IR 05000133/2007004

IR 05000133-07-004, IR 0720270-07-002, Pacific Gas and Electric Company Dated 09/16/2008

ML082600729
Person / Time
Site:	Humboldt Bay
Issue date:	09/16/2008
From:	Spitzberg D Division of Nuclear Materials Safety IV
To:	Conway J Pacific Gas & Electric Co
References
IR-07-002, IR-07-004
Download: ML082600729 (81)

Text

UNITED STATES NUCLEAR REGULATORY C O M M I S S I O N

SUBJECT:

NRC INSPECTION REPORT 050-1 33/07-004; 072-027/07-002

Dear Mr. Conway:

This report covers six inspection visits made by the U.S. Nuclear Regulatory Commission (NRC)

to your Humboldt Bay Power Plant Unit 3 Independent Spent Fuel Storage Installation (ISFSI)

between January 28 and July 31,2008.

The purpose of the inspection was to observe your dry fuel storage preoperational testing activities, to independently assess your readiness to load spent fuel into the ISFSI, and to inspect your initial fuel loading operation. The initial loading of spent fuel into dry storage occurred between July 23 and August 15, 2008. On August 25, 2008, a telephonic exit briefing was conducted with Mr. Loren Sharp, Director and Plant Manager, and other members of your staff. The enclosed report presents the scope and results of that inspection.

Based on the results of the inspection, the NRC identified a violation of NRC requirements. The violation involved failure to post copies of IO CFR Part 21 regulations and post copies of procedures providing guidance on reporting defects or noncompliances. This Severity Level IV violation is being treated as a Non-Cited Violation (NCV) consistent with Section V1.A. of the Enforcement Policy. The NCV and the circumstances surrounding the violation are described in the subject inspection report. The violation is not being cited, in part, because your staff issued a deficiency report and took appropriate corrective actions to prevent recurrence. If you contest the violation or severity level of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 ; with a copy to the Regional Administrator, Region IV and the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.qov/reading-rm/Adams.html. To the extent possible, your response, if any, should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.

Should you have any questions concerning this inspection, please contact the undersigned at (817) 860-8191 or Ray L. Kellar at (817) 860-8164.

Since rely, D. Blair Spitzberg, Ph.D., Chief Fuel Cycle and Decommissioning Branch Docket No.:

050-133 License No.: DPR-7 072-027 SNM-2514

Enclosure:

NRC Inspection Report 050-1 33/07-004; 072-027107-002 Attachments:

(I)

Supplemental Inspection Information (2) Humboldt Bay lSFSl - Inspector Notes

REGION IV==

050-1 33; 072-027 DPR-7; SNM-2514 050-1 33/07-004; 072-027/07-002 Accompanied By:

Approved By:

Attachments:

Pacific Gas and Electric Company (PG&E)

Humboldt Bay Power Plant (HBPP), Unit 3 1000 King Salmon Avenue Eureka, California 95503 January 28,2008 - August 21, 2008 R. L. Kellar, P.E., RIV/DNMS, Lead E. M. Garcia, RIV/DNMS S. P. Atwater, RIVDRP R. R. Temps, NMSS/SFST J. J. Pearson NMSS/SFST K. J. Hardin, NMSS/SFST J. B. Hickman, FSME/DWMEP B. P. Tripathi, NMSS/SFST W. E. Bezanson, Contractor (ATL)

D. B.Spitzberg, Ph.D., Chief Repository and Spent Fuel Safety Branch, Region IV 1. Supplemental Inspection Information 2. Inspector Notes

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Enclosure

EXECUTIVE SUMMARY Humboldt Bay Power Plant, Unit 3 Independent Spent Fuel Storage Installation NRC Inspection Report 050-1 33/07-004; 072-027/07-002 The Humboldt Bay Independent Spent Fuel Storage Installation (ISFSI) was granted a site-specific license by the U.S. Nuclear Regulatory Commission (NRC) on November 17,2005.

The ISFSI was designed to hold up to 400 spent fuel assemblies in five storage casks inside a concrete vault. A sixth cask will store greater than class C (GTCC) waste. The underground ISFSI storage vault was classified as being Important-To-Safety (ITS). An inspection of the ISFSI vault construction was preformed by the NRC during 2007 (ML072480245). The Holtec HI-STAR HB dry storage system, a modified storage/transportation system for the Humboldt Bay fuel, will be used to store the spent fuel.

This inspection report covers six inspection visits made by the U.S. Nuclear Regulatory Commission (NRC) to the Humboldt Bay Power Plant, Unit 3 facility Independent Spent Fuel Storage Installation (ISFSI) between January 28 and July 31, 2008. The first inspection was of the DAVIT crane which occurred on January 28-31, 2008. The inspection of the welding and lid removal process occurred on February 11-1 5, 2008. A NRC team inspection of the licensee ISFSI related programs was conducted on April 28, 2008 to May 1, 2008. The inspection of the fluid operations and heavy load handling operations occurred on June 9-1 2, 2008. The final demonstration of placing the canister in the spent fuel pool and loading a "dummy" fuel assembly was inspected on July 15-1 7, 2008. Initial loading activities were inspected from July 23-31, 2008. Several minor problems were encountered during the initial loading operation, which were effectively resolved in a safety conscious manner by licensee management personnel. The licensee staff was observed practicing effective ALARA principles during the canister loading process. The first HI-STAR cask loaded with spent fuel was placed into storage in the Humboldt Bay ISFSI vault on August 15,2008.

Crane

A functional test of the DAVIT crane was performed on June 19, 2008 which included inspections of the limit switches, the lift yoke and the stand jack system. There were no deficiencies noted during the operation of the DAVIT crane during the licensee demonstrations or the cask loading activities (Attachment 2, Crane Operational Testing, Page 3).

The Davit crane was designed and rated for a maximum load of 190,000 pounds. The initial 125% load test was conducted at the fabricator facility using test weights which totaled 248,630 pounds. The "dynamic" load test using the 100 percent weight was conducted at the fabricator facility using test weights which totaled 190,110 pounds (Attachment 2, Dynamic Load Testing & Static Load Testing, pages 4 & 6).

Vacuum Dwing / Hydro Testing I Helium

Hydrostatic testing of the Multi-Purpose Canister (MPC) confinement boundary was performed in accordance with the requirements of the ASME Code,Section I l l,

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Enclosure

Subsection NB, Article NB-6000, after field welding of the MPC lid-to-shell weld was completed (Attachment 2, Hydrostatic Testing, page 11).

The helium leak rate test of the MPC vent and drain port cover plates was demonstrated to have appropriate test sensitivity and combined leakage acceptance level (Attachment 2, MPC Helium Leak Rate, page 12).

Emerqency Planning

A review of selected training records indicated that all operations personnel were trained and qualified in both normal and emergency operation of plant systems, consistent with their assigned responsibilities. Annually, refresher training was found to have been provided for the Emergency Plan and Emergency Operating Procedures as part of overall retraining program (Attachment 2, Emergency Operations Training, page 13).

The licensee had made provisions for conducting semiannual communications checks with offsite response organizations and for biennial onsite exercises to test response to simulated emergencies (Attachment 2, Exercises 1, page 14).

Fuel

0 Several months prior to the loading operations, the NRC inspectors questioned whether sufficient documentation was available to support the licensee's determination that the fuel which was planned to be loaded could be defined as intact per the definition contained in the Technical Specification. A meeting was held between the licensee and the NRC on February 5,2008 to discuss the method that had been used by the licensee to categorize the fuel as intact. As a follow-up to the meeting, the licensee provided supplemental documentation of how the fuel could be classified as intact based on prior core operational records. The supporting documentation supplied by the licensee was reviewed by staff from the Office of Nuclear Regulatory Regulation (NRR) and the Division of Spent Fuel Storage and Transportation (SFST) to determine whether it met the requirements of the license. Based on the supplemental information provided by the licensee, the staff documented in a letter dated May 20, 2008 that the additional analyses of reactor operating records in conjunction with the prior video examinations that had been performed constituted a reasonable approach to the classification of intact and damaged fuel at Humboldt Bay (Attachment 2, ISG-1, page 17).

The inspector reviewed the characteristics of the fuel assemblies that were placed into the first canister (MPC Serial Number 28). All the fuel assemblies met the Technical Specification requirements for initial enrichment, burnup and decay heat limits. The licensee discovered that 44 assemblies had initial enrichments outside the limits imposed by the Technical Specifications and had submitted a License Amendment Request, which was approved by the NRC on August 6,2008 (Attachment 2, Spent Fuel To Be Stored, page 18).

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Enclosure

Greater-Than-Class-C (GTCC)

The licensee program for GTCC waste had not been developed. PG&E stated that it would be several years before loading of the GTCC material will occur. Therefore the NRC will delay review of the GTCC waste handling process until such time as the licensee program is in place (Attachment 2, GTCC, page 19).

Heavv Loads

Appropriate controls for heavy load handling operations in proximity to irradiated fuel were included in Attachments 7.1 and 7.2 of Procedure HBAP C-702 (Attachment 2, Procedures, page 20).

Pre-Operational Tests

Prior to beginning the loading process, the licensee had prepared for and successfully performed start-up demonstrations that included: (1) Preparing the HI-STAR HB for movement into the Spent Fuel Pool (SFP), (2) Placing the HI-STAR HB into the SFP and simulating movement using a dummy fuel assembly, (3) Removing the HI-STAR HB from the SFP and installing the MPC lid, (4) Decontaminating the HI-STAR HB, (5) Removing the MPC lid retention device, welding the MPC lid, moisture removal, and filling the MPC with Helium, (6) Installing the HI-STAR HB cask top lid, (7) Loading the HI-STAR HB on the rail dolly using the DAVIT crane, (8) Transporting the HI-STAR HB cask from the RFB to the storage vault using the transporter, (9) Positioning and lowering the HI-STAR HB into the storage vault, (1 0) Unloading activities; MPC cooldown and MPC lid weld removal (Attachment 2, Startup Testing, page 30).

Radioloqical

The initial and final contamination surveys of the first HI-STAR HB cask to be loaded at Humboldt Bay were documented as being below the specified radiological limits defined in the Technical Specifications (Attachment 2, HI-STAR Cask Surface Contamination, page 37).

The licensee performed radiological surveys of the ISFSI vault lid after the insertion of the loaded HI-STAR overpack. The results of the radiological surveys were well below the acceptance criteria specified in the Final Safety Analysis Report (Attachment 2, ISFSI Dose Rates, page 38).

Special Liftinq Devices

The licensee provided documentation that the lift yoke, which was used for lifting a critical load using a single path hoisting system, had been subjected to a load test equal to 300% of the maximum service load along with satisfactory Non Destructive Examination (NDE) test reports (Attachment 2, Acceptance Testing - Critical Loads, page 48).

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Enclosure

Special Topics

The NRC team inspection discovered that the licensee had not posted the 10 CFR Part 21 regulations as required by 10 CFR 21.26(a)(I)(i). Additionally, the licensee had not posted the procedures or references to procedures which provided specific guidance on reporting defects or noncompliance's as required by 10 CFR 21.26(a)(I)(iii). The licensee wrote SAPN 1246508 upon discovery of the noncompliance, posted the required regulations and revised appropriate procedures to include specific instructions for reporting of defects and noncompliance's. This Severity level IV violation is being treated as a Non-Cited Violation, consistent with Section V1.A of the NRC Enforcement Policy (Attachment 2, Reporting of Defects, page 51).

Technical Specification Programs

A program to evaluate and control the transportation of loaded casks between the Humboldt Bay Refueling Building and the ISFSI storage vault was required by Technical Specification 5.1.5. The revised Cask Transportation Evaluation Program met the Technical Specification requirements prior to beginning the canister loading activities (Attachment 2, Cask Transportation Evaluation Program, page 52).

Training

The Humboldt Bay ISFSI training and certification program met the requirements of 10 CFR 72.190. The program included Job Performance Measures (JPMs) to evaluate the competence of the trainees during performance of the assigned tasks (Attachment 2, Certification of Personnel, page 54).

Unresolved Items (URI)

URI 72-027/0701-01 (Closed): During the inspection of the third and final concrete placement for the Humboldt Bay ISFSI, a minor deviation was identified which was determined to be non-safety significant based on the expectation that the concrete would meet or exceed the required minimum 28 day compressive strength of 4,000 psi. The concrete compression test results from the concrete cylinders that were cast during the final concrete placement exceeded the required minimum concrete compressive strength (Attachment 2, URI-72-027/0701-01, page 55).

URI 72-027/0701-02 (Closed): During the inspection of the concrete placement activities for the Humboldt Bay ISFSI vault, several minor deviations from the ISFSI design documents, ACI code and ASTM standard requirements were identified by the licensee and the inspector. The licensee documented their 10 CFR 72.48 review and disposition of the identified ISFSI construction discrepancies in Document HBPP 2006-01. The NRC agreed that the construction changes did not impact the ability of the ISFSI vault to perform the intended Important-To-Safety (ITS) functions (Attachment 2, URI-72-027/0701-02, page 56).

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Enclosure

Welding

The inspectors found that the welding materials to be used had not been procured to the 1995 edition of the ASME Code with addenda through 1997 and that an ASME Code reconciliation had not been performed. The contractor subsequently performed the Code reconciliation and determined that the welding wire met the appropriate ASME Code requirements. To preclude a similar problem during the MPC welding operations, the welding procedure was revised to have Quality Control verify that the materials were certified to the correct Code years and if not, that a Code reconciliation had been performed (Attachment 2, Governing Code Years, Page 60).

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Enclosure

SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel:

J. Albers, Radiation Protection Manager R. Clark, QA Supervisor V. Jenson, Training and Programs Coordinator L. Pulley, ISFSI Project Manager P. Roller, Unit 3 Operations and Maintenance Manager L. Sharp, Director and Plant Manager, Nuclear M. Smith, Engineering Manager D. Sokolsky, Licensing Supervisor Contract Personnel:

M. DeWitt, Quality Verification Engineer L. Dugay, Humboldt Bay ISFSI Assistant Project Manager J. Griffin, Licensing Assistant T. Hardwick, Humboldt Bay ISFSI Project Engineer D. OConner, Quality Verification Engineer S. Rowland, Loading Supervisor S. Soler, Project Manager INSPECTION PROCEDURES USED 60854 60855 60857 Preoperational Testing of an independent Spent Fuel Storage Installation Operation of an Independent Spent Fuel Storage Installation Review of 10 CFR 72.48 Evaluations ITEMS OPENED, CLOSED, AND DISCUSSED Opened NCV 72-027/0702-01 Failure to post copies of 10 CFR Part 21 regulations and post copies of procedures providing guidance on reporting defects or noncompliances.

Closed URI 72-027/0701-01 Review the concrete compressive strength test results to confirm that the concrete compressive strength of the final ISFSI concrete placement meets the specified compressive strength of 4,000 psi at 28 days.

URI 72-027/0701-02 Review the 10 CFR 72.48 safety reviews of the changes from the design documents, ACI code and ASTM standard requirements to ensure that the changes do not impact the ISFSI vault and that a license amendment is not required.

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Attachment 1

NCV 72-027/0702-01 Failure to post copies of 10 CFR Part 21 regulations and post copies of procedures providing guidance on reporting defects or noncompliances.

