Action C.2.2 which demonstrated that the as-loaded MPCs remain within the HI-STORM system design basis for peak fuel cladding temperatures and the temperature limits for other cask components for normal long term dry storage of fuel., short-term operations, and off-normal and accident conditions. Therefore, these MPCs have been returned to an analyzed condition as required by the. cask Technical Specifications and Bases.

Reference 6.73 provides the applicable thermal analysis supporting the as-loaded configuration for the Salem MPCs. While assessing the issue, the noted Hope Creek MPCs were determined to be bounded by a prior analysis of record for a specific regional loading case and no further analysis was required (Reference 6.80). This case was later used to develop the applicable heat load table in a Holtec. FSAR change implemented via ECO-5014-196. Although all affected MPCs have been demonstrated to meet applicable thermal limits, due to its overall impact on the, ISFSI design basis, this issue is considered a deviation from HI-STORM FSAR Section 2.1.9.1 for these 13 Salem and Hope Creek MPCs.

Note that for Hope. Creek MPCs 1.021-i55 through -158 (for which both deviations are applicable), there is no aggregate effect, because the vacuum drying and helium backfill are separate thermal. conditions. Vacuum drying occurs as a one-time transient condition during MPC preparation and the helium backfill deficit occurred after vacuum drying was complete and exists only during, long-term storage operations.

5.4.1.13 CoC Holder Approval of Cask Operating Procedures Holtec International has reviewed and approved the site dry cask storage operating procedures as required by HI-STORM FSAR Section 8.0, as documented in Reference 6.52. Holtec International also prepared the first drafts of the new Salem cask operating procedures to adopt CoC Amendment 5 and FSAR Revision 7. The Salem procedures are being created from the Hope Creek procedures previously reviewed and approved by Holtec. Furthermore, Holtec is contracted for loading services for the first Salem cask loading campaign and thus will have input to the procedure development process. Procedures are owned, understood, maintained and revised by PSEG Nuclear after the first loading campaigns at each station.

5.4.1.14 ISFSI Pad Elevation Section 4.4.4.3 of HI-STORM FSAR Revision 7 requires users to confirm the elevation of the ISFSI pad to determine whether a site-specific thermal analysis is required. The HI-STORM FSAR requires a unique thermal analysis for ISFSI pads situated at elevation 1500 ft or higher.

The Salem/Hope Creek ISFSI is located near the eastern shore of the Delaware River on land that slopes, very gradually up from the shoreline. The ISFSI pad is situated well below 1500 ft.

Paq of 8 Page 42 of 88 Rev. 7

PSvc Ift-1A...U Salem/Hope Creek Generating Station Independent Spent Fuel Storage Installation NUCLEAR LLC 10 CFR 72.212 Evaluation Report 6.56.11 SC.RE-FR.DCS-0001, "Dry Cask Storage Fuel Characterization."

6.56.12 SC.RE-FR.DCS-0002, "Dry. Cask Storage Fuel Selection for Cask Loadinu."

6.56.13 SC.RE-FR.DCS-0003, "Fuel Spacer Matrix."

6.56.14 SC.RE-FR.ZZ-0001. "Fuel Handling."

6.56.15 RP-SA-303, "HI-TRAC Radiation Survey."

6.56.16 RP-SA-304, "HI-STORM Radiation Survey."

6.56.17 SC.RE-FR.ZZ-0007, "Verification of Fuel Locations."

6.57 Sargent & Lundy Report No. 009670, "Salem Generating Station Independent Spent Fuel Storage Installation Fire Hazards Analysis," Revision 1, PSEG VTD 901554 (001).

6.58 PSEG Nuclear letter LR-N09-0034 to the NRC, License Amendment Request S08-06, "License Amendment Request to Relocate Communications, Manipulator Crane, and Crane Travel Requirements from Technical Specifications," April 9, 2009, and Salem Units I and 2 License Amendments 277 and 293.

