ML13247A036
| ML13247A036 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick, 07109168  |
| Issue date: | 08/20/2013 |
| From: | Roberts R D Studsvik Processing Facility |
| To: | Mark Lombard Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| E-130823-L | |
| Download: ML13247A036 (9) | |
Text
StudsvikVia UPSAugust 20, 2013 E-1 30823-LNuclear Regulatory Commission 11555 Rockville PikeRockville, Maryland 20852ATTN: Document Control DeskMr. Mark Lombard, DirectorDivision of Spent Fuel Storage & Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Re: 10 CFR 71.95 Report on the 8-120B Cask
Dear Mr. Lombard:
Studsvik Processing Facility Erwin, LLC (SPFE) hereby submits the attached report as required by 10CFR 71.95(a)(3) for instances in which the conditions of approval in the Certificate of Compliance forthe 8-120B Cask (CoC #9168) may not have been observed in making certain shipments.
Theattached report contains the certificate holder's (EnergySolutions) input received August 14, 2013.As stated in the certificate holder's letter, the circumstances described in this report, even thoughwritten by EnergySolutions, are applicable to SPFE as a licensed user of the cask.SPFE makes between 20 and 50 annual shipments in the 8-120B Cask. SPFE has consistently followed the then applicable Air Pressure Drop Test procedure (TR-TP-002) for each shipment.
SPFEwill continue to follow the latest revision to this procedure which currently includes the 60 minutepressure test of the vent port as part of pre-shipment testing.If you have any questions regarding this submittal, please contact me at 423-722-1975.
Sincerely, R. Dale RobertsDirectorStudsvik Processing Facility ErwinAttachments:
EnergySolutions letter dated August 14, 2013Report by ES: "Failure to Observe Certificate of Compliance Conditions for the 8-120BVent Port Leak Test Hold Time"cc: Mr. H. Stevens \652,*Mr. J. DiCamillo Mr. James D. Harris, EnergySolutions Studsvik Processing Facility Erwin, LLC: 151 T.C. Runnion Rd, Erwin, TN. 37650 Phone: 423-735-6300 Fax: 423-743-0794 www.studsvik.com ENERGYSOLUTIONS August 14, 2013
Dear Valued Customer:
In late May, 2013, an 8-120B cask user discovered a discrepancy between EnergySolutions' air pressuredrop test procedure TR-TP-002 and the 8-120B Safety Analysis Report (SAR). EnergySolutions' airpressure drop test procedure TR-TP-002 described a 20-minute hold time for the pre-shipment leak test ofthe cask vent port. The 8-120B SAR, however, specifies a hold time of 60 minutes for the test; therefore the conditions of approval in the Certificate of Compliance may not necessarily have been observed inmaking shipments.
TR-TP-002 is the basis for leak tests on all EnergySolutions shipments, as well as thesuggested procedure content for most shipments.
Based on a review performed by EnergySolutions of pastrevisions of CoCs, SARs and cask handling procedures, it appears that this discrepancy has existed forapproximately 12 years, spanning approximately 88 cask users and approximately 1,400 shipments.
EnergySolutions has completed its review of the event and developed our report in accordance with 10CFR 71.95(a)(3).
Additionally, EnergySolutions approached the NRC the week of August 4, 2013, with aproposal to make a single notification on behalf of all our cask users. The initial discussion ledEnergySolutions to believe that the NRC would grant this request.
- However, in recent discussions with theNRC, they informed us that each licensee must file their own report as required by 10 CFR 71.95.EnergySolutions filed the attached report containing the information required by 10 CFR 71.95 on August14, 2013. In the report, EnergySolutions describes the cause of the discrepancy and provides an analysisdemonstrating there is no safety significance.