Discussed None ANSI ASME CFR CTEP FSAR HBPP He HMSLD HPP GTAW GTCC ISFSI JPM LBlE LT M&TE MPC NDE NRC NRR PG&E PSlG PQR PT QA QAP SAPN SFP SFST SNM URI USACE VT WPQ LIST OF ACRONYMS American National Standards Institute American Society of Mechanical Engineers Code of Federal Regulations Cask Transporter Evaluation Program Final Safety Analysis Report Humboldt Bay Power Plant Helium Helium Mass Spectrometer Leak Detector Holtec Project Procedure Gas Tungsten Arc Welding Greater Than Class C Independent Spent Fuel Storage Installation Job Performance Measure Licensing Basis Impact Evaluation Leak Test Measuring and Test Equipment Multi-Purpose Canister Non Destructive Examination Nuclear Regulatory Commission Nuclear Reactor Regulation Pacific Gas & Electric Pounds per Square Inch (Gage)

Procedure Qualification Record Liquid Penetrant Test Quality Assurance Quality Assurance Plan Systems Application and Processes Notification (Problem report)

Spent Fuel Pool Spent Fuel Storage and Transportation Special Nuclear Material Unresolved Item United States Army Corp of Engineers Visual Test Welder Performance Qualification

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Attachment I

ATTACHMENT 2 Cntegoi y Crane Design Crane Design Crane Design Crane Inspection Crane Inspection Crane Inspection Crane Inspection Crane Load Testing Crane Load Testing Crane Load Testing Crane Load Testing Crane Load Testing Crane Load Testing Crane Load Testing Crane Maintenance Crane Operation Crane Operation Drying/Hydro/Helium DryinglH ydro/Heli um Drying/Hydro/Helium Drying/Hydro/Helium Drying/Hydro/Helium Drying/H ydro/Helium Drying/Hydro/Helium Drying/Hydro/Helium Drying /H yd ro/H el i u m Drying /H yd ro/H el i u m Humboldt Bay ISFSI (DOCKET 72-027)

INSPECTOR NOTES - TABLE OF CONTENTS Topic Automatic Controls Emergency Stop Feature Limit Switches Crane Inspection - Frequent Crane Inspection - Periodic Crane Operational Testing Hoist Overload Testing Cold Proof Testing Dynamic Load Testing Maximum Weight of Canister NDE Exams Following Cold-Proof Testing Rated Load Marking Static Load Testing Testing Requirements Preventive Maintenance Program Qualification For Crane Operator Training Canister Drying Fuel Not Subjected to Air During Loading Helium Purity for Backfilling MPC HI-STAR Drying Hl-STAR Helium Backfill HI-STAR Helium Leak Rate Hydro Pressure Gage Calibration Hydrostatic Testing MPC Helium Backfill MPC Helium Leak Rate Page #

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Category Drying/Hydro/Helium Drying/Hydro/Helium Emergency Planning Emergency Planning Emergency Planning Emergency Planning Emergency Planning Emergency Planning Emergency Planning Emergency Planning Emergency Planning Fire Protection Fire Protection Fuel Verification Fuel Verification Fuel Verification Fuel Verification GTCC Heavy Loads Heavy Loads Heavy Loads Heavy Loads Heavy Loads Heavy Loads Heavy Loads Heavy Loads NDE Certification Exams NDE Certification Exams NDE Personnel Quals NDE Personnel Quals NDE Personnel Quals NDE Personnel Quals NDE Procedures - HT Topic Pressure Relief Valves Time to Boil Emergency Equipment Emergency Operations Training Emergency Plan Changes Emergency Radiological Teams Exercises 1 Exercises 2 License Conditions Off-Normal and Accident Conditions Offsite Emergency Support Administrative Controls - Specific Hazards Fuel Tank Limits Fuel Misloading Independent Verification Spent Fuel To Be Stored GTCC Waste Cask Transport Route - 1 Cask Transport Route - 2 Component Weights for Heavy Lifts Initial Load Test on Trunnions Procedures Safe Load Paths Torquing Requirements Visual Exam of Lifting Trunnions Level Ill Exam Grading Level Ill Exam Waivers Certification Records Recertification Visual Acuity Written Practice MPC Helium Leak Rate Limit ISG-1 Page #

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Catego y NDE Procedures - PT NDE Procedures - PT NDE Procedures - PT NDE Procedures - PT NDE Procedures - PT NDE Procedures - PT NDE Procedures - PT NDE Procedures - PT NDE Procedures - PT NDE Procedures - VT NDE Procedures - VT NDE Procedures - VT NDE Procedures - VT Pre-Operational Tests Pre-Operational Tests Procedures/Tech Specs Procedures/Tech Specs P roced u res/Tech Specs Procedures/Tech Specs Procedures/Tech Specs QA QA QA QA QA Radiological Radiological Radiological Radiological Radiological Radiological Radiological Radiological Topic Acceptance Criteria Contaminants Final Interpretation Light Intensity Minimum Elements Non Standard Temperature Permanent Record Removing Excess Penetrant Surface Preparation Eye Position and Lighting Procedure Requalification Procedure Validation Visual Examination Acceptance Criteria MPC Unloading Startup Testing Cask Transporter Compliance with 10CFR50.68 Stuck Fuel Assembly During Loading MPC Unloading - MPC Temperature Vault Inspections Control of Measuring and Test Equipment Corrective Actions Procurement Controls for Material QA Audits QA Program ALARA Program Criticality Monitoring GTCC Cask Dose Rate HI-STAR Cask Surface Contamination HI-STAR HB Cask Dose Rates ISFSI Dose Rates Public Trails Radioactive Effluent Control Program Page #

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Category Radiological Radiological Records Records Records Records Records Safety Reviews Safety Reviews Slings Slings Slings Slings Slings Slings Slings Special Lifting Devices Special Lifting Devices Special Lifting Devices Special Lifting Devices Special Lifting Devices Special Lifting Devices Special Lifting Devices Special Topics Tech Spec Programs Tech Spec Programs Tech Spec Programs Training Training Training Unresolved Items Unresolved Items Welding Topic Radioactive Materials Unloading - Cask Gas Sample License Conditions Material Balance, Inventory, and Records Neutron Absorbers Physical Inventory QA Records Changes, Tests, and Experiments Part 50 Operating License Sling Heavy Load Requirements Sling Inspections - Frequent Sling Load Rating Sling Temperature Limits Sling User Training Synthetic Round Sling Removal from Service Wire Rope Sling Removal From Service Acceptance Testing - Critical Loads Ferritic Metal NDT Inspection Prior to Use Load Testing -Cask Trunnions Stress Design Factors Stress Design Factors - Critical Load Transfer Cask Trunnion Safety Factors Reporting of Defects Cask Transportation Evaluation Program ISFSI Operations Program Tech Spec Bases Control Program Certification of Personnel Health Requirement for Certified Personnel NRC Approved Training Program URI 72-027/0701-01 URI 72-027/0701-02 Hydrogen Purge & Monitoring Page #

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Category Welding Welding Materials Welding Personnel Quals Welding Personnel Quals Welding Personnel Quals Welding Personnel Quals Welding Procedures Welding Procedures Welding Procedures Welding Procedures Welding Procedures Welding Procedures Welding Procedures Welding Procedures Welding Procedures Welding Procedures Topic Welding and NDE Requirements Minimum Delta Ferrite Content Expiration Welder Performance Qual Test (WPQ)

Welder Performance Qualification (WPQ)

Welding Operator Performance Qualification Governing Code Years GTAW Essential Variables GTAW Non Essential Variables (1-14)

GTAW Non Essential Variables (1 5-27)

GTAW Supplementary Essential Variables Procedure Qualification Record (PQR)

Tack Welds Weld Repairs - Base Metal Defects Weld Repairs - Surface Defects Welding Procedure Specification (WPS)

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umboldt Bay ISFSI (72-027)

(INSPECTOR NOTES)

Category:

Crane Desiqn Topic: Automatic Controls Reference:

NUREG 0554, Section 3.3 Requirement: The automatic controls and limiting devices should be designed so that, when disorders due to inadvertent operator action, component malfunction, or disarrangement of subsystem control functions occur singly or in combination during the load handling, and assuming no components have failed in the subsystems, these disorders will not prevent the handling system from stopping and holding the load.

This requirement was achieved. Issue number 12 in the licensee's 50.59 Evaluation of the DAVIT crane states that during the setup of the computer system logic, the operator enters a variety of preset variables that establish the expected load weight, distance to be traveled and overload value. If the computer senses that the values entered by the operator are about to be exceeded, the computer shuts the crane systems down.

Finding:

During the wet operation demonstration, the licensee demonstrated the movement of the HI-STAR using the DAVIT crane. The crane operator input the distance the strand jack was to raise or lower the HI-STAR. The final raising or lowering of the cask was accomplished by the operator using a "dead-man" type of control that would stop the movement if the operator released the button.

10 CFR 50.59 Evaluation 08-01, "Installation and Testing of the Davit Crane,"

Documents Reviewed:

Revision 1 Category:

Crane Desiqn Topic: Emerqencv StoD Feature Reference:

NUREG 0554, Section 3.3 Requirement: An emergency stop feature should be installed at the control station.

Finding:

This requirement was achieved. The inspector observed the presence of the emergency stop button on the DAVIT crane controls, during the licensee crane demonstration of lifting the HI-STAR cask for placement into the spent fuel pool.

The licensee had documented a test of the emergency stop button as part of Procedure ITP 2008-001 on June 19,2008.

Procedure ITP 2008-001, "Installation and Testing of the Holtec DAVIT Crane,"

Documents Reviewed:

Revision 4A Category:

Crane Design Topic: Limit Switches Reference:

NUREG 0554, Section 5.2 Requirement: Safety devices such as limit-type switches provided for malfunction, inadvertent operator action, or failure should be in addition to and separate from the limiting Page 1 of64

means or control devices provided for operation.

This requirement was achieved. The DAVIT crane had limit switches mounted beneath the DAVIT crane cross member, which stopped the upward movement of the strand jack when the lift yoke neared the bottom face of the beam.

Additionally, the computer system that operated the strand jack was capable of monitoring the stress levels of the lifting system to stop the crane once the maximum specified load was sensed by the computer.

10 CFR 50.59 Evaluation 08-01, "Installation and Testing of the Davit Crane,"

Finding:

Documents Reviewed:

Revision 1 Category:

Crane Inspection Topic: Crane Inspection - Frequent Reference:

ASME 930.2; Section 2-2.1.2 Requirement: Cranes in regular use shall be subjected to a frequent crane inspection monthly during normal service, weekly to monthly during heavy service, and daily to weekly during severe service. The frequent inspection points should include: a)

operating mechanisms for proper operation; b) leakage in lines, tanks, valves, pumps, and other parts of the air or hydraulic systems; c) hooks for cracks, more than 15% of normal throat opening, or more than 10 degrees of twist; d) hook latches for proper operation; e) hoist ropes including end clamps; and e) the rope reeving system. All limit switches should be checked at the beginning of each work shift by inching, or running at slow speeds, each motion into its limit switch.

The applicable portions of this requirement were achieved. The DAVIT crane is not an overhead crane that is governed by ASME 930.2. and is intended for a specific application. As such Procedure ITP 2008-1 1 provided a set of pre-use inspections in Attachment 10.1. Included in the attachment were pre-use inspection requirements to be conducted when the crane was unloaded that included verification that the pivot pins were in satisfactory condition, verifying the structural members were free from signs of deformation, insuring that there were no signs of loose or missing parts, verifying that there was no evidence of cracking or deformation of the lift yoke, and insuring that there was no evidence of damage or leakage of the hydraulic hoses.

Finding:

Prior to using the DAVIT crane to lift the HI-STAR, additional pre-lift crane inspections were performed that included a detailed inspection of the lifting strands along with a verification that one of the two limit switches worked correctly. The licensee determined that the DAVIT crane pre-lift inspections were to be performed on a daily basis as necessary, which were valid for a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Due to the specific use requirements of the DAVIT crane, a pre-lift inspection frequency of daily was determined to provide adequate assurance that the crane would function as designed.

Procedure ITP 2008-1 1, "DAVIT Crane Operation and Maintenance," Revision 1 Documents Reviewed:

Page 2 of 64

Category:

Crane Inspection Topic: Crane Inspection - Periodic Reference:

ASME B30.2; Section 2-2.1.3 Requirement: Cranes in regular use shall be subjected to a periodic crane inspection annually during normal and heavy service, and quarterly during severe service. The periodic inspection includes checking for: a) deformed, cracked or corroded members; b) loose bolts or rivets; c) cracked or worn sheaves and drums; d)

worn, cracked or distorted pins, bearings, shafts, gears, and rollers; e)

excessive brake system wear; f) load, wind, and other indicators over their full range for any significant inaccuracies; g) gasoline, diesel, electric, or other power plants for improper performance; h) excessive drive chain sprocket wear and chain stretch; i) deterioration of controllers, master switches, contacts, limit switches and pushbutton stations.

The applicable portions of this requirement were achieved. The licensee had extracted the periodic recommendations from the Humboldt Bay Davit Crane Operations and Maintenance Manual and included the associated inspection requirements in SAP Maintenance Plan 2001 2302. Inspections and maintenance activities were included for the Davit crane structure and the strand jack. Inspections were specified to be performed on a monthly, six month and annual basis.

Procedure M-113, "Crane Inspections," Revision 17; SAP Maintenance Plan 2001 2302, "ISFSI Davit Crane Maintenance and Inspection," Dated July 18, 2008 Finding:

Documents Reviewed:

Category:

Crane Inspection Topic: Crane Operational Testinq Reference:

ASME B30.2; Section 2-2.2.1 Requirement: Prior to initial use, all new, reinstalled, extensively repaired, or modified cranes Finding:

Documents Reviewed:

shall have the following functions tested: (a) lifting and lowering, (b) trolley travel, (c) bridge travel, (d) limit switches, and (e) locking, limiting and indicating devices. The trip setting of the hoist limit devices shall be determined by tests with an empty hook traveling in increasing speeds up to the maximum speed.

The actuating mechanism of the limit device shall be located so that it will trip the device under all conditions in sufficient time to prevent contact of the hook or load block with any part of the trolley or crane.

This requirement was achieved. A functional test of the DAVIT crane was performed after installation had been completed. The functional test that was performed on June 19, 2008 included inspections of the limit switches, the lift yoke and the stand jack system. There were no deficiencies noted during the operation of the DAVIT crane during the licensee demonstrations or cask loading activities.

Procedure ITP 2008-001, "Installation and Testing of the Holtec DAVIT Crane,"

Revision 4A Category:

Crane Inspection Topic: Hoist Overload Testinq Reference:

NUREG 0554, Section 8.3 Requirement: The complete hoisting machinery should be tested for ability to sustain a load Page 3 of 64

hang-up condition by a test in which the load-block-attaching points are secured to a fixed anchor or an excessive load. The crane manufacturer may suggest additional or substitute test procedures that will ensure that proper functioning of protective overload devices.

' This requirement was achieved. An overload test was performed on the Davit Crane at the fabrication facility. HPP-1125-6, Section 6.4 documented that the overload alarm was received when attempting to lift a test load that exceeded the rated capacity of the crane.

Procedure HPP-1125-6, "HBPP Davit Crane Functional Test Procedure,"

Finding:

Documents Reviewed:

Revision 0 Category:

Crane Load Testinq Topic: Cold Proof Testing Reference:

Requirement: Minimum operating temperatures for the crane should be specified to reduce the NUREG 0554, Section 2.4; NUREG 0612, C-2 possibility of brittle fracture of the ferritic load-carrying members of the crane.

