ML050240241

Special Report

ML050240241
Person / Time
Site:	Arkansas Nuclear, Holtec
Issue date:	01/19/2005
From:	James D E Entergy Operations
To:	Document Control Desk, NRC/NMSS/SFPO
References
0CAN010503
Download: ML050240241 (7)

Text

E EnL)7Iergy Entergy Operations, Inc.1448 S.R. 333 Russeliville, AR 72802 Tel 501 858 5000 1 OCFR72.214 OCAN01 0503 January 19, 2005 ATTN: Document Control Desk Director, Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Special Report Arkansas Nuclear One -Units 1 and 2 Docket Nos. 50-313, 50-368, and 72-13 License Nos. DPR-51 and NPF-6

Dear Sir or Madam:

Per the requirements of the Holtec International Certificate of Compliance (CoC) (72-1014) for the Hl-STORM 100 System, damaged fuel assemblies are not authorized for loading into the Model 32 Multi-Purpose Canister (MPC-32).

However, on December 20, 2004, Arkansas Nuclear One (ANO) was notified that five previously loaded intact fuel assemblies had been reclassified as damaged fuel assemblies.

Upon notification, the actions contained in Appendix B, Section 2.1 of the Holtec CoC, Fuel Specifications and Loading Conditions, were initiated by ANO. The affected fuel assemblies were verified to be in a safe condition and the NRC Operations Center was notified of the event within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Attachment 1 completes the final action of submitting a Special Report within 30 days.New commitments contained in this submittal are summarized in Attachment 2.If you have any questions concerning this submittal or Entergy Operations' storage of spent fuel under the general license, please contact Stephenie Pyle at (479) 858-4704.D. James Director, Nuclear Safety Assurance DEJ/SLP Attachments

1. Special Report 2. List of Commitments

~-k (-) <S O ,:~~0 OCAN01 0503 Page 2 cc: Dr. Bruce Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Drew Holland Mail Stop 0-7 D1 Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission Attn: Mr. Thomas Alexion Mail Stop 0-7 D1 Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission Attn: Mr. Stephen C. O'Connor Mail Stop 0-13 D13 Washington, DC 20555-0001 Scott Atwater U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Attachment I OCAN01 0503 Special Report Attachment 1 to OCAN010503 Page 1 of 2 Special Report Cause of the violation:

To restore full core offload capability prior to the next Arkansas Nuclear One (ANO) Unit 2 refueling outage, a dry fuel storage (DFS) cask loading campaign was required in the fall of 2004. In early August 2004, prior to this loading campaign, it was identified by Entergy Operations, Inc. (Entergy) that additional fuel inspections would be required to support the Holtec Safety Analysis Report (SAR) and Certificate of Compliance (CoC) requirements.

Areva was contracted to perform ultrasonic testing (UT) data evaluations, on select Unit 2 fuel assemblies.

In late October 2004, the on-site UT inspection of Unit 2 fuel assemblies was completed and a preliminary report issued on November 2, 2004. Based on a high confidence in the technical accuracy of the UT fuel inspection preliminary report, the report was utilized by ANO for fuel selection to support the scheduled cask loading campaign that began on November 8, 2004, in which four Holtec Model 32 Multi-Purpose Canister (MPC-32) casks were placed in service.ANO was verbally notified, by Areva, on December 20, 2004, that a secondary review of preliminary results of UT data evaluations resulted in conservative reclassifications of five fuel assemblies previously determined to be free of fuel failures.

The secondary review concluded that ANO Unit 2 fuel assemblies AKC401, AKC504, AKDO01, AKF1 03, and ADF1 10 are suspected as each containing a damaged fuel pin. Because the size of the defect could not be determined based on the UT and visual examinations performed, the defects were conservatively assumed to be greater than pinhole leaks or hairline cracks.The verbal notification was documented in subsequent correspondence received from Areva on December 21, 2004. The identified assemblies were loaded in MPC-32 serial numbers 001, 002, 003, and 009, during the November and December 2004, cask loading campaigns.

Two of the subject fuel assemblies were loaded into serial number 001 and one each into serial numbers 002, 003, and 009.The root cause of this condition was determined to be insufficient guidance / processes in site fuel inspection and dry fuel storage selection procedures to control the use of preliminary reports. There are no specific regulatory or program requirements specifying the level of review required for this component of the fuel selection activities to support the loading of an assembly into dry fuel storage. Reactor Engineering used a preliminary report that had not received an appropriate level of technical review to make decisions on fuel selection which led to loading fuel into DFS casks that was later classified as failed fuel by the final report.Corrective steps that have been taken: In accordance with Appendix B, Section 2.1 of the Holtec CoC, Fuel Specifications and Loading Conditions, the affected fuel assemblies were verified to be in a safe condition.

An assessment of the effect a damaged rod would have on the storage configuration of a fuel assembly in the HI-STORM 100 system considering the normal, off-normal, and accident conditions was performed by Entergy and validated by Holtec. Based on this assessment, loading damaged fuel assemblies in Holtec MPC-32 serial numbers 001, 002, 003, and 009 results in no impact to safety, and all functions of the DFS casks are maintained.

This assessment did not consider the requirements for the MPC to be transported off-site.Additional reviews will be performed prior to considering these casks for transportation.

Attachment 1 to OCAN01 0503 Page 2 of 2 Corrective steps that will be taken to avoid further violations:

Appropriate fuel inspection and fuel selection procedures will be revised to include restrictions prohibiting use of reports that have not received the appropriate level of review in determining acceptability of fuel assemblies considered for loading into DFS casks.Applicable procedures will be revised to require additional evaluations prior to shipment or transport off-site of any MPC containing damaged fuel.Date when full compliance will be achieved: While loading of the damaged fuel into the MPC-32s is not allowed by the CoC, it is Entergy's and Holtec's position that unloading the affected MPC-32s to restore compliance is not prudent. Rather, an exemption will be pursued to allow these affected MPC-32s to remain in storage. Unloading the subject MPCs would subject personnel to a significant amount of unnecessary dose, generate additional contaminated waste, increase the risk of a possible fuel handling accident, and increase the risk of a possible heavy load handling accident.Entergy plans to submit the required exemption within 60 days of the date of this special report. Full compliance will be achieved upon the NRC's approval of the subject exemption.

Attachment 2 OCAN01 0503 List of Regulatory Commitments Attachment 2 to OCAN01 0503 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document.

Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED C NEeck One) C OMPLETION ONE-TIME CONTINUING DATE COMMITMENT ACTION COMPLIANCE (If Required)Appropriate fuel inspection and fuel X 03/11/05 selection procedures will be revised to include restrictions prohibiting use of reports that have not received the appropriate level of review in determining acceptability of fuel assemblies considered for loading into DFS casks.Applicable procedures will be revised to X 04/29/05 require additional evaluations prior to shipment or transport off-site of any MPC containing damaged fuel.An exemption will be submitted to allow. X 03/20/05 continued storage of identified damaged fuel assemblies within the affected MPC-32s.