We expect that the information required for individual usersto make their own notifications is contained in this report. Because the discrepancy spans over 12 years,we understand from the NRC that they do not expect a detailed review of shipments and specific instances of non-compliance to be identified as part of each licensee's 10 CFR 71.95(a)(3) report. Reference to thisreport in individual user reports would be appropriate if you so choose.We sincerely apologize for any inconvenience this issue may have caused within in your organization.
Our corrective actions as a result of this issue are intended to prevent recurrence of similar issues and toensure the highest quality of products and services that we provide.For additional
- details, please contact Phillip Thomas at phthomas@energysolutions.com or 803-541-5044.Sincerely, Js H arrisV.P. and General Manager, Cask Logistics Logistics, Processing and DisposalEnergySolutions, LLC
Attachment:
Letter and Report to NRC on 8-120B Caskcc: Tony DidgeonMark LewisDan Shrum740 Osborn Road .Barnwell, South Carolina 29812803.259.1781
.Fax 803.259.1477 ENERGYSOLUTIONS August 14, 2013 CD13-0232 Mark Lombard, DirectorDivision of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington DC 20555-0001 ATTN: Document Control Desk
Subject:
10 CFR 71.95 Report on the 8-120B Cask
Dear Mr. Lombard:
EnergySolutions hereby submits the attached report providing the information required by 10CFR 71.95(a)(3) for instances in which the conditions of approval in the Certificate ofCompliance for the 8-120B Cask (Certificate of Compliance
- 9168) may not have been observedin making certain shipments.
The circumstances described in this report are applicable to alllicensed users of the cask.If you have any questions regarding this submittal, please contact me at 801-649-2109.
Sincer,Daniel B. ShrumSenior Vice President, Regulatory AffairsEnergySolutions
Attachment:
Failure to Observe Certificate of Compliance Conditions for the 8-120B Vent PortLeak Test Hold Timecc: Michele Sampson, ChiefThermal and Containment BranchPierre M. SaverotLicensing Branch423 West 300 South, Suite 200 -Salt Lake City, LIT B4101www.energysolutions.com ENERGYSOLUTIONS Failure to Observe Certificate of Compliance Conditions for the 8-120B Vent Port Leak Test Hold TimeAugust 14, 20131) AbstractThis report provides the information required by 10 CFR 71.95(a)(3) for instances in whichthe conditions of approval in the Certificate of Compliance for the 8-120B Cask (Certificate of Compliance
- 9168) may not have been observed in making certain shipments.
Thecircumstances described in this report are applicable to all licensed users of the cask.EnergySolutions' air pressure drop test procedure TR-TP-002 describes a 20-minute holdtime for the pre-shipment leak test of the cask vent port. The 8-120B Safety Analysis Report(SAR), however, specifies a hold time of 60 minutes for the leak test of the vent port;therefore the conditions of approval in the Certificate of Compliance may not necessarily have been observed in making shipments.
TR-TP-002 is the basis for leak tests on allEnergySolutions shipments, as well as the suggested procedure content for most shipments by our authorized users.'The 8-120B CoC requires the package to be prepared for shipment and operated inaccordance with Chapter 7 of the SAR, and tested and maintained in accordance withChapter 8 of the SAR. TR-TP-002 captures the applicable SAR requirements and providesfurther detail for the development of a shipper's operating procedure.
- Recently, an 8-120Bcask user identified the hold time discrepancy between TR-TP-002 and the SAR (i.e., 20versus 60 minutes).
Based on a review of past revisions of CoCs, SARs, and cask handlingprocedures, it appears that this discrepancy has existed for approximately 12 years, spanningapproximately 88 cask users and approximately 1,400 shipments.
Upon notification and after confirmation of the discrepancy, EnergySolutions revisedTR-TP-002 to incorporate the SAR required 60-minute vent port leak test. This change toTR-TP-002 was communicated to all EnergySolutions registered cask users on June 13,2013. The SAR requires pre-shipment leak testing of the vent port only when the port hasbeen opened since the preceding vent port leak test. EnergySolutions issued a notice toregistered cask users on July 2, 2013 to clarify this issue. Operation of a package vent port isinfrequent.