The minimum temperature can be determined by: 1) a drop weight test per ASTM E-208, 2) a Charpy test per ASTM A-370 or 3) a 125% cold proof test. If the crane is made of low alloy steel such as ASTM A514, cold proof testing should be done. If cold proof testing is omitted, the default minimum crane operating temperature is 70 degrees F. For crane operation at temperatures below 70 degrees F, cold proof testing must be performed and the ambient temperature at which the testing is conducted becomes the minimum crane operating temperature.

This requirement was met. The majority of the structural portion of the DAVIT crane had been fabricated from Weldox 700 material. The Dedication Report and Quality Plan included copies of Charpy Impact Testing that had been performed on the material at -40 degrees F. Selected test reports from MIC numbers C-3387, C-3389, C-3388 and C-3390 were reviewed and found to exceed the minimum specified shear strength values.

Dedication Report and Quality Plan for Weldox 700, Dated May 17, 2007 Finding:

Documents Reviewed:

Category:

Crane Load Testing Topic: Dynamic Load Testinq Reference:

NUREG 0554, Section 8.2 Requirement: After the 125% static load test, the crane should be given a full performance test with 100% of the maximum critical load attached, for all speeds and motions for which the system is designed. This should include verifying all limiting and safety control devices. The features provided for manual lowering of the load and manual movement of the bridge and trolley during an emergency should be tested with the maximum critical load attached.

This requirement was achieved. The "dynamic" load test using the 100 percent weight was conducted at the fabricator facility using test weights which totaled 190,110 pounds. The 100 percent load was conducted after the 125 percent rated load test. The individual weights used to assemble the test weight had been weighted on the Bigge yard scale, which was within it's 1 year certification Finding:

Page 4 of 64

duration. The Bigge yard scale had been calibrated by Acme Scale Co. with weights that were traceable to NlST weights.

The load test consisted of allowing the top strand jack anchor to hold the 190,110 pound test load for 10 minutes and then allowing the bottom strand jack anchor to hold the test load for 10 minutes. The next phase of the test verified that the hydraulic cylinders would move the test load, which was suspended from the strand jack, through the fully extended position back to the fully retracted position. The operation of the cylinders and potential interferences were monitored during the testing of the hydraulic cylinders.

Procedure HPP-1125-6, "HBPP Davit Crane Functional Test Procedure,"

Revision 0; Bigge Certificate of Weight for the Davit Crane Upgrade Project, Dated January 3, 2008; Acme Scale Co. Traceable Certificate of Calibration, Certificate Number 42396 Documents Reviewed:

Category:

Crane Load Testinq Topic: Maximum Weiqht of Canister Reference:

N/A Requirement: The maximum weight of the HI-STAR cask containing the canister filled with water and fuel (including dynamic loads) that will be lifted by the crane is to be verified to be within the crane's rated capacity.

This requirement was achieved. The Davit Crane was tested to 125% (248,630 pounds) and 100% (1 90,110 pounds) of the rated load as documented in Procedure HPP-1125-6. The maximum calculated weight of the lift of the HI-STAR with fuel and water from the spent fuel pool was reported as 172,200 pounds. The maximum lift is well within the rated capacity of the Davit Crane of 190,000 pounds.

Procedure HPP-1125-6, "HBPP Davit Crane Functional Test Procedure,"

Finding:

Documents Reviewed:

Revision 0 Category:

Crane Load Testinq Topic: NDE Exams Followinq Cold-Proof Testinq Reference:

Requirement: Following the 125% cold-proof testing, a nondestructive examination of the NUREG 0554, Section 2.4 and 2.6 welds whose failure could result in the drop of a critical load should be performed. If any of these weld joint geometries would be susceptible to lamellar tearing, the base metal at the joints should be nondestructively examined.

This requirement was achieved. Following the 125 percent load test of the Davit crane a nondestructive visual examination was performed by a Level I I non-destructive examiner. The examiner measured the pin holes to determine if any deformation had occurred. The diameter of all the pin holes was determined to be satisfactory. The examiner also performed a visual exam of the accessible portions of the critical welds identified in Exhibit 7.5 for signs of damage or deformation. No damage or deformations were discovered and all the critical welds were determined to be satisfactory. The inspector reviewed the certification records for the Level I I examiner and determined that the examiner Finding:

Page 5 of 64

was qualified to perform visual and liquid penetrant examinations.

Procedure HPP-1125-6, "HBPP Davit Crane Functional Test Procedure,"

Revision 0 and Revision 1; NDT Certification Records for Level II Examiner Documents Reviewed:

Category:

Crane Load Testinq Topic: Rated Load Markinq Reference:

NUREG 0554, Section 2.2 Requirement: The maximum critical load should be clearly marked on the crane.

Finding:

This requirement was achieved. The licensee had clearly marked the rated load on the crane of 190,000 pounds.

Documents None Reviewed:

Category:

Crane Load Testinq Topic: Static Load Testinq Reference:

NUREG 0554, Section 8.2 Requirement: The crane should be static load tested at 125% of the maximum critical load.

The test should be conducted at all positions generating maximum strain in the bridge and trolley structures and other positions as recommended by the designer or manufacturer This requirement was achieved. The Davit crane was designed and rated for a maximum load of 190,000 pounds. The initial 125% load test was conducted at the fabricator facility using test weights which totaled 248,630 pounds. The individual weights used to assemble the combined test weight had been weighted on the Bigge yard scale, which was within it's 1 year certification duration. The Bigge yard scale had been calibrated by Acme Scale Co. with weights that were traceable to NlST standards. A load cell had also been utilized during the load test which registered the test load as 249,800 pounds.

Finding:

The load test consisted of allowing the top strand jack anchor to hold the 248,630 pound test load for 10 minutes and then allowing the bottom strand jack anchor to hold the test load for 10 minutes. The next phase of the test verified that the hydraulic cylinders would move the test load, which was suspended from the strand jack, through the fully extended position back to the fully retracted position. The operation of the cylinders and potential interferences were monitored during the testing of the hydraulic cylinders.

After assembly at the plant site, another 125% load test was performed of the Davit crane assembly by lifting the load with the crane in the fully retracted position. This test was performed to test the plates that were mounted to the wall, which had not been included in the load test performed at the fabricator facility. The test weights used were determined to be 240,350 pounds by the licensee. An inspection after the load test of the Davit crane did not find any evidence of cracking, deformation, fluid leakage or other damaged parts.

Documents Reviewed:

Procedure HPP-1125-6, "HBPP Davit Crane Functional Test Procedure,"

Revision 0; Bigge Certificate of Weight for the Davit Crane Upgrade Project, Page 6 of 64

Dated January 3, 2008; Acme Scale Co. Traceable Certificate of Calibration, Certificate Number 42396 Category:

Crane Load Testinq Topic: Testinq Requirements Reference:

Requirement: The following load testing will be performed for the DAVIT crane and strand jack LAR Dated July 9, 2004 system prior to delivery to the site:

a. The strand jacks will be bench tested per NUREG-0554, as applicable b. The strands will be individually load tested per NUREG-0554, as applicable c. The DAVIT crane structure will be assembled and load tested per NUREG-0554 d. The lift yoke will be bench tested per ANSI N14.6 The applicable requirements were achieved. The strand jack was tested as part of the 125 percent load tests performed at the manufacturer's facility and at Humboldt Bay. Samples of the strand were sent off to a lab to determine their ultimate strength. The results of the tests indicated that each strand of the total of 19 strands had an ultimate strength of 63,910 pounds. This provided an ultimate strength for all the individual strands of 1,214,290 pounds. The DAVIT crane structure was load tested at both the manufacturer's facility and at Humboldt Bay. A separate functional test was performed at Humboldt Bay to demonstrate that the assembled structure operated as designed. The lift yoke was load tested according to the requirements of ANSI N14.6 by lifting a load of three times the weight to be lifted (172,200 pounds) using a combined test weight of 550,800 pounds.

Procedure ITP 2008-001, "Installation and Testing of the Holtec DAVIT Crane,"

Revision 4A; Procedure HPP-1125-6, "HBPP Davit Crane Functional Test Procedure," Revision 0; Drawing 5381, "HB Davit Crane Lift Anchor Assembly,

Revision 4 Finding:

Documents Reviewed:

Category:

Crane Maintenance Topic: Preventive Maintenance Proqram Reference:

ASME B30.2; Section 2-2.3.1 Requirement: A preventive maintenance program should be established based on the crane manufacturer's or a qualified person's recommendations. Dated records should be kept where readily available to appointed personnel.

This requirement was achieved. The licensee incorporated maintenance for the DAVIT crane strand jack system and the boom arm hydraulic system in Section 6.3 and 6.5 of Procedure ITP 2008-1 1, respectively. The Davit Crane vendor manual was referenced for additional guidance.

Procedure ITP 2008-1 1, "Davit Crane Operation and Maintenance," Revision 0 Finding:

Documents Reviewed:

Category:

Crane Operation Topic: Qualification For Crane Operator Reference:

ASME B30.2, Section 2-3.1.4 Requirement: Qualification to operate a floor operated crane, requires the operator to pass a Page I of 64

practical operating examination specific to the type of crane to be operated.

This requirement was achieved. The licensee required the operators of the DAVIT crane to pass a written exam and to successfully pass the job performance measures before operator qualification was approved. The licensee also required the crane operator to meet the medical examination requirements contained in ANSI N546-1976.

Lesson Plan LP-HOL-06, "Dry Storage System Load Handling," Revision 0; Instructor Lesson Guide HBAP B-2, "ISFSI Loading," Revision 17; Job Performance Measure JPM ISFSI-217, "DAVIT Crane Operations," Revision 1 Finding:

Documents Reviewed:

Category:

Crane Operation Topic: Traininq Reference:

LAR Dated July 9, 2004 Requirement: The augmented training will also include instruction on the special lifting devices, heavy load exclusion areas, safe load paths and equipment testing requirements. The training will be completed prior to any heavy load movements of the cask.

This requirement was achieved. The inspector reviewed two lessons plans (LP-HOL-06 and HBAP B-2) along with the job performance measure JPM ISFSI-217 and found that the overall training program offered to the DAVIT crane operators included instruction on the special lifting devices, heavy load exclusion areas, safe load paths and equipment testing requirements.

Lesson Plan LP-HOL-06, "Dry Storage System Load Handling," Revision 0; Instructor Lesson Guide HBAP B-2, "ISFSI Loading," Revision 17; Job Performance Measure JPM ISFSI-217, "DAVIT Crane Operations," Revision 1 Finding:

Documents Reviewed:

Category:

Drvinq/Hvdro/Helium Topic: Canister Drvinq Reference:

HB Technical Specification SR 3.1.I.I Requirement: During the canister drying operation verify that the MPC-HB cavity vacuum drying pressure is less than or equal to 3 torr for greater than or equal to 30 minutes OR while recirculating helium through the MPC-HB cavity, verify that the gas temperature exiting the demositurizer is less than or equal to 21 degrees F for greater than or equal to 30 minutes or the dew point of the gas exiting the MPC is less than or equal to 22.9 degrees F for greater than or equal to 30 minutes.

This requirement was achieved. Procedure HPP-1125-300, Section 6.25 specified that the vacuum drying process for the MPC would be acceptable after the vacuum was held for a minimum of 30 minutes with a pressure of less than or equal to 3 torr. The licensee has also considered the instrument error of the vacuum gauges and had appropriately reduced the required vacuum pressure to be less than or equal to 2.64 torr. The licensee demonstrated the vacuum drying process and held a vacuum of less than 2.64 torr for 30 minutes on a portion of the Vacuum Drying System configuration.

Finding:

The vacuum gages had been calibrated on June 19, 2008. The calibration Page 8 or64

records indicated that the measured error of the gages in the range of interest (3 torr) was between 0.03 and 0.04 torr. Therefore the uncertainty included in the required vacuum reading for acceptance of the test of 0.36 torr conservatively bounded the observed error in the vacuum instruments.

Procedure HPP-1125-300, "Procedure for Drying, Backfill, and Sealing the Documents Reviewed:

MpC," Revision 3 Category:

Drving/HVdro/Helium Topic: Fuel Not Subiected to Air Durinq Loadinq Reference:

Requirement: Fuel assemblies are never subjected to air or oxygen during loading and Finding:

HI-STAR 1008 FSAR, Table 8.0.1 unloading operations.

This requirement was achieved. The inspector witnessed portions of the loading and unloading demonstrations performed by the licensee and reviewed Procedures HPP-1125-500 and HPP-1125-300. The fuel inside the MPC was not subjected to air during the processes. An inert gas was utilized whenever the water was removed from the MPC.

Procedure HPP-1125-500, "Procedure for MPC Unloading at Humboldt Bay Power Plant," Revision 0; Procedure HPP-1125-300, "Procedure for Drying, Backfill, and Sealing the MPC," Revision 3 Documents Reviewed:

Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

Drvinq/Hvdro/Helium Topic: Helium Puritv for Backfillins MPC HB FSAR, Section 10.2.2.3 Helium used for the backfill of MPC shall have a purity of greater than or equal to 99.995%.

This requirement was achieved. The helium had been supplied by Praxair along with a Certificate of Analysis for Helium 5.0. The certificate specified that the Oxygen was <I

.O ppm; the moisture was ~ 3. 0 ppm; the hydrocarbons were < I.O ppm and nitrogen was <4.0 ppm. The licensee determined that the helium was at least 99.9991 % pure, which met the requirement of having a purity of greater than or equal to 99.995%.

The helium bottles were observed to be marked as ultra-pure helium and contained in a "six-pack" of six bottles connected by a common header system for use during the helium backfilling operations.

Praxair Helium Certificates for PG&E PO Number 137632, Dated June 24, 2008 Category:

Reference:

Requirement:

Finding:

Drvinq/Hvdro/Helium Topic: HI-STAR Drvinq HB Technical Specification SR 3.1.2.1 Verify that the HI-STAR Overpack annulus vacuum drying pressure is less than 3 torr for greater than or equal to 30 minutes.

This requirement was achieved. The licensee demonstrated the vacuum drying process for the HI-STAR Overpack. Section 7.2.31 of Procedure HPP-1125-400 specified that the vacuum drying of the HI-STAR Overpack was considered Page 9 of 64

acceptable after the pressure remained less than or equal to 2.5 torr for a minimum of 30 minutes. The Technical Specification requirement of 3 torr had been reduced to allow for instrument error.

The vacuum gage had been calibrated on July 8, 2008. In the range of the vacuum test of 3 torr, the error was recorded to be +/- 0.04 torr. The acceptance criteria of 2.5 torr for the vacuum test was determined to be conservative.

Procedure HPP-1125-400, "Procedure for HI-STAR Sealing, Processing and Transport to the Storage Vault at Humboldt Bay Nuclear Power Plant," Revision 6 Documents Reviewed:

Category:

Drvinq/Hvdro/Helium Topic: HI-STAR Helium Backfill Reference:

Requirement: Verify that the HI-STAR Overpack annulus helium backfill pressure is greater Finding:

HB Technical Specification SR 3.1.2.2 than or equal to 10 psig and less than or equal to 14 psig.

