W3F1-2013-0054, CFR 71.95 Report on Issues Involving Radwaste Cask 8-120B

CFR 71.95 Report on Issues Involving Radwaste Cask 8-120B

ML13256A006
Person / Time
Site:	Waterford
Issue date:	09/09/2013
From:	Pellegrin B Entergy Operations
To:	Document Control Desk, NRC/NMSS/SFST
References
W3F1-2013-0054
Download: ML13256A006 (8)

Text

Entergy Operations, Inc.

17265 River Road Killonan LA 70057-3093 Tel 504-739-6203 Fax 504-739-6698 bpelleg@entergy.com Bryan J. Pellegrin Licensing Manager -Acting Waterford 3 10 CFR 71.95 W3F1-2013-0054 September 9, 2013 Attn: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852

Subject:

10CFR 71.95 Report on Issues Involving Radwaste Cask 8-120B Waterford Steam Electric Station, Unit 3 (Waterford 3)

Docket No. 50-382 License No. NPF-38

Dear Sir or Madam:

Entergy hereby submits this report pursuant to 10 CFR 71.95(a)(3) regarding potential instances in which the conditions of approval in Certificate of Compliance #9168 for the model 8-120B cask may not have been observed in making shipments from Waterford 3.

The attached notification from the certificate holder (EnergySolutions) provides the information related to the condition and requirements for 10 CFR 71.95 Reports.

On August 11, 2013, the model 8-120B cask certificate holder notified Entergy staff at Waterford 3 and other customers via email, that their investigation into the recent vent and drain port leak test finding was complete. The attached report, dated August 14, 2013, was developed by the certificate holder, and is applicable to the use of the 8-120B by Entergy at Waterford 3. Due to the time frame over which the discrepancy between the Air Pressure Drop Test Procedure TR-TP-002 and the 8-120B Safety Analysis Report (SAR) has existed, Entergy cannot rule out that shipments may have occurred with the subject vent port seal having been opened, and a subsequent 20 minute leak test performed, rather than the 60 minutes required by the SAR. The model 8-120B cask was last used at Waterford 3 in January, 2006.

This report contains no new commitments. Please contact Bryan Pellegrin, Licensing Manager - Acting, at (504) 739-6203 if you have questions regarding this information.

Sincerely, B JPJ W

Attachment:

1OCER 71.95 Report on the 8-120B Cask

W3F1-2013-0051 Page 2 cc: Mr. Steven Reynolds, Regional Administrator (acting)

U.S. NRC, Region IV RidsRgn4MailCenter@nrc.gov U.S. NRC Project Manager for Waterford 3 Kaly.Kalyanam@nrc.gov U.S. NRC Senior Resident Inspector for Waterford 3 Marlone.Davis@nrc.gov Chris.Speer@nrc.gov Daniel Shrum, EnergySolutions DShrum@energysolutions.com MSLewis@energysolutions.com JHarris@energysolutions.com

Attachment to W3FI -2013-0054 10CFR 71.95 Report on the 8-120B Cask (5 pages)

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ENERGYSOLUTIONS August 14, 2013 CD13-0232 Mark Lombard, Director Division 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 10 CFR 71.95(a)(3) for instances in which the 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. The circumstances described in this report are applicable to all licensed users of the cask.

If you have any questions regarding this submittal, please contact me at 801-649-2109.

Sincer Daniel B. Shrum Senior Vice President, Regulatory Affairs EnergySolutions

Attachment:

Failure to Observe Certificate of Compliance Conditions for the 8-120B Vent Port Leak Test Hold Time cc: Michele Sampson, Chief Thermal and Containment Branch Pierre M. Saverot Licensing Branch 423 West 300 South, Suite 200 - Salt Lake City, UT 84101 www.energysolutions.com

ENERGYSOLUTIONS Failure to Observe Certificate of Compliance Conditions for the 8-120B Vent Port Leak Test Hold Time August 14, 2013

1) Abstract This report provides the information required by 10 CFR 71.95(a)(3) for instances in which the 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. The circumstances 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 hold time 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 all EnergySolutions shipments, as well as the suggested procedure content for most shipments by our authorized users.1 The 8-120B CoC requires the package to be prepared for shipment and operated in accordance with Chapter 7 of the SAR, and tested and maintained in accordance with Chapter 8 of the SAR. TR-TP-002 captures the applicable SAR requirements and provides further detail for the development of a shipper's operating procedure. Recently, an 8-120B cask user identified the hold time discrepancy between TR-TP-002 and the SAR (i.e., 20 versus 60 minutes). Based on a review of past revisions of CoCs, SARs, and cask handling procedures, it appears that this discrepancy has existed for approximately 12 years, spanning approximately 88 cask users and approximately 1,400 shipments.