6.59 PSEG Design Change Package 80091593, "Salem Dry Cask Storage Operations," latest revision.

6.60 PSEG Notifications 20478677 and 20489632, "Hope Creek MPC Annulus Flushing."

6.61 Contractor Procedures 6.61.1 Holtec Procedure 1I-PP-1746-600, "Procedure for MPC Cooldown and Weld Removal for MPC Unloading at Hope Creek and Salem Plants," Revision 2.

6,61.2 PCI procedure Pl-900995-01, "Closure Welding of Multi-Purpose Canisters at Hope Creek and Salem," Revision 2.

6.62 U.S. NRC Enforcement Guidance Memorandum 09-006, "Enforcement Discretion for Violations of 10 CFR 72, Subpart K. Regarding Implementation of Certificate of Compliance Amendments to Previously Loaded Spent Fuel Storage Casks," September 15, 2009.

6.63 Holtec Report No. HI-2094469, "Design Basis Wind., Tornado, and Snow Load Evaluation for Salem Generating Station," Revision 1, PSEG VTD 901918 (001).

6.64 Holtec Report No. .HI-2073864, "Seismic Analysis of the Crawler, HI-STORM and ZPT on the Egress Pad." Rev. 8, PSEG VTD 901298 (001).

6.65 Holtec Operations and Maintenance Manual for the Supplemental Cooling System and Manifold, Ancillary 421, PSEG VTD 901300 (001).

Page 56 of 88 Rev. 7

Salem/Hope Creek Generating Station

.0 . Independent Spent Fuel Storage Installation NUCLEAR LLC 10 CFR 72.212 Evaluation Report 6.66 PSEG Notifications 20530707, 20532615, and 20532467, "Dry Cask Helium Backfill Not Meeting Tech Spec.".

6.67 Letter from Holtec International, Andrew Fecht, to PSEG Nuclear, Tom Wallender, "Leaving Mating Device Installed Atop a Loaded HI-STORM in a ZPT," dated July 30, 2010.

6.68 Holtec Component Completion RecOrd 1027-421-8, "MPC Supplementary Cooling System,"

Revision 0.

6.69 Holtec Report No. HI-2073816, "Structural Analysis of.Zero. Profile Transporter (ZPT)," Rev. 5, PSEG VTD 901426 (001).

6.70 Email from A. Fecht, Holtec, to B. Gutherman, PSEG, "ZPT Hydraulic Fluid Volume and MSDS." dated July 15, 2010.

6.71 Holtec Purchase Specification PS-i 129, "HI-STORM Zero Profile Transporter," Revision 5, PSEG VTD 901475 (001).

6.72. Holtec Report No. HI-2104690, "Seismic/Structural Analysis of HI-TRAC/Pedestal at Salem,"

Rev. 2, PSEG VTD 902010, (001).

6.73 NuclearFuels IncomingCorrespondence NFSI 12-011, Holtec Report HI-211.5051, "Thermal.

Analysisof MPC with Lower Helium Backfill Pressure at Salem.,' Revision 0.

6.74 Holtec Report No. H1-2022966, "Forced Helium Dehydrator Sourcebook," Rev. 4, PSEG VTD 902019 (001).

6.75 Holtec 10 CFR 72.48.Evaluation No. 915, "Thermal Evaluation of Loaded HI-STORM in the ZPT," Revision 1.

6.76 PSEG Design Change Package 80103873, "Salem Unit I DCS-Stack-up Seismic Lateral Restraints," Rev. 0.

.6.77 PSEG Design Change Package 801-043.15, "Salem Unit 2.DCS-Stack-up Seismic Lateral Restraints," Rev. 0.

6.78 PSEG Nuclear letter to NRC LR-N12-0194, "HI-STORM 1.00 Cask Supplemental Cooling System Validation System Testing Using Air Mass Flow Rate," dated June 25, 2012.

6.79 Nuclear Fuels.Incoming Corresponderice NFSI 10- 115, "Heat Load Limits Applicableto Vacuum Drying without Annulus Flushing

• Analysis Results and Technical Position."

6.80 Nuclear Fuels Incoming Correspondence NFSI 11-074, "RRTI-1332-00.1, .Response to Request for Technical Information."

Page.57 of 88 Rev. 7