This requirement was achieved. Procedure HPP-1125-400, Step 7.3.9 required that the HI-STAR Overpack be backfilled with helium until a pressure between 10.5 and 13.5 psig was achieved. This backfill pressure considered the instrument accuracy in the specified backfill pressure. This process was successfully demonstrated by the licensee using HPP-1125-400 during the week of June 9,2008.

Procedure HPP-1125-400, "Procedure for HI-STAR Sealing, Processing and Transport to the Storage Vault at Humboldt Bay Nuclear Power Plant," Revision 2 Documents Reviewed:

Category:

Drvinq/HVdro/Helium Topic: HI-STAR Helium Leak Rate Reference:

Requirement: Verify that the total helium leak rate through the Overpack closure plate inner HB Technical Specification SR 3.1.2.3 mechanical seal, the Overpack vent port plug seal and the Overpack drain port plug seal is less than or equal to 4.3 E-6 atm-cclsec (He).

This requirement was achieved. Appendix I of Procedure MSLT-OP-Holtec specified that the acceptable combined leak rate of the Overpack closure plate inner seals and vent / drain plug seals were to be less than or equal to 4.3 X 10-6 atm-cc/sec. The measured leak rates of the Overpack closure plate inner seal and the vent port plug seal were 2.0 X 10-9 and 9.0 X 10-8 atm-cclsec respectively during the licensee demonstration.

Procedure MSLT-OP-Holtec, "Helium Mass Spectrometer Leak Test Procedure Holtec HI-STAR Overpack," Revision 0 Finding:

Documents Reviewed:

Category:

Drving/Hvdro/Helium Topic: Hvdro Pressure Gage Calibration Reference:

ASME Section Ill, Article NB-6413 Requirement: All test gages shall be calibrated against a standard dead weight tester or a calibrated master gage. The gages shall be calibrated before each test or series of tests. A series of tests is that group of tests using the same pressure test gage or gages, which is conducted at the same site within a period not Page 10 of 64

exceeding 2 weeks.

This requirement was achieved. The licensee utilized two Omega/Dwyer pressure displays with transducers to verify the pressure during the hydro-test.

The inspector reviewed the calibration reports and found that the two instruments were accurate to within +/- 0.3 psi in range that the hydro test was conducted. The licensee was in the process of revising the loading procedure to specify that the gages were to be used during the loading operations for a two week period and then recalibrated at the time of the inspection.

Calibration Reports for Omega/Dwyer pressure display and transducer serial numbers 80201 34 and 80201 35 Finding:

Documents Reviewed:

Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

Drving/Hvdro/Helium Topic: Hydrostatic Testinq HI-STAR 1008 FSAR, Section 9.1.2.2.2 Hydrostatic testing of the MPC confinement boundary shall be performed in accordance with the requirements of the ASME Code, Section Ill, Subsection NB, Article NB-6000, when field welding of the MPC lid-to-shell weld is completed. The hydrostatic pressure for the test is 125+5,-0 psig, which is 125% of the design pressure of 100 psig. Following the 10 minute hold period at hydrostatic pressure the surface of the MPC lid-to-shell weld will be visually examined and re-examined by dye penetrant examination.

This requirement was achieved. Step 9.2.2 of Procedure PI-900971 -01 specified that the quality control inspector was to visually examine the lid-to-shell weld after the hydrostatic pressure of 126-1 30 psig had been held for a minimum of ten minutes. Step 9.2.3 required the quality control inspector to perform the liquid penetrant examination after the hydrostatic test was completed. The inspector witnessed the licensee demonstrations of the hydro test and associated inspections.

Procedure PI-900971 -01, "Closure Welding of Multi-Purpose Canisters at Humboldt Bay," Revision 2 Category:

DrvindHvdrolHelium Topic: MPC Helium Backfill Reference:

Requirement: Verify that the MPC-HB helium backfill pressure is greater than equal to 45.2 HB Technical Specification SR 3.1.I

.2 psig and less that or equal to 48.8 psig at a reference temperature of 70 degrees F.

This requirement was achieved. The licensee determined the minimum and maximum volume of the MPC with the various fuel bundles. Using this information, the licensee determined the volume of helium required to fill the MPC at the standard temperature of 70 degrees F. The minimum and maximum volumes were determined to vary between approximately 629 and 649 cubic feet of helium, depending on the number of fuel channels installed. The licensee provided documentation that the specified backfill volumes equated to a pressure range of between 45.2 and 48.8 psig at a reference temperature of 70 degrees F.

Finding:

Page 11 of 64

Documents Holtec Report HI-2084081, "MPC Free Volume and Helium Backfill Calculation,"

Reviewed:

Revision 0; Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

Drvinq/Hvdro/Helium Topic: MPC Helium Leak Rate HB Technical Specification SR 3.1.I

.3 Verify that the total helium leak rate through the MPC-HB vent and drain port cover plate welds is less than or equal to 1.OE-7 atm-cc/sec (He).

This requirement was achieved. Procedure MSLT-DSC-HOLTEC provided the instructions to perform the helium leak rate test of the MPC vent and drain port cover plates. Appendix I I contained appropriate instructions for test sensitivity and for the combined leakage acceptance level of less than or equal to 1.OE -7 atm cc/sec (He).

Procedure MSLT-DSC-HOLTEC, "Helium Mass Spectrometer Leak Test Procedure Dry Fuel Storage Container," Revision HB-0 Category:

Drvinq/Hvdro/Helium Topic: Pressure Relief Valves Reference:

HI-STAR 1008 FSAR, Figures 8.1.19; 8.1.21; Requirement: Pressure relief valves in the water and gas processing systems limit the MPC pressure to acceptable levels. Reference Figures 8.1.19, 8.1.21, and 8.1.23.

Finding:

This requirement was achieved. The inspector reviewed the calibration sheets for the relief valves used during the dry cask loading process. All the relief valves had been checked and adjusted as necessary. The highest set point was for RV-10, which was used during the hydro test of 125 +5/-0 psig. RV-10 was set to lift at 140 psig. The remainder of the relief valves were well below the MPC rated pressure of 100 psig.

Relief Valve Data Sheet for RV-IO, Dated June 27, 2008; Relief Valve Data Sheet for RV-1, Dated June 30, 2008; Relief Valve Data Sheet for RV-2, Dated June 27, 2008; Relief Valve Data Sheet for RV-3, Dated June 30, 2008; Relief Valve Data Sheet for RV-11, Dated June 30, 2008 Documents Reviewed:

Category:

Drving/Hvdro/Helium Topic: Time to Boil Reference:

HB FSAR, Section 10.2.2.1 Requirement: Water inside the MPC cavity is not permitted to boil. A limit is imposed on the maximum allowable time duration for fuel to be submerged in water after a loaded HI-STAR cask is removed from the pool and prior to the start of canister drying operations. If the time to boil limit is approaching, action will be taken to cool the water inside the canister or the HI-STAR will be placed back in the spent fuel pool.

This requirement was achieved. The licensee included the time to boil limit in Procedure HPP-1125,-200. In Section 7.5.8, the procedure stated that the time to boil was calculated to be 338 hours0.00391 days <br />0.0939 hours <br />5.588624e-4 weeks <br />1.28609e-4 months <br /> when the spent fuel pool water temperature remained at 90 degrees F, or less. In the event that the spent fuel pool water temperature was greater than 90 degrees F, Step 7.6.1 provided the Finding:

Page 12 of 64

equation to calculate the appropriate time to boil. Step 7.6.2.2 required the Cask Supervisor to verify that the time to boil had been determined correctly.

Procedure HPP-1125-200, "Procedure for MPC Loading At Humboldt Bay Unit Documents Reviewed:

3.11 Revision 0 Category:

Reference:

HB ISFSl Emergency Plan Requirement: Equipment which is designated for use only in the event of an emergency, such E merqencv Pla nni nq To pic: Em e rqe n cv Eq u i p me n t as survey instruments and emergency kits, are inspected on a semiannual basis or after each use to verify both availability and functionality. When emergency equipment is removed for calibration or repair, it shall be replaced with calibrated operational equipment.

This Requirement was achieved. Procedure STP-33.3.2 required quarterly inventory and testing of equipment for emergency kits. The inspector sampled random kits which were noted to be current. To ensure that the minimum number of emergency kits were available, Procedure EPlP R-10 required that equipment be replaced when removed for repair or calibration.

Procedure STP-3.33.2, Vol. 6, "Satellite Phone Test and (Evacuation)

Emergency Response Kit Inventory," Revision. 1 ; Procedure EPlP R-I 0, Vol. 3,

"Emergency Plan Management," Revision 7 Finding:

Documents Reviewed:

Category:

Eme rqencv Plan ni nq Topic: Emerqencv Operations Traininq Reference:

HB ISFSl Emergency Plan Requirement: All operations personnel are trained and qualified in both normal and emergency operation of plant systems, consistent with their assigned responsibilities.

Annually, refresher training is provided for the Emergency Plan and Emergency Operating Procedures as part of overall retraining program.

This requirement was achieved. Selected training records were reviewed by the inspector and found to meet the stated requirement and were current.

Procedure HBAP 8-2, Attachment. 5, "Training Session Record(s)," Revision 17 HBPP Information I Qualifications System (Computer Record)

Finding:

Documents Reviewed:

Category:

Emerqencv Planning Topic: Emersencv Plan Chanqes Reference:

10 CFR 72.44(f)

Requirement: Within six months of any changes made to the emergency plan, the licensee shall submit a report containing a description of the changes to the appropriate regional office and HQ.

This requirement was achieved. Procedure EPlP R-10 required that a report be sent to the NRC 30 days after a change was effective. No non-compliance issues were identified.

Procedure HBAP E-4, "Procedure Controls," Revision 61; Procedure EPlP R-I O, "Emergency Plan Management," Revision 7 Finding:

Documents Reviewed:

Page 13 of 64

Category:

E merqencv Plan ni nq Topic: Emerqencv Radioloqical Teams Reference:

HB ISFSI Emergency Plan Requirement: Emergency Radiological Teams will ordinarily be two-person teams. Each team should be headed by an individual who is trained in emergency radiological monitoring.

This requirement was achieved. The inspector reviewed the site requirements and training records and determined that appropriate staff were on the team and that their training was current.

Procedure HBAP B-2, Attachment 5, "Training Session Record(s)," Revision 17; HBPP Information / Qualifications System (Computer Record)

Finding:

Documents Reviewed:

Category:

Emerqencv Planninq Topic: Exercises 1 Reference:

10 CFR 72.32(a)( 12)

Requirement: Provisions for conducting semiannual communications checks with offsite response organizations and biennial onsite exercises to test response to simulated emergencies. Radiological / Health Physics, Medical, and Fire drills shall be conducted annually. Semiannual communications checks with offsite response organizations must include the check and update of all necessary telephone numbers.

This requirement was achieved. The licensee has conducted biennial onsite exercises for simulated emergencies. The licensee has conducted communication checks and phone number verification for offsite response organizations. Radiological, medical, and fire drills had been conducted annually.

ISFSI Emergency Plan, Volume 3, Revision 0; Drill Plan and Summary for May 15, 2007, September 27, 2007, December 21, 2007, and January 18, 2008 Finding:

Documents Reviewed:

Category:

E merg encv Plan ni nq Topic: Exercises 2 Reference:

I O CFR i2.32(a)( 12)(ii)

Requirement: Participation of offsite response organizations in biennial exercises, although recommended, is not required. Exercises must use scenarios not known to most exercise participants. The licensee shall critique each exercise using individuals not having direct implementation responsibility for conducting the exercise.

Critiques of exercises must evaluate the appropriateness of the plan, emergency procedures, facilities, equipment, training of personnel, and overall effectiveness of the response. Deficiencies found by the critiques must be corrected.

This requirement was achieved. Exercise critiques were conducted by appropriate individuals with adequate expertise. The critiques adequately addressed plan characteristics and effectiveness. Identified deficiencies were addressed in a timely manner.

ISFSI Emergency Plan, Volume 3, Revision 0; Drill Plan and Summary for May 15,2007, September 27, 2007, December 21, 2007, and January 18,2008 Finding:

Documents Reviewed:

Page 14 of 64

Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

E merqen cv Pla nn i nq Topic: License Conditions License SNM-2514, Condition 15 The licensee shall follow the Humboldt Bay ISFSI Emergency Plan dated December 15,2003, as revised or supplemented on October 1,2004 and as further supplemented and revised in accordance with 10 CFR 72.44(f).

This requirement was achieved. The ISFSI Emergency Plan was consistent with the HBPP Emergency Plan and was being met. At the time of the inspection, the EPIPs were being revised to comply with both the Emergency Plan and the ISFSI Emergency Plan.

ISFSI Emergency Plan, Revision 0; Procedure EPlP R-4, "Instructions for Emergency Response Personnel," Revision 49; Procedure EPlP R-6,

"Emergency Plan Activation," Revision 20; Procedure EPlP R-I 0, "Emergency Plan Management," Revision 7; Humboldt Bay Power Plant Emergency Plan, Category:

E merqencv Plan ni nq Topic: Off-Normal and Accident Conditions Reference:

HB FSAR, Section 4.4.1.2.4 Requirement: For off-normal and accident conditions, the necessary response is a function of the nature of the event. Chapter 8 of the FSAR describes the off-normal and accident events for which the cask system is designed and provides suggested corrective actions. Based on the circumstances of an actual event, plant personnel will take appropriate action ranging from inspections of the affected cask components to movement of the cask back into the SFP and unloading the spent fuel assemblies.

This requirement was achieved. As described in Chapter 8 of the FSAR, no specific reactive actions were required. Multiple areas were addressed proactively in the Cask Transportation Evaluation Program to preclude the need for compensatory actions.

ISFSI Emergency Plan, Volume 3, Revision 0; HB ISFSI FSAR, Chapter 8, Revision 1 ; ITP 2008-05, "Cask Transportation Evaluation Program," Draft Finding:

Documents Reviewed:

Category:

Reference:

Requirement:

Finding:

Emerq en cv Plan ni nq Topic: Offsite Emergency Support 10 CFR 72.32(a)( 15)

The applicant's emergency plans shall include a brief description of the arrangements made for requesting and effectively using offsite assistance on site and provisions that exist for using other organizations capable of augmenting the planned onsite response.

This requirement was achieved. The licensee had letters of agreement with two hospitals, an ambulance service, a local fire district, and local law enforcement agencies. The letters of agreement were current. Appropriate drills had been conducted with support organizations in the past year. ISFSI operations will not alter agreements for hospital or ambulance support.

Page 15 of 64

Documents Reviewed:

ISFSI Emergency Plan, Revision 0; Letters of Agreement: PML-07-54, November 20, 2007; PML-07-55, November 20, 2007; PML-07-56, October 29, 2007; and PML-07-57, November 1, 2007.

Category:

Fire Protection Topic: Administrative Controls - Specific Hazards Reference:

HB FSAR, Section 2.2.2.2.1 & 2.2.2.2.2 Requirement: Administrative controls will be used to ensure that the 3,000 gallon capacity gasoline tanker truck and the 2,098 gallon capacity propane storage truck are not allowed on site during any transport operations. Additionally the 30 psi portion of the 12-inch natural gas line is shut-off and depressurized during transport operations. The site will not permit transport operations while the 65,000 barrel gasoline barge is in the bay.