However some vent ports mayhave been opened during the past 12 years; andtherefore the pre-shipment leak testing would have been required.
The licensing basis for the pre-shipment leak tests for all three of the 8-120B lid containment seals is a pressure drop calculation for the largest of the three seals (the primary lid seal).The required hold time is therefore conservative for the two seals with smaller test volumes.Because of the small size of the vent port seal test volume, EnergySolutions has determined that the 20-minute hold time meets the same criterion by which the 60-minute hold time wasderived for the larger primary lid seal. In fact, in the case of the vent port leak test, the 20-minute hold time provides substantial margin for detecting any leakage from the vent port. Ittherefore follows that there is no safety significance associated with the condition.
Since registered users of the 8-120B package are licensees, these licensees would normally prepare andissue an approved procedure to control their pre-shipment activities.
ENERGYSOLUTIONS Furthermore, there is no continuing safety concern as new lids are required to be used afterAugust 31, 2013 with different testing procedures.
Due to the long timeframc over which this condition has existed, the large number of 8-120Bcask users, the many shipments that have occurred, the difficulty of determining which if anyshipments may have been out of compliance, and the finding of no significant safety impact,EnergySolutions hereby submits this notification to summarize the issue as it applies to all8-120B users. Because of the imminent rollout of new lids and related test procedures, nofurther corrective actions by certificate users are necessary to address this leak test procedure.
- 2) Narrative Description of the Eventa) Status of Components All 8-120B components are operating normally.
b) Dates of Occurrences February 2001 to present.c) Cause of ErrorDiscrepancy between EnergySolutions air pressure drop test procedure TR-TP-002 andChapter 8 of the 8-120B SAR.d) Failure Mode, Mechanism, and EffectsNot applicable; no 8-120B packaging components have failed.e) Systems or Secondary Functions AffectedNot applicable.
f) Method of Discovery of the ErrorThe condition was identified by an 8-120B cask user.3) Assessment of Safety Consequences There is no safety consequence of performing the pre-shipment leak test of the 8-120B caskvent port using a 20-minute hold time versus the 60-minute hold time that is required by the8-120B CoC. The required hold time varies in proportion to the test volume if the testpressure and acceptance criterion remain unchanged.
Larger test volumes require longerhold times. The test volume includes the free volume of the space to be tested and thevolume of the test manifold.
For the original subject 8-120B lids, Section 4.4 of the July2012 SAR Addendum shows the calculation basis for a 60-minute hold time. Only onecalculation was presented for the large primary lid containment seal. Since the other sealshave smaller test volumes, a 60-minute hold time was conservatively specified for all seals,including the vent port.
ENERCYSOLUTIONS The SAR test volume for the primary containment seal was 103.2 cc. For the pre-shipment vent port leak test, there is no safety impact from a 20-minute hold time provided that the testvolume is less than or equal to the 20/60 times the primary containment seal test chambervolume, or (20/60)*
103.2 = 34.4 cc. The vent port test volume is equal to the combinedvolume of the test manifold (10 cc) plus a very small residual volume inside the vent port,which is less than 34.4 cc. Therefore, pre-shipment leak tests of the vent port performed using a 20-minute hold time are adequate to demonstrate compliance with maximum leakrate acceptance
- criteria, and there is no safety consequence from testing vent ports for 20minutes instead of 60 minutes.4) Planned Corrective ActionsAs noted above, upon notification and after confirmation of the discrepancy, EnergySolutions revised TR-TP-002 to incorporate the SAR required 60-minute vent port leak test andnotified registered cask users of the change.Beginning September 1,2013, the 8-120B fleet will ship with a new lid design, authorized inthe latest revision of the CoC.2 Thereafter, the 8-120B cask may no longer be used with theold seals that were authorized in Revision No. 17 of the 8-120B CoC. Shipments with thenew lids will be required to use the seals authorized in Revision 19 of the CoC. TheEnergySolutions air pressure drop test procedure TR-TP-002 is being revised and reissuedbased on the requirements of Revision 19 of the 8-120B CoC. These revisions are reviewedand approved by the EnergySolutions Cask Licensing Manager to assure that they arecompliant with the requirements of the CoC.EnergySolutions also has initiated a lifecycle procedure for managing Type B casks to assurethat CoC requirements flow through the design, fabrication, and operational phases. This is anew procedure that also would identify existing inconsistencies and prevent futureinconsistencies between the SAR and operating procedures.