Upon notification and after confirmation of the discrepancy, EnergySolutions revised TR-TP-002 to incorporate the SAR required 60-minute vent port leak test. This change to TR-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 has been opened since the preceding vent port leak test. EnergySolutions issued a notice to registered cask users on July 2, 2013 to clarify this issue. Operation of a package vent port is infrequent. However some vent ports may have been opened during the past 12 years; and therefore 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 was derived 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. It therefore 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 and issue 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 after August 31, 2013 with different testing procedures.

Due to the long timeframe over which this condition has existed, the large number of 8-120B cask users, the many shipments that have occurred, the difficulty of determining which if any shipments 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 all 8-120B users. Because of the imminent rollout of new lids and related test procedures, no further corrective actions by certificate users are necessary to address this leak test procedure.

2) Narrative Description of the Event a) Status of Components All 8-120B components are operating normally.

b) Dates of Occurrences February 2001 to present.

c) Cause of Error Discrepancy between EnergySolutions air pressure drop test procedure TR-TP-002 and Chapter 8 of the 8-120B SAR.

d) Failure Mode, Mechanism, and Effects Not applicable; no 8-120B packaging components have failed.

e) Systems or Secondary Functions Affected Not applicable.

f) Method of Discovery of the Error The 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 cask vent port using a 20-minute hold time versus the 60-minute hold time that is required by the 8-120B CoC. The required hold time varies in proportion to the test volume if the test pressure and acceptance criterion remain unchanged. Larger test volumes require longer hold times. The test volume includes the free volume of the space to be tested and the volume of the test manifold. For the original subject 8-120B lids, Section 4.4 of the July 2012 SAR Addendum shows the calculation basis for a 60-minute hold time. Only one calculation was presented for the large primary lid containment seal. Since the other seals have smaller test volumes, a 60-minute hold time was conservatively specified for all seals, including the vent port.

ENERGYSOLUTIONS 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 test volume is less than or equal to the 20/60 times the primary containment seal test chamber volume, or (20/60)* 103.2 = 34.4 cc. The vent port test volume is equal to the combined volume 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 leak rate acceptance criteria, and there is no safety consequence from testing vent ports for 20 minutes instead of 60 minutes.

4) Planned Corrective Actions As 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 and notified registered cask users of the change.

Beginning September 1, 2013, the 8-120B fleet will ship with a new lid design, authorized in the latest revision of the CoC. 2 Thereafter, the 8-120B cask may no longer be used with the old seals that were authorized in Revision No. 17 of the 8-120B CoC. Shipments with the new lids will be required to use the seals authorized in Revision 19 of the CoC. The EnergySolutions air pressure drop test procedure TR-TP-002 is being revised and reissued based on the requirements of Revision 19 of the 8-120B CoC. These revisions are reviewed and approved by the EnergySolutions Cask Licensing Manager to assure that they are compliant with the requirements of the CoC.

EnergySolutions also has initiated a lifecycle procedure for managing Type B casks to assure that CoC requirements flow through the design, fabrication, and operational phases. This is a new procedure that also would identify existing inconsistencies and prevent future inconsistencies 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 of requirements into operating procedures. Accordingly, EnergySolutions plans to conduct a review of the 8-120B and other EnergySolutions Type B packagings to verify that CoC and SAR requirements have been accurately translated into the prescribed operating procedures.

If any such discrepancies are found, EnergySolutions will expand the scope of these reviews as necessary.

5) Previous Similar Events Involving the 8-120B No previous similar events have been identified.

2 No shipments have been made using the new lids to date.

EN ERGYSOLUTIONS

6) Contact for Additional Information Dan Shrum EnergySolutions Senior Vice President, Regulatory Affairs (801) 649-2109

7) Extent of Exposure of Individuals to Radiation or Radioactive Materials None.