This requirement was achieved. The Cask Transportation Evaluation Program (CTEP) included a check of Chevron barge traffic and a request for coast guard assistance. Fuel deliveries to the site were barred during fuel movement. The gas line to Unit 2 will be isolated and depressurized during fuel movement. The propane tank is to be emptied for the duration of fuel movement.

HB ISFSI FSAR Sections 2.2.2.2.2 & 2.2.2.4 & 8.2.6, Revision 1 ; ITP 2008-05,

"Cask Transportation Evaluation Program," Draft; TBD-301 "Fire Hazards Analysis," Revision 8 Finding:

Documents Reviewed:

Category:

Fire Protection Topic: Fuel Tank Limits Reference:

HB FSAR, Table 2.2-1 Requirement: The onsite transporter fuel tank will contain no more than 50 gallons of diesel Finding:

fuel while handling a loaded overpack.

This requirement was achieved. The fuel capacity of the Vertical Cask Transporter was 45 gallons of diesel fuel, therefore it physically cannot contain more than 50 gallons of fuel.

ISFSI FSAR Table 2.2-1, Rev I; Procedure ITP 2008-05, "Cask Transportation Evaluation Program," Revision Draft; Procedure TBD-301, "Fire Hazards Analysis," Revision 8; Procedure HPP-1125-400, "Procedure for HI STAR Sealing Processing and Transport to the Storage Vault at Humboldt Bay Power Plant," Revision 0; Report HI-2002501, "Functional Specification for the Diablo Canyon Cask Transporter," Revision 8 Documents Reviewed:

Category:

Fuel Verification Topic: Fuel Misloadinq Reference:

HB Technical Specification 2.2 Requirement: If any of the fuel specifications or loading conditions of Technical Specification 2.1 are violated, the licensee shall:

1. Place the affected fuel assemblies in a safe condition 2. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, notify the NRC Operations Center.

3. Within 30 days, submit a special report which describes the cause of the violation, and actions taken to restore compliance and prevent recurrence.

Page 16 of 64

Finding:

Documents Reviewed:

This requirement was initially not completed by the licensee, but had been corrected before fuel loading had begun. During the team inspection the station procedures had not been updated to address reporting requirements for a fuel misload. The inspector reviewed a Work Package that provided directions to place the affected fuel assemblies in a safe condition meeting the first requirement. Procedure HBAP C-11 was updated in revision 11 to include the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 30 day ISFSI reporting requirements of Technical Specification 2.2.

Procedure B-5, "Movement of Material in the Spent Fuel Pool," Revision 36; Procedure ITP 2008-07, "Cask Loading Plan," Revision 0; Procedure IAPC-101-

" I S F S I No n - Ro u t i ne Not if i c a t i o n and Reporting to Reg u I a tory Agencies, 'I Appendix 6.1 - Guidelines, 24-hour notifications, Draft; Work Package HBAP C-45 #2, Attachment 7.1, Draft; Procedure HBAP C-11, "Non-Routine Notification and Reporting to the Nuclear Regulatory Commission (NRC)," Revision 1 OA and Revision 1 1 ; Procedure HBAP E-1 1, "Licensee Event Report Processing,"

Revision 5C Category:

Fuel Verification Topic: Independent Verification Reference:

HB Technical Specification 5.1.3.f.

Requirement: The correct MPC-HB loading is to be independently verified by a cognizant engineer to ensure that the fuel assemblies in the MPCs are placed in accordance with the original loading plan.

This requirement was achieved. Procedure ITP 2008-14 required an independent verification of the video inspection of the fuel assemblies located in the MPC that specifically required that the fuel assembly serial number was legible and matched the fuel assembly move sheets for the corresponding MPC cell number. The inspector reviewed a copy of the DVD which showed each fuel assembly in the corresponding MPC cell location. The fuel assembly serial numbers were visible in the DVD.

Finding:

Additionally, Work Package HBAP C-45, Attachment 7.1, required an independent verification by the job supervisor that the fuel assemblies had been placed in accordance with the MPC loading plan.

Procedure B-5, "Movement of Material in the Spent Fuel Pool," Revision 36; Procedure ITP 2008-07, "Cask Loading Plan," Revision 0; Procedure HPP-1125-200, "Procedure for MPC Loading at Humboldt Bay Unit 3," Revision 0; Work Package HBAP C-45 #2, Attachment 7.1, Revision Draft; Procedure ITP 2008-14, "PG&E MPC Closure Activities," Revision 0 Documents Reviewed:

Category:

Fuel Verification Topic: ISG-1 Reference:

Interim Staff Guidance-I (ISG-1)

Requirement: Damaged fuel should be classified based on ISG-1 "Damaged Fuel."

Finding:

This requirement was achieved. Several months prior to the initial loading operation, the NRC inspectors questioned whether sufficient documentation was available to support the licensee's determination that the fuel which was planned to be loaded could be defined as intact per the definition contained in the Page 17 of 64

Technical Specification. A meeting was held between the licensee and the NRC on February 5,2008 to discuss the method that had been used by the licensee to categorize the fuel as intact. As a follow-up to the meeting, the licensee provided supplemental documentation of how the fuel could be classified as intact based on prior core operational records. The supporting documentation supplied by the licensee was reviewed by both NRR and SFST staff to determine whether it met the requirements of the license. Based on the supplemental information provided by the licensee, the staff documented in a letter dated May 20, 2008 that the additional analyses of reactor operating records in conjunction with the prior video examinations that had been performed constituted a reasonable approach to the classification of intact and damaged fuel at Humboldt Bay.

PG&E Letter HIL-08-002, Dated April 24, 2008; NRC letter to John Conway, Documents Reviewed:

Dated May 20, 2008 Category:

Fuel Verification Topic: Spent Fuel To Be Stored Reference:

HB Technical Specification 2.1.I Requirement: Intact fuel assemblies and damaged fuel assemblies meeting the limits specified in Tables 2.1-1 and 2.1-2 may be stored in the SFSC system.

Finding:

This requirement was achieved. The inspector reviewed the loading pattern for one cask and verified that the pattern met the TS requirements. All heat loads per assembly were verified to be less than or equal to 50 watts. The licensee's calculation of the heat load for one cask was reviewed and found to be correct as meeting the requirement of being less than or equal to 2,000 watts.

The inspector found that 44 assemblies had enrichments of 2.08% U-235.

Technical Specification 2.1 required that the limit of the enrichment be greater than or equal to 2.09% U-235. The licensee had identified this discrepancy and had submitted a license amendment request, which was issued on August 6, 2008.

During the initial loading, the inspector reviewed the characteristics of the fuel assemblies that were placed into the first canister (MPC Serial Number 128). All the fuel assemblies met the Technical Specification requirements for initial enrichment, burnup and decay heat limits. The decay heat load of all the fuel assemblies loaded in the first MPC was 1,906 watts.

Procedure 8-5, "Movement of Material in the Spent Fuel Pool," Revision 36; Procedure ITP 2008-07, "Cask Loading Plan," Revision 0; Procedure HBAP D-7, "Control and Accountability of Special Nuclear Material and Waste Shipment,"

Revision 20; Procedure HBAP C-20, Attachment 7.1, "Calculation Number NX-290," Revision 8; Sampling of associated fuel records, loading plans, and SNM Movement Authorizations.

Documents Reviewed:

Page 18 of 64

Category:

GTCC Topic: GTCC Waste Reference:

HB Technical Specification 2.1.2 Requirement: Greater-than-Class-C (GTCC) waste meeting the description in Section 3.1 of the Humboldt Bay ISFSI FSAR may be stored in one cask at the ISFSI.

Finding:

The licensee program for GTCC waste had not been developed. PG&E stated that it would be several years before loading of the GTCC material will occur.

Therefore the NRC will delay review of the GTCC waste handling process until such time as the licensee program is in place.

Documents None developed yet.

Reviewed:

Category:

Heavv Loads Topic: Cask Transport Route - 1 Reference:

Requirement: The cask transport route consist of a 26 feet wide compacted gravel roadway HB FSAR, Section 4.3.3, Section 8.2.1 2.2 that is built to USACE Technical Manual EM 11 10-3-141 standards. The incline grade does not exceed 8.5 percent (nominal).

This requirement was achieved. The inspector reviewed the documents listed and determined that the licensee had met the requirements specified in the USACE Technical Manual EM 1 1 10-3-141 and that the incline did not exceed the 8.5 percent (nominal) grade.

Procedure HBPP-2006-001, "Specification for construction of an ISFSI,I1 Revision 2; Drawing 4035924, ISFSI Haul Path Profile and Sections," Revision 1; Humboldt Bay ISFSI FSAR Vol. 1: Chapter 2 Section 2.6.7.7 (Slope Stability Analysis), Section 2.6.7.8 (Slope Displacement Analysis); GEO.HBIP.02.08 Finding:

Documents Reviewed:

Category:

Heavy Loads Topic: Cask Transport Route - 2 Reference:

HB FSAR, Section 4.3.3 Requirement: The underground utilities and concrete pipeways located beneath the cask Finding:

Documents Reviewed:

transport r h t e were designed for H-20 traffic loads.

This requirement was met. PGE-290-CALC-001 was reviewed by the inspector, which indicated that the licensee had performed the analysis of the underground utilities located underneath the transport route. However, the inspector did not find any evidence that the 4" clay pipe (that had been abandoned) prior to the ISFSI construction had been removed. The licensee indicated that the subject 4" clay pipe, which had carried chemicals, had been totally abandoned and that P G & E planned to abandon the clay pipe in place. The licensee documented in SAPN 124957 that the abandoned clay pipe would not impact the transporter operation. The inspector determined that the underground utilities documented in PGE-290-CALC-001 would not impact the transport route.

PGE-290-CALC-001, "Evaluation of Underground Utilities," Rev. 0; SAPN 1246957, Dated June 26,2008 Page 19 of 64

Category:

Heavv Loads Topic: Component Weights for Heavv Lifts Reference:

Requirement: Tables 3.4-2; 3.4-3; and 4.2-1 provides the maximum handling weights for the Finding:

HB FSAR, Tables 3.4-2; 3.4-3; 4.2-1 various dry cask components.

This requirement was achieved. The listed documents were reviewed and it was determined that the expected weights of the various components were bounded by the weights shown in the relevant tables from the Humboldt Bay FSAR. The inspector found that the weights of the dry cask components had been incorporated into the licensee operating procedures.

Holtec Drawing 4508 (Sheet. 1 of 12), "HI-STAR HB Overpack Assembly, Revision 9; Holtec Drawing 4529 (Sheet. 1 of 8), "MPC-HB Fuel Basked,"

Revision 8; Holtec Drawing 4530 (Sheet. 1 of 12), "MPC-HB Enclosure Vessel,"

Revision 14; Procedure ITP 2008-02, "Transporter Operating Procedure,"

Revision Draft; Procedure ITP 2008-05, "Cask Transporter Evaluation Program," Revision 0 Documents Reviewed:

Category:

Heavv Loads Topic: Initial Load Test on Trunnions Reference:

Requirement: The overpack trunnions are maintained and inspected in accordance with ANSI Finding:

HB FSAR, Section 4.4.3.1, 4.2.3.3 N14.6.

This requirement was achieved. The inspector found sufficient information in the sample MTR #O 540-17 for the first HI-STAR to validate that the load test had been performed for the overpack trunnions.

Documents Purchase Specification PS-5043, Purchase Specification for the Fabrication of Reviewed:

HI-STAR HB," Revision 3; Report HI-2033042 "Miscs. Calculations for the HI-STAR HB," Revision 3 ; MTR #O 540-17, "Trunnion Load Test Data," Revision 0 Category:

Heavv Loads Topic: Procedures Reference:

NUREG 0612, Section 5.1.1 (2)

Requirement: Procedures should be developed to cover load handling operations for heavy loads that are or could be handled over or in proximity to irradiated fuel or safe shutdown equipment. The procedures should include: a) identification of the required equipment; b) inspections and acceptance criteria required before movement of the load; c) the steps and proper sequence to be followed in handling the load; d) defining the safe load path; and e) special precautions.

This requirement was achieved. Appropriate controls for heavy load handling operations in proximity to irradiated fuel were included in Attachments 7.1 and 7.2 of Procedure HBAP C-702.

Procedure HBAP C-702, "Handling Large Equipment," Revision 7.

Finding:

Documents Reviewed:

Category:

Heavv Loads Topic: Safe Load Paths Reference:

NUREG 0612, Section 5.1.1 (I)

Page 20 of 64

Requirement:

Finding:

Documents Reviewed:

Safe load paths should be defined for the movement of heavy loads to minimize the potential for heavy loads, if dropped, to impact irradiated fuel in the reactor vessel and in the spent fuel pool, or to impact safe shutdown equipment. The path should follow, to the extent practical, structural floor members, beams, etc.,

such that if the load is dropped, the structure is more likely to withstand the impact.

This requirement was achieved. The licensee had included the safe load paths for the cask movement in Attachment 7.1 of Procedure HBAP C-702.

Procedure HBAP C-702, "Handling Large Equipment," Revision 7.

Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

Heavv Loads Topic: Torquinq Requirements HI-STAR 1008 FSAR, Table 8.1.3 The requirements for the various components of the HI-STAR system that require a specified torque value are listed in Table 8.1.3 of the HI-STAR 1008 FSAR.

This requirement was achieved prior to loading. The torque requirements for the Humboldt Bay HI-STAR were included in Attachments 8.1, 7.2 and 7.3 of Procedure HPP-1125-400. However, upon review by the inspector, several of the torque values were found to differ from the values specified in the HI-STAR FSAR. The torque values were corrected in Procedure HPP-1125-400 to the values specified in the HI-STAR FSAR prior to placing the HI-STAR lid on the loaded MPC.

Procedure HPP-1125-400, "Procedure for HI-STAR Sealing, Processing and Transport to the Storage Vault at Humboldt Bay Nuclear Power Plant," Revision 2A Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

Heavv Loads Topic: Visual Exam of Liftinq Trunnions HB FSAR, Section 4.4.3.1 Prior to each fuel loading, a visual examination is performed on the overpack lifting trunnions. The examination shall inspect for indications of overstress such as cracking, deformation, or wear marks.

This requirement was achieved. Section 5 of Procedure HPP-1125-200 included the requirement to perform a visual examination of the overpack lifting trunnions prior to each fuel loading.

Procedure HPP-1125-200, "Procedure for MPC Loading at Humboldt Bay Unit 3," Revision 2 Category:

NDE Certification Exams Topic: Level I l l Exam Grading Reference:

SNT-TC-1 A, Section 8 Requirement: Level Ill examiners take 3 examinations; BASIC, METHOD AND SPECIFIC. A composite grade should be determined by simple averaging of the results of the 3 examinations. A passing composite grade should be 80% with no one examination below 70%.

Page 21 of 64

Finding:

This requirement was implemented. The certification records for the PCI Energy Services Level I I examiner performing the visual testing (VT) and liquid penetrant (PT) testing methods contained the grades for the BASIC, METHOD AND SPECIFIC examinations. The composite grade for VT Level II was 90.14% with no grade below 85%. The composite grade for PT Level II was 90.8% with no grade below 85%.

The certification record for the Leak Testing Specialists Level Ill examiner performing the helium leak testing (LT) contained the grades for the BASIC, METHOD AND SPECIFIC examinations. The composite grade was 91.8% with no grade below 80%.