The procedure will be effective August 19, 2013.The error in incorporating the revised 60-minute vent port leak rate criteria into TR-TP-002 raises a question as to whether there are other similar errors involving the flow-down ofrequirements into operating procedures.
Accordingly, EnergySolutions plans to conduct areview of the 8-120B and other EnergySolutions Type B packagings to verify that CoC andSAR requirements have been accurately translated into the prescribed operating procedures.
If any such discrepancies are found, EnergySolutions will expand the scope of these reviewsas necessary.
- 5) Previous Similar Events Involving the 8-120BNo previous similar events have been identified.
2 No shipments have been made using the new lids to date.
ENERGYSOLUTIONS
- 6) Contact for Additional Information Dan ShrumEnergySolutions Senior Vice President, Regulatory Affairs(801) 649-21097) Extent of Exposure of Individuals to Radiation or Radioactive Materials None.
3153496799 RAD PROTECTION 02:42:31 p.m. 08-20-2013 1/1Entergy Nuclear Northeast 1E ntergyEntergy Nuclear Operations.
Inc.James A. FitzPatrick NPPIJIILI& o P.O. Box 110Lycoming, NY 13093August 20, 2013JRP-13-009 U.S. Nuclear Regulatory Commission Spent Fuel Project OfficeOffice of Nuclear Material Safety and Safeguards Washington, DC 20555Gentlemen:
Pursuant to the requirements of 10 CFR 71.17, Entergy Nuclear Operations, as holder ofLicense No. DPR-59, wishes to register as a user of the EnergySolutions 10-160B package.Package identification number for this cask is USA19204/B(U)F-96, NRC Docket No. 71-9204.It is requested that future information for this package be forwarded to the following individual:
R. Thomas PhelpsNameSr. HP/Chemistry Specialist TitleJames A. FitzPatrick, NPPOrganization P.O. Box 110, Lycoming.
NY 13093Organization's AddressSincerely, R. Thomas PhelpsSr. HP/Chemistry Specialist cc: EnergySolutions Document ControlSuite 100, Center Point 11100 Center Point CircleColumbia, SC 29210
.=153496799 RAD PROTECTION 02:42:31 p.m. 08-20-2013 1/1Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.James A. FitzPatrck NPPwd-- nte WP.O. Box 110Lycoming, NY 13093August 20, 2013JRP-13-009 U.S. Nuclear Regulatory Commission Spent Fuel Project OfficeOffice of Nuclear Material Safety and Safeguards Washington, DC 20555Gentlemen:
Pursuant to the requirements of 10 CFR 71.17, Entergy Nuclear Operations, as holder ofLicense No. DPR-59, wishes to register as a user of the EnergySolutions 10-160B package.Package identification number for this cask is USA/9204/B(U)F-96, NRC Docket No. 71-9204.It is requested that future information for this package be forwarded to the following individual:
R. Thomas PhelpsNameSr. HP/Chemistry Specialist TitleJames A. FitzPatrick, NPPOrganization P.O. Box 110, Lycoming, NY 13093Organization's AddressSincerely, R. Thomas PhelpsSr. HP/Chemistry Specialist cc: EnergySolutions Document ControlSuite 100, Center Point II100 Center Point CircleColumbia, SC 29210