PCI Energy Services NDE Personnel Certificates; Leak Testing Specialists, Inc.,

Documents Reviewed:

Certification Record Category:

NDE Certification Exams Topic: Level I l l Exam Waivers Reference:

SNT-TC-1 A, Section 8 Requirement: The BASIC AND METHOD examinations may be waived by a valid endorsement on an ASNT NDT Level I l l certificate. The SPECIFIC examination may be waived by a valid endorsement on an ASNT NDT Level I l l certificate AND documented evidence of Level I l l experience including the preparation of NDT procedures to codes, standards, or specifications and the evaluation of test results.

This requirement was implemented. Procedure GQP-9.0 was the PCI Energy Services written practice for controlling NDE examiner training and qualification.

Procedure GQP-9.0 does not provide for examination waivers under any conditions and PCI does not use them.

Procedure GQP-9.0, "Training, Qualification, Examination and Certification of NDE, Inspection and Testing Personnel," Revision 7 Finding:

Documents Reviewed:

Category:

NDE Personnel Quals Topic: Certification Records Reference:

SNT-TC-1 A, Section 9 Requirement: Certification records should contain the name of the certified individual, the certification level and method, the individual's educational background and NDE experience, a statement of satisfactory completion of training per the employer's written practice, visual examination results, evidence of successful completion of examinations including grades, date of certification, and the signature of the employer.

This requirement was implemented. The PCI Energy Services NDE personnel Certificates for the Level II examiner performing the visual testing (VT) and liquid penetrant testing (PT) contained all the information specified in SNT-TC-1 A, Section 9.

Finding:

The Leak Testing Specialists, Inc., Certification Record for the examiner performing the helium leak testing (LT) contained the information specified in SNT-TC-IA, Section 9.

Page 22 of 64

Documents Reviewed:

Certification Record PCI Energy Services NDE Personnel Certificates; Leak Testing Specialists, Inc.,

Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

NDE Personnel Quals Topic: Recertification SNT-IC-IA, Section 9 Maximum recertification intervals are 3 years for Levels I and II, and 5 years for Level Ill. Recertification may be granted without testing provided there is documented continuing satisfactory performance. "Continuing" must be defined in the written practice. Without documented continuing satisfactory performance, reexamination is required for those sections deemed necessary by the Level I l l examiner.

This requirement was implemented. The PCI Energy Services NDE personnel Certificates for the Level II examiner performing the visual testing (VT) and liquid penetrant testing (PT) indicated a maximum re-certification interval of 3 years.

The examiner had re-certified VT on 08/15/2007 and PT on 08/24/07. PCI did not provide for re-certification without testing.

The Leak Testing Specialists, Inc., Certification Record for the Level Ill examiner performing the helium leak testing (LT) indicated a maximum re-certification interval of 5 years. The examiner had re-certified on 03/07/08. PCI and LTS did not provide for re-certification without testing.

PCI Energy Services NDE Personnel Certificates; Leak Testing Specialists, Inc.,

Certification Record Category:

NDE Personnel Quals Topic: Visual Acuitv Reference:

SNT-TC-1 A, Section 8.2 Requirement: The NDE examiner should have natural or corrected near-distance acuity in at least one eye capable of reading Jaeger Number 1 at a distance of not less than 12 inches on a standard Jaeger test chart, or capable of perceiving a minimum of 8 on an Ortho-Rater test pattern. This should be verified annually. The NDE examiner should demonstrate the capability of distinguishing and differentiating contrast among colors used in the applicable method. This should be verified every 3 years.

This requirement was implemented. The PCI Energy Services Vision Examination Report for the Level II examiner performing the visual testing (VT)

and liquid penetrant testing (PT) indicated the examiner had met the visual acuity requirements for natural or corrected distance acuity and color differentiation. The visual examination was conducted on 07/17/07 and was valid for one year.

Finding:

The Leak Testing Specialists, Inc., (LTS) Visual Acuity Record for the Level Ill examiner performing the helium leak testing (LT) indicated the examiner had met the visual acuity requirements for natural or corrected distance acuity and color differentiation. The visual examination was conducted on 02/04/08 and was valid for one year.

Page 23 of 64

Documents Reviewed:

(LTS) Visual Acuity Record PCI Energy Services Vision Examination Report; Leak Testing Specialists, Inc.

Category:

NDE Personnel Quals Topic: Written Practice Reference:

SNT-TC-IA, Section 5 Requirement: The employer shall establish a written practice for control and administration of NDT personnel training, examination and certification. The written practice should describe the responsibility of each level of certification for determining the acceptability of material or components. The written practice shall describe the training experience and examination requirements for each level of certification.

This requirement was implemented. Procedure GQP-9.0 was the PCI Energy Services written practice for controlling NDE examiner training and qualification.

Section 7.0 of Procedure GQP-9.0 established the responsibility and authority of Level I, I I, and Ill examiners for determining the acceptability of material or components. Section 8.0 of Procedure GQP-9.0 contained the education and experience requirements for each level of certification. Section 9.0 of Procedure GQP-9.0 contained the training requirements for each level of certification.

Section 10.0 described the written and practical examination requirements for each level of certification, as well as the requirements for visual acuity.

Finding:

All sections of the PCI written practice (Procedure GQP-9.0) were consistent with the SNT-TC-1A requirements.

Procedure GQP-9.0, Training, Qualification, Examination and Certification of NDE, Inspection and Testing Personnel, Revision 7 Documents Reviewed:

Category:

NDE Procedures - HT Topic: MPC Helium Leak Rate Limit Reference:

HB Technical Specification SR 3.1.I

.3 Requirement: Verify that the total helium leak rate through the MPC-HB vent and drain port cover plate welds is less than or equal to 1.OE-7 atm-cclsec (He).

Finding:

This requirement was implemented. Humboldt Bay Technical Specification 3.1.I

.3 limited the helium leak rate through the vent and drain port cover plate welds to 1.0 X IO(-7) atm-cclsec (He). For this application, ANSI N14.5 required a minimum helium mass spectrometer leak detector (HMSLD) sensitivity of 5.0 X IO(-8) atm-cclsec (He).

The VTl leak rate standard used by Leak Testing Specialists (LTS) for the demonstration was a calibrated leak rate of 7.46 X 10-8 atm-cclsec. The HMSLD demonstrated the ability to detect a minimum sensitivity of 2.15 X 10-9 atm-cclsec. The actual leak rate during the demonstration was measured and the reading corrected for temperature was recorded as 4.5 X 10-8 atm-cclsec.

The VTI leak rate standard had been calibrated on 12/19/2007 with a 3-year calibration interval.

Vacuum Technologies, Inc. (VTI) Leak Rate Standard Serial # 3253; Leak Testing Specialists (LTS) Serial # CL-HE-18.

Documents Reviewed:

Page 24 of 64

Category:

NDE Procedures - PT Topic: Acceptance Criteria Reference:

Requirement: Only indications with major dimensions greater than 1/16 inch should be ASME Section I l l, Article NB-5352 considered relevant. The following relevant indications are unacceptable: (1)

any cracks or linear indications. Linear indications have a length at least 3 times greater than the width; (2) rounded indications with dimensions greater than 3/16 inch (4.8 mm); (3) more than four rounded indications in a line, separated by 1/16 inch (1.6 mm) or less edge to edge; and (4) more than ten rounded indications in any 6 square inch area in the most unfavorable location relative to the indications being evaluated.

This requirement was achieved. The inspector reviewed Procedure GQP-9.2 and found that Appendix A addressed the acceptance criteria.

PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 2 Finding:

Documents Reviewed:

Category:

NDE Procedures - PT Topic: Contaminants Reference:

Requirement: The user shall obtain certification of contaminant content for all liquid penetrant ASME Section V, Article 6, T-641 materials used on austenitic stainless steels. The certifications shall include the manufacturers batch number and sample results. Sub-article T-641 (b) limits the total halogen (chlorine plus fluorine) content of each agent (penetrant, cleaner and developer) to 1.O weight percent (wt.%) when used on austenitic stainless steels.

This requirement was achieved. The inspector reviewed the Sherwin certifications for the following products and determined that the materials met the specified requirements:

Finding:

DURO-CHEK, KO-19-Cleaner, Batch # 514-H56 DURO-CHEK, KO-17-Penetrant, Batch # 31 3-C54 DURO-CHEK, D35O-Developer, Batch 527-B71 Sherwin Certification Documentation; PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 2 Documents Reviewed:

Category:

NDE Procedures - PT Topic: Final Interpretation Reference:

ASME Section V, Article 6, T-676.1 Requirement: Final interpretation shall be made after allowing the penetrant to bleed-out for 7 to 60 minutes under standard temperatures (50 and 125 degrees F). The 7 to 60 minute clock starts immediately after application of a dry developer. For wet developer, the clock starts when the coating is dry.

The requirement was achieved. During the welding demonstration, the inspectors witnessed the performance of the final weld interpretation which met the above stated requirement.

Finding:

Page 25 of 64

Documents Reviewed:

PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 2 Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

NDE Procedures - PT Topic: Liqht lntensitv ASME Section V, Article 6, T-676.3 For color contrast penetrants, a minimum light intensity of 50 foot-candles (500 lux) is required to ensure adequate sensitivity during examination and evaluation of indications.

This requirement was achieved. The inspector determined that Procedure GQP-9.2 exceeded the above stipulation by requiring a minimum light intensity of 100 foot candles during the examination. The examiner used light meter PCI-1521 042, which was determined to be within the specified calibration frequency at the time of the demonstration (Calibrated on 08/03/07, Calibration due date of 08/02/08).

PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 2 Category:

NDE Procedures - PT Topic: Minimum Elements Reference:

Requirement: Each liquid penetrant (PT) procedure shall include the: (1) materials, shapes or ASME Section V, Article 6, T-621 sizes to be examined; (2) type of each penetrant, remover, emulsifier, and developer; (3) pre-examination cleaning and drying, including the cleaning materials used and minimum time allowed for drying; (4) applying the penetrant, the length of time the penetrant will remain on the surface (dwell time), and the temperature of the surface during examination; (5) removing excess penetrant and drying the surface before applying the developer; (6) length of developing time before interpretation; and (7) post-examination cleaning.

This requirement was achieved. PCI Procedure GQP-9.2, Section 2.0 addressed the material shapes and sizes to be examined and Section 7.1 addressed the type of penetrant, remover, emulsifier, and developer to be used.

The remaining PT requirements were addressed in Section 9 of Procedure GQP-9.2.

PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 2 Finding:

Documents Reviewed:

Category:

Reference:

Requirement:

NDE Procedures - PT Topic: Non Standard Temperature ASME Section V, Article 6, T-653 When performing liquid penetrant examinations outside the range of 50 to 125 degrees F, the examiner may use a standard temperature procedure or a non-standard temperature procedure. In either case, the examination procedure requires qualification at the proposed higher or lower temperature. This shall require the use of a quench cracked aluminum block, also designated as a liquid penetrant comparator block.

Page 26 of 64

Finding:

This requirement was achieved. Procedure GQP-9.2 was used for both Low and Hi temperature liquid penetrant examinations (50 to 300 degrees F). The D-100 developer was rated for 50 to 250 degrees F and the D350 developer was rated for 175 to 300 degrees F.

Procedure GQP-9.2 had been approved by the PCI Level I l l examiner and it was also noted that the Holtec Level I l l examiner had approved the procedure.

PCI Procedure GQP-9.2 "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 2 Documents Reviewed:

Category:

NDE Procedures - PT Topic: Permanent Record Reference:

Requirement: The inspection process, including findings (indications), shall be made a HB FSAR Table 3.4-5; ASME Sect VI Article 6, permanent part of the user's records by video, photographic, or other means which provide an equivalent retrievable record of weld integrity. The video or photographic records should be taken during the final interpretation period.

This requirement was not initially achieved. During the welding demonstration there were no procedural requirements to perform or document the results of the final PT examination as part of the permanent records. The licensee committed to including this information in a future procedural revision.

Finding:

During the wet operations demonstration, the licensee provided PCI Procedure GQP-9.2, which included a report of any indications from the liquid penetrant examination along with a sketch of any indications that were discovered in Exhibit 1. This Exhibit was incorporated into the permanent record of the weld maintained by the licensee in step 9.1.35.a of PCI-PI-900971-01. This met the requirement specified above.

PCI-PI-900971-01, "Closure Welding of Multi-Purpose Canisters at Humboldt Bay," Revision 0; PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 2 Documents Reviewed:

Category:

NDE Procedures - PT Topic: Removing Excess Penetrant Reference:

Requirement: Excess solvent removable penetrants shall be removed by wiping with a cloth or ASME Section V, Article 6, T-673.3 absorbent paper until most traces of the penetrant have been removed. The remaining traces shall be removed by lightly wiping the surface with a cloth or absorbent paper moistened with solvent. Care shall be taken to avoid the use of excess solvent.

This requirement was achieved. The instructions contained in Procedure GQP-9.2, did not agree with the above requirement as the cleaner (KO-17) was sprayed directly on the weld and then wiped with a water saturated cloth. The inspector contacted Sherwin NDE products, who stated that the method used by PCI was considered satisfactory and would not adversely affect the performance of the process. The inspector determined that the process used by PCI with the Finding:

Page 27 of 64

Sherwin materials met the intent of the requirement.

PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 2 Documents Reviewed:

Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

NDE Procedures - PT Topic: Surface Preparation ASME Section V, Article 6, T-642 (b)

Prior to each liquid penetrant examination, the surface to be examined and all adjacent areas within one inch must be dry and clean.

This requirement was achieved. Procedure GQP-9.2, Section 9. I.I required that the surface to be examined and all adjacent areas with one inch be dry and clean prior to performing each liquid penetrant examination.

PCI Procedure GQP-9.2, "High Temperature Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials and Cladding," Revision 2 Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

NDE Procedures - VT Topic: Eve Position and Liqhtinq ASME Section V, Article 9, T-952 Direct visual examinations shall be conducted with the eye within 24" (610 mm)

of the surface, at an angle not less than 30 degrees. The light intensity must be at least 100 foot-candles (2001 edition). The light intensity must be at least 15 foot-candles for general examination and 50 foot-candles for the detection and study of small anomalies (1995 edition).

This requirement was achieved. Procedure GQP 9.6, Section 4.1 specified a minimum light intensity of 100 foot candles and the requirements of Section 6.2 exceeded the minimum code light intensity requirements for general examination/detection of anomalies. The inspector observed the measurement of the light intensity during the visual examination when light meter PCI-1521 042, Digital Radiometer / Photo Meter was used. The instrument was found to be within the required calibration frequency and had last been calibrated on August 2, 2007.

PCI GQP-9.6, "Visual Examination of Welds," Revision 8 Category:

NDE Procedures - VT Topic: Procedure Requalification Reference:

Requirement: Whenever a change is made to the following essential variables in a VT ASME Section V, Article 9, T-921.2 Examination procedure, the procedure must be requalified: (1 ) technique used; (2) remote visual aids; (3) personnel performance requirements; (4) decrease in light intensity.

This requirement was achieved. The welding vendor did not have a procedure that specifically commited the vendor to following the requirements for requalifying the VT procedure per the ASME Code requirement. Subsequently, the welding vendor provided a letter stating that conformance to ASME Boiler and Pressure Vessel Code,Section V, Article 9 would be adhered to for ASME Code work.

Finding:

Page 28 of 64

Documents Reviewed:

Procedure GQP-9.6, "Visual Examination of Welds", Revision 8; Letter to Eric Jones and Steve Soler, Dated July 18, 2008 Category:

NDE Procedures - VT Topic: Procedure Validation Reference:

Requirement: The visual testing (VT) procedure shall contain, or reference, a report of what ASME Section V, Article 9, T-941 method was used to demonstrate that the examination procedure was adequate. In general, a fine line 1/32 inch (0.8 mm) or less in width, an artificial imperfection or a simulated condition, located on the surface or a similar surface to that to be examined, may be considered as a method for procedure demonstration. The condition or artificial imperfection should be in the least discernible location on the area surface to be examined to validate the procedure.

This requirement was implemented. Section 6.3 of Procedure GQP-9.6 specified that resolution of a 1/32-inch or less black line on an 18% neutral gray card located in the least discernible location on the surface to be examined qualified the procedure.

Procedure GQP-9.6, "Visual Examination of Welds", Revision 8 Finding:

Documents Reviewed:

Category:

NDE Procedures - VT Topic: Visual Examination Acceptance Criteria Reference:

Requirement: The governing code for visual examination of welds made on the Holtec -

Holtec - Humboldt Bay Project No. 900971 Humboldt Bay Project No. 900971 was ASME Code Section Ill, Article NF-5360.

ASME Section I l l, Article NF-5360, "Visual Acceptance Standards" provided the acceptance criteria for arc strikes and blemishes, cracks, craters, fusion and overlap, porosity, slag, undercut, and weld length and thickness.

This requirement was implemented. Section 10.0 of Procedure GQP-9.6 required welds to be examined to the acceptance criteria identified within the governing code, specification, and/or contract documents. The visual examination requirements that contained the ASME Code Section Ill, Article NF-5360 requirements were included in a procedure supplement to Procedure GQP-9.6 tit led, "Vis u a I Accept an ce St and a rds.I1 GQP-9.6 Supplement Holtec - Humboldt Bay Project No. 900971 Finding:

Documents Procedure GQP-9.6, "Visual Examination of Welds," Revision 8; Procedure Reviewed:

Category:

Pre-Operational Tests Topic: MPC Unloadinq Reference:

HB FSAR, Section 5.1.I

.4; 10.2.3 Requirement: In the event that an MPC must be unloaded during the loading campaign, an evaluation of the bulk temperature of the gas in the MPC cavity is made and cooled using appropriate means. Appropriate means could include recirculation water in the overpack annulus and/or helium recirculation with the FHD system to cool the MPC temperature at or below the maximum allowed temperature for re-flooding in accordance with Humboldt Bay ISFSl TS and Section 10.2.

This requirement was achieved. Section 7.5 of Procedure HPP-1125-500 Finding:

Page 29 of 64

provided directions to cool the MPC down to an appropriate temperature prior to beginning the unloading process. The licensee planned to cool the MPC down using water circulated in the HI-STAR annulus region. Limitations had been placed in the procedure to limit incoming water temperature to less than 100 degrees F and to ensure that the flow rate was at least 10 gallons per minute.

Based on the heat load in the casks, Holtec had determined that the annulus cooling process was required to be maintained for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

HPP-1125-500, "Procedure for MPC Unloading At Humboldt Bay Power Plant,"

Documents Reviewed:

Revision 3 Category:

Pre-Operational Tests Topic: Startup Testinq Reference:

HB FSAR, Section 9.2.4 Requirement: Startup testing will verify the performance of the storage system; ensure that plant equipment complies with the requirements of the FSAR, and validate the ISFSI operation procedures. The following operations will be included in the startup testing for the Humboldt Bay ISFSI: (1) Preparing the HI-STAR HB for movement into the SFP, (2) Placing the HI-STAR HB into the SFP and simulating movement using a dummy fuel assembly, (3) Removing the HI-STAR HB from the SFP and installing the MPC lid, (4) Decontaminating the HI-STAR HB, (5) Removing the MPC lid retention device, welding the MPC lid, moisture removal, and filling the MPC with Helium, (6) Installing the HI-STAR HB cask top lid, (7) Loading the HI-STAR HB on the rail dolly using the DAVIT crane, (8)

Transporting the HI-STAR HB cask from the RFB to the storage vault using the transporter, (9) Positioning and lowering the HI-STAR HB into the storage vault, (IO) Unloading activities; MPC cooldown and MPC lid weld removal The requirements were achieved. The licensee had prepared for and performed demonstrations that included: (1) Preparing the HI-STAR HB for movement into the SFP, (2) Placing the HI-STAR HB into the SFP and simulating movement using a dummy fuel assembly, (3) Removing the HI-STAR HB from the SFP and installing the MPC lid, (4) Decontaminating the HI-STAR HB, (5) Removing the MPC lid retention device, welding the MPC lid, moisture removal, and filling the MPC with Helium, (6) Installing the HI-STAR HB cask top lid, (7) Loading the HI-STAR HB on the rail dolly using the DAVIT crane, (8) Transporting the HI-STAR HB cask from the RFB to the storage vault using the transporter, (9) Positioning and lowering the HI-STAR HB into the storage vault, ( I O ) Unloading activities; MPC cooldown and MPC lid weld removal.

Finding:

By the time that cask loading activities were started, all the start-up activities and demonstrations associated with the activities described above had been completed by the licensee. Additionally, the MPC canister weld removal demonstration was successfully performed by PG&E for both Humboldt Bay and Diablo Canyon.

Holtec Procedure HPP-1125-200, "Procedure for MPC Loading at Humboldt Bay Unit 3," Revision 2; Holtec Procedure HI-STAR1 00 HPP-1125-400, "Procedure for HI-STAR Sealing, Processing and Transport to the Storage Vault at Humboldt Bay Nuclear Power Plant," Revision 1; Holtec Procedure HPP-1125-Documents Reviewed:

Page 30 of 64

300, "MPC Backfill and Sealing Operation," Revision 6 Category:

ProceduresRech Specs Topic: Cask Transporter Reference:

Requirement: The cask transporter is used to move the SFSC from the power plant to the HB Technical Specification SR 4.3 ISFSI. The transporter is designed, fabricated, inspected, maintained, operated and tested in accordance with applicable guidelines of NUREG 0612, "Control of Heavy Loads at Nuclear Power Plants".

This requirement was achieved. The Vertical Cask Transporter (VCT) had been inspected and documented in previous NRC Inspection Reports at the factory (ML070400122) and during the initial on-site functional testing at Diablo Canyon (ML080360630). The current inspection reviewed the open items from the previous inspections and the cause of the weld cracks discovered while at Humboldt Bay.

Finding:

The open issues from the earlier inspections consisted of the frequent and periodic inspections of the VCT. Procedure ITP 2008-05 was revised to include appropriate daily, weekly, monthly, biannual and annual inspections and maintenance requirements. The daily inspections included inspection for loose, missing or broken parts, track bolts, condition of track, missing components, and hydraulic leaks, A prestart-up inspection list was included with the procedure.

Recently discovered issues associated with the wedge-lock anchors were included in the procedure.

Periodic inspections were revised to include inspections of the track bolts, the VCT structure, the center section bolts, the lift links and wedge lock anchors.

The inspections included in Procedure ITP 2008-05 for frequent and periodic inspections appropriately considered the items that were necessary for VCT inspections at Humboldt Bay.

After the VCT demonstration at Humboldt Bay, cracks were discovered in welds associated with the VCT carriage, considered to be Not-Important-To-Safety (NITS). Repairs were made to the welds by the vendor and a root cause was preformed. The root cause determined that even though the welding preheat met the AWS Code requirements, it was insufficient for portions of the thinner NITS material being welded. The root cause acknowledged that the Important-To-Safety (ITS) welds were preheated to a higher temperature and had not experienced any cracking. The root cause concluded that the ITS portions of the VCT were unaffected. Additional NDE had been performed on the ITS welds after completion that confirmed the welds were unaffected.

Procedure ITP 2008-05, "Cask Transportation Evaluation Program," Revision 1 ;

SAPN 1247041, Dated July 18, 2008; Procedure ITP 2008-05, "Transporter Operating Procedure," Revision 2.

Documents Reviewed:

Category:

Procedures/Tech Specs Topic: Compliance with 1 OCFR50.68 Reference:

Reg. Issue Summary 2005-05 Page 31 of 64

Requirement: Subcriticality in the spent fuel pool must be maintained without credit for soluble boron in compliance with 10 CFR 50.68. However, Part 72 allows credit for boron in the spent fuel pool during loading, unloading and handling operations.

Review the licensee's criticality analysis or other documentation demonstrating compliance with 10 CFR 50.68 during canister loading.

This requirement was achieved. The SAFSTOR criticality analysis bounded the process of loading the MPC's as long as no more than three fuel assemblies at any one time were outside containers containing neutron absorbing materials (Humboldt Bay Technical Specification 4.2.1). The MPC cells contained neutron absorbing material.

SAPN 1246530, Dated June 4,2008 Finding:

Documents Reviewed:

Category:

Procedures/Tech Specs Topic: Stuck Fuel Assemblv Durinq Loading MPC Reference:

None Requirement: During the loading of the fuel assemblies into the MPC, it is possible that a fuel assembly could become stuck. Removing the fuel assembly requires establishing a lifting limit to prevent damaging the fuel assembly.

This requirement was met by the licensee. Procedure B-5 included instructions in Section 6.6 to provide direction to operations personnel in the event that a fuel assembly would not seat in a MPC cell.

Procedure B-5, "Movement of Material in the Spent Fuel Pool," Revision 36 Finding:

Documents Reviewed:

Category:

ProceduredTech Specs Topic: Unloadinq - MPC Temperature Reference:

Requirement: Prior to initiating the MPC-HB re-flooding during the unloading operations, HB Technical Specification SR 3.1.3.1 ensure via analysis or direct measurement that the MPC-HB cavity bulk helium temperature is less than or equal to 200 degrees F.

This requirement was achieved. Step 7.5.6 of Procedure HPP-1125-500 stipulated that the minimum cooling time for the MPC during unloading was to be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the initial introduction of the cooling water into the HI-STAR annulus. Holtec has affirmed that a cooling time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using a flow rate of 10 gpm into the HI-STAR annulus was sufficient to cool down a Humboldt Bay HI-STAR after being stored in the ISFSI vault at the cask equilibrium temperature.

Procedure HPP-1125-500, "Procedure for MPC Unloading at Humboldt Bay Power Plant," Revision 3; Holtec Letter to Mr. Larry Pully dated May 23, 2008 Finding:

Documents Reviewed:

Category:

Procedures/Tech Specs Topic: Vault Inspections Reference:

HB FSAR, Section 4.4.3.8 Requirement: The inspection for water in the vault drain system will be performed initially on a monthly basis. The subsequent inspection interval will be selected based on the Page 32 of 64

results obtained during the initial 12-month period. The inspection method will be visual inspection of the drain collection point combined for the initial period with remote camera inspection through the vault viewports.

This requirement was achieved. The licensee included instructions in Section 6.2 of Procedure ITP 2008-06 to perform monthly inspections of the drainage system as well as after a flood, tsunami or earthquake. Work Order 20012321 was originated to track and record the observations.

Procedure ITP 2008-06, "ISFSI Surveillances," Revision 1, Work Order 2001 2321, "ISFSI ITP Surveillance," Dated August 1, 2008 Finding:

Documents Reviewed:

Category: -

QA Topic: Control of Measurinq and Test Equipment Reference:

10 CFR 72.164 Requirement: The licensee shall establish measures to ensure that tools, gauges, instruments and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specific periods to maintain accuracy within necessary limits.

This requirement was achieved. The licensee had an established program for the use and control of M&TE equipment for quality related activities. Section 1.I

.3 of Procedure HBAP D-5#1 allowed the vendor to use and control their M&TE in accordance with the vendor's PG&E approved quality assurance program.

Finding:

The vendor was using Procedure HQP-12.0 for control of the M&TE equipment.

This procedure provided directions for the use of M&TE equipment, including selection of the proper type, range and accuracy to accomplish the activity.

Section 6.1.4 stated that when possible, the calibrating inspection tools will have a range of accuracy of four times that of the tool being calibrated. Instructions were also provided to issue nonconformance reports when the M&TE was found unacceptable during calibration or a periodic check.

Holtec Quality Procedure, HQP-12.0, "Equipment Calibration and Control of Measuring and Test Equipment," Revision 11 ; Procedure HBAP D-5#1, "Use and Control of Measuring and Test Equipment (M&TE)," Revision 5A; Procedure HBAP D-5#2, "Calibration of Measuring and Test Equipment (M&TE)," Revision 2A Documents Reviewed:

Category: -

QA Topic: Corrective Actions Reference:

10 CFR 72.172 Requirement: The licensee shall establish measures to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures must ensure that the cause of the condition is determined and corrective action taken to preclude repetition. This must be documented and reported to appropriate levels of management.

This requirement was achieved. The team verified that the SAPN system is Finding:

Page 33 of 64

used for the documentation, tracking, and resolution of ISFSI-related problems and issues. Specifically, Section 1.3 of Procedure HBAP C-12 stated in part that this procedure describes the methods used for controlling and classifying Unit 3 quality-related items that utilize the SAPN system for tracking and documentation purposes, including the Humboldt Bay ISFSI and associated support activities. A sampling of ISFSI-related SAPNs were reviewed by the team and resolution of the underlying issues was assessed to be adequate.

Procedure HBAP C-I 2, "Problem Identification and Resolution," Revision 27 Documents Reviewed:

Category: -

QA Topic: Procurement Controls for Material Reference:

10 CFR 72.1 54(a)/(b)/(c)

Requirement: The licensee shall establish measures to ensure that purchased material, equipment, and services conform to procurement documents. These measures must include provisions for source evaluation and selection, objective evidence of quality furnished by the contractorlsubcontractor, inspection at the contractor/subcontractor source and examination of product on delivery.

Records shall be available for the life of the ISFSI. The effectiveness of the control of quality by contractordsubcontractors shall be assessed at intervals consistent with the importance, complexity and quantity of the product or service.

This requirement was met. The inspector reviewed the appropriate sections of the licensee's QA program and selected ISFSI rebar procurement control documentation for additional review, which included the Certificate of Compliance. The licensee did not include 10 CFR Part 21 notification as part of the original purchase requirements since the rebar was supplied according to HBPP-2006-001, which stipulated that the rebar would be dedicated by the licensee. The inspector verified that the rebar, as supplied, met the specification requirements and also met the requirements of Holtec drawing 4105 Sheet 2, Revision 3 Note 6. The rebar had been tested by the PG&E Technical and Land Services. The rebar test reports and associated documents were determined to be acceptable. Procedure HBAP-E1 stipulated that the ISFSI records were considered Lifetime records.

DCPP Units 1 & 2 FSAR Update, Chapter 17, Section 17.4, "Procurement Document Control"; Procurement Process Audit, Audit # 071 52001 8; Procedure HBAP E-I, "Retention and Storage of HBPP Unit 3 and ISFSI Records," Section 4, Revision 13B; Procedure HBPP-2006-01, "Specification for Construction of an ISFSI, Section 3.22, Concrete Reinforcement, Revision 2; Multiple Certificates of Compliance from Harris-Salinas Rebar Inc.; Multiple CMTRs from Cascade Steel Rolling Mills, Inc.

Multiple Quality Source Surveillance Checklists (for rebar dedication); Nupic Audit of Holtec Mfg., Audit # 19523 Finding:

Documents Reviewed:

Category: -

QA Topic: QA Audits Reference:

10 CFR 72.176 Requirement: The licensee shall carry out a comprehensive system of planned and periodic audits to verify compliance with all aspects of the QA program and to determine Page 34 of 64

the effectiveness of the program.

This requirement was met. Implementation of the QA program was evident in the existing program, process activities and documents related to the Humboldt Bay ISFSI program. The audits and assessments provided evidence of considerable oversight of ISFSI activities. Approximately 35 assessment observations had been performed as part of the 2008 HBPP ISFSI Assessment Plan from January 9, 2008 to April 8, 2008.

Finding:

The inspector reviewed audit report 071 52001 8 and determined that multiple areas were covered by the audit. The HBPP ISFSI & Engineering services activities for the Unit 3 procurement activities were specifically addressed in this audit report. This area was found to be acceptable.

A review of the NUPIC Audit Report indicated that three findings had been issued to Holtec Manufacturing Division, however no corrective action were available for review by the inspector.

The 2008 schedule included audits during the dry run inspections and the loading operations. The inspector noted that the audit schedule was adequate and included appropriate criteria according to the updated FSAR.

Procurement Process Audit - Report # 071520018 (6/6-12/14/07); NUPIC Audit 06-003/NUPIC # 19523 (5/15-26/06) of Holtec Mfg.; Humboldt Bay Power Plant ISFSI Oversight Plan, Revision 0; Various HBPP QA Assessment Observations; Procedure QASP-9, "Audit Process," Revision 12; Group Master Internal & External Audit & Review Schedule (3/5/08)

Documents Reviewed:

Category: -

QA Topic: QA Proqram Reference:

License SNM-2514, Condition 13 Requirement: The Commission's finding that the Quality Assurance Program complies with the requirements of 10 CFR 72, Subpart G is based on the existence of the approved Diablo Canyon Power Plant Quality Assurance Program which meets the requirements of 10 CFR 50, Appendix B.

This requirement was achieved. Humboldt Bay License Condition 14 stated that the Quality Assurance Plan (QAP) for Diablo Canyon Power Plant (DCPP) will be applied to the Humboldt Bay ISFSI. The DCPP QAP is contained in Chapter 17 of the DCPP FSAR Update. The team reviewed the DCPP QAP and verified that the Humboldt Bay ISFSI had been incorporated in appropriate sections of the FSAR.

Finding:

The inspector found that the DCPP FSAR QA requirements were general in nature and included specific implementation for each of the 18 Part 50 (and similar Part 72) QAP criteria. The inspector noted that the 18 QAP criteria had been incorporated into various Humboldt Bay implementing procedures.

Attachment 7.2 of Procedure IAP A-8 provided a comparison between the DCPP FSAR Sections (QA criteria) and the associated implementing procedures at Humboldt Bay. Several of the implementing procedures were reviewed and verified to properly implement the higher tier requirements.

Page 35 of 64

Documents Reviewed:

Humboldt Bay ISFSI Material License SNM-2514; DCPP Units 1 &2 FSAR Update, Chapter 17, "Quality Assurance"; Procedure IAP A-8, "HBIP Organization and Administrative Controls," Revision OA Category:

Radioloqical Topic: ALARA Proqram Reference:

Requirement: Humboldt Bay Power Plant's ALARA program complies with the requirements of HB FSAR, Section 7.1.I 10 CFR 20 and 10 CFR 50. The ALARA program is implemented through administrative and working level procedures. These documents will be revised as needed to address ISFSI operations prior to loading the first spent fuel cask into the ISFSI.

This requirements was achieved. The licensee utilized Procedure RCP-1 B to provide direction for performing ALARA reviews. It was discovered during the NRC team inspection that the licensee had not updated the ALARA procedure to include 10 CFR Part 72 applications. SAPN 1246535 was written by the licensee and subsequently Procedure RCP-1 B was revised to include the ISFSI operations.

SAPN 1246535, Dated June 9, 2008; Procedure RCP-1 B, "Performing TEDE ALARA Reviews for Controlling Occupational Radiation Exposure," Revision 10 Finding:

Documents Reviewed:

Category:

Radioloqical Topic: Criticalitv Monitorinq Reference:

10 CFR 72.124(c)

Requirement: A criticality monitoring system shall be maintained in each area where special nuclear material is handled, used, or stored which will energize clearly audible alarm signals if accidental criticality occurs. Underwater monitoring is not required when special nuclear material is handled or stored beneath water shielding. Monitoring of dry storage areas where special nuclear material is packaged in its stored configuration is not required.

The NRC has defined "packaged" to begin when the canister lid is seal welded.

This requirement was implemented by the licensee. The inspector identified that the licensee had not addressed the requirement of 10 CFR 72.124(c) during the team inspection. The licensee initiated SAPN 1246531 to evaluate the finding.

The licensee evaluated the area monitors that were located in the fuel building and revised the requirements in the Work Order that governed the loading process. The new Work Order requirements stated that the two area monitors in the refueling building shall alarm at 15 mremlhr and at least one of these channels shall be available to monitor the fuel storage. If the stated Work Order conditions could not be achieved, the Work Order stipulated to use portable instruments.

Finding:

Humboldt Bay had specifically specified the method to be used during the cask loading activities in the ISFSI FSAR. Specifically, Humboldt Bay stated their intent to use the two area radiation monitors, which were stated to generally conform to RG 8.12, "Criticality Accident Alarm Systems," and ANSVANS 8.3-Page 36 of 64

1979, "Criticality Accident Alarm System."

SAPN 1246531, Dated June 6, 2008; Humboldt Bay ISFSI FSAR, Revision 1 Documents Reviewed:

Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

Radioloqical Topic: GTCC Cask Dose Rate HB FSAR, Section 7.2.1.1 The calculated dose rate from the GTCC material does not exceed the calculated dose rate from the spent fuel casks. The GTCC cask surface dose rate will be measured prior to placing the GTCC cask in the ISFSI.

This requirement was not achieved. The licensee had not revised the program requirements to address the loading of GTCC components into the ISFSI. The licensee does not plan to load any GTCC components into the MPC's in the near future. The requirements for GTCC will be reviewed by the agency at a later date after the licensee has revised their programs to deal with handling the GTCC cask.

Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

Radioloqical Topic: HI-STAR Cask Surface Contamination HB FSAR, Section 7.2.2.1 Removable contamination on the exterior surface of the HI-STAR HB cask and accessible portions of the MPC shall not exceed 1000 dpm/l00 sq cm from beta and gamma and 20 dpm/lOO sq cm from alpha sources.

This requirement was achieved. The limits for removable contamination on the exterior surface of the HI-STAR HB cask were stipulated not to exceed 1000 dpm/l00 sq cm from beta / gamma and 20 dpm/100 sq cm from alpha sources in Step 3.1 1.3 of SAPN 1246432. The results of the contamination surveys had to be approved by the RP supervisor before removing the cask from the fuel building. The initial and final contamination surveys of the first HI-STAR HB cask to be loaded at Humboldt Bay were documented to below the specified radiological limits.

SAPN 1246432, Task 02, "Fuel Loading - HI-STAR Position # I," Revision 0; HI-STAR Survey Report 08-0517, Dated July 31, 2008; HI-STAR W/Lid Survey Report 08-0561 Category:

Reference:

Requirement:

Finding:

Radiological Topic: HI-STAR HB Cask Dose Rates HB FSAR, Table 7.3-1 3.4-2 The surface dose rates of the HI-STAR transfer cask, based on bounding fuel cooling time and burnup are shown in Table 7.3-1. The dose point locations are shown on Figure 7.3-1. The dose rate on contact will be less than or equal to 15 mrem/hr (gamma + neutron) on cask surface at midplane.

This requirement was achieved. SAPN 1246432 specified the final radiation survey acceptance criteria for the HI-STAR overpack. Section 3.1 1.6 specified that the acceptance criteria for gamma and neutron dose rates on the side of the overpack must not exceed 8.3 mremlhour at the HI-STAR cask surface at Page 37 of 64

midplane. An additional requirement was that at I meter the dose at midplane would be less than 3.8 mrem. The dose rate of the first HI-STAR HB taken at midplane after the water was removed was reported as less than 0.22 mrem (gamma and neutron).

SAPN 1246432, Task 02, "Fuel Loading - HI-STAR Position #I

,I1 Revision 0; HI-STAR W/MPC Lid Survey Number 08-0552 Documents Reviewed:

Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

Radiological Topic: ISFSI Dose Rates HB FSAR, Section 4.2.3.3.6, 7.2.1.I The average external contact dose rate (gamma and neutron) at the ISFSI vault lid should be less than or equal to 0.2 mrem/hour. The dose rate to the public will be below the 10 CFR 72.104 Regulatory Limit of 25 mrem/year. This limit applies to the cells loaded with fuel and the GTCC canister.

This requirement was achieved. Requirements to perform radiological surveys of the ISFSI vault lid after the insertion of the loaded HI-STAR overpack had been included in Step 3.1 1.7 of SAPN 1246432. The radiological acceptance criteria was specified to be less than or equal to 0.15 mrem/hour, for the total neutron and gamma radiation readings on the ISFSI vault lids. The highest radiological reading for the combined Gamma and Neutron dose rates associated with the initial ISFSI vault lid was reported as 0.12 mremlhour SAPN 1246432, Task 02, "Fuel Loading - HI-STAR Position #I

, I 1 Revision 0; ISFSI Pad Survey 2008-0563 Category:

Reference:

Requirement:

Finding:

Radioloqical Topic: Public Trails HB FSAR, Section 2.1.2 A public trail traverses the ISFSI 100-meter area. The public access to the trail will be blocked by PG&E during loaded cask movements or handling evolutions.

In the event of an accident, PG&E will asses the radiological conditions and take appropriate measures including closing and locking the access gates, if necessary.

This requirement was achieved. The Humboldt Bay FSAR had postulated ISFSI accidents which could occur during the transport operations. Accordingly, Procedure ITP 2008-05 specified the requirements that must be in place prior to transporting a loaded HI-STAR to the ISFSI, which included having the public trail controlled by security during the transport operations. The emergency plan also discussed the need to control the public trail adjacent to the ISFSI.

The inspector observed the licensee demonstration of moving the HI-STAR to the ISFSI using the transporter. During the demonstration, a fishing boat was spotted by security in the area designated to be clear of water vessels prior to movement of the HI-STAR. The Coast Guard was notified and intercepted the boat which was advised to leave the area. After the fishing boat had exited the area, the movement of the Hi-STAR using the transporter occurred without further incident Page 38 of 64

Documents Reviewed:

SAPN 1246486, Dated June 4,2008; Procedure ITP 2008-05, "Cask Transportation Evaluation Program," Revision 0 Category:

Radioloaical Topic: Radioactive Effluent Control Proqram Reference:

HB Technical Specification 5.1.2 Requirement: A program to implement the requirements of 10 CFR 72.44(d) or 72.1 26 will be established and maintained to provide limits on the surface contamination of the Overpack and GTCC cask prior to removal from the refueling building.

This requirement was met. The licensee incorporated the requirements of Technical Specification 5.1.2 into Procedure HBRCD-IO. Section 4.6.2 specified that the surface contamination level requirements of the accessible surfaces of the MPC and HI-STAR Overpack when removed from the fuel building must not have removable contamination that is above 1000 dpm/100 sq cm from beta and gamma or 20 dpmll00 sq cm from alpha sources.

Procedure HBRCD-IO, "Requirements for Routine Radiological Reports,"

Finding:

Documents Reviewed:

Revision 8 Category:

Radioloqical Topic: Radioactive Materials Reference:

10 CFR 72.1 04(a)

Requirement: During normal operations and anticipated occurrences, the annual dose equivalent to any real individual who is located beyond the controlled area must not exceed 25 mrem to the whole body, 75 mrem to the thyroid and 25 mrem to any other critical organ.

This requirement was achieved. Holtec Report HI-2033047 determined that the maximum dose to an individual located at the site boundary in a single year would be 19.45 mrem. This calculated dose is below the dose requirement specified by 10 CFR 72.1 04(a). The licensee will place TLDs at predetermined locations to measure the actual radiological dose received at the site boundary.

Holtec Report HI-2033047, "ISFSI Dose Assessment for Humboldt Bay,"

Finding:

Documents Reviewed:

Revision 4 Category:

Radiological Topic: Unloading - Cask Gas Sample Reference:

HI-STAR 1008 FSAR, Section 8.3.2 Requirement: Gas sampling is performed to assess the condition of the MPC confinement boundary. The HI-STAR vent port plug should be slowly opened and a gas sample collected for evaluation. If radioactive gas is present, the cask should be vented in accordance with instructions from Radiation Protection.

The intent of this requirement was achieved. The radiation protection department determined that the spent fuel to be loaded from Humboldt Bay could release radioactive contamination to the cooling gas (helium) that was present inside the sealed MPC. Based on the potential contamination that could be present in the helium, the licensee elected to treat the gas as radioactive during an unloading event. The gas would be vented through two sets of HEPA Finding:

Page 39 of 64

filters and then released through a monitored release path.

Documents RWP 2008-0127, Revision 00 Reviewed:

Category:

Records Topic: License Conditions Reference:

License SNM-2514, Condition 16 Requirement: The licensee is exempted from the provisions of 10 CFR 72.72(d), with respect to maintaining a duplicate set of records. The licensee may maintain records of spent fuel and high level radioactive waste in storage in duplicate, as required by 10 CFR 72.72(d) or alternatively, a single set of records may be maintained at a record storage facility that satisfies the standards of ANSI N45.2.9-1974.

The licensee utilized a single set of records maintained at a record storage facility, which satisfied the requirements of ANSI N45.2.9-1974. Record storage and retention requirements were incorporated into Procedure HBAP E-I.

ANSI N45.2.9 - 1974, "Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants"; The Humboldt Bay Record Management System (RMS)

Procedure HBAP E-I, "Retention and Storage of HBPP Unit 3 and ISFSI Records," Revision 13B Finding:

Documents Reviewed:

Category:

Records Topic: Material Balance, Inventorv, and Records Reference:

10 CFR 72.72(a)

Requirement: Each licensee shall keep records showing the receipt, inventory (including location), disposal, acquisition, and transfer of all SNM with quantities specified in 10 CFR 74.13(a)(I).

This requirement was achieved. A sample of the SNM records were reviewed as part of the inspection. The licensee was able to demonstrate how a record tracked a liner containing SNM until it was placed in an SNM waste container.

Then the waste container was tracked until it was shipped offsite.

Finding:

A separate record tracked all movements of a storage container that contained fission chambers until it was shipped offsite.

The inventory sheets maintained by the licensee were verified to meet the minimum requirements of 10 CFR 72.72 (a).

Procedure HBAP E-I, "Retention and Storage of HBPP Unit 3 and ISFSl Records," Revision 13B; Procedure ITP-2008-07, "Cask Loading Plan,"

Revision 0; Procedure HBAP D-7, "Control and Accountability of Special Nuclear Material and Waste Shipment," Revision 20 Documents Reviewed:

Category:

Records Topic: Neutron Absorbers Reference:

License SNM-2514, Condition 17 Requirement: Prior to loading spent nuclear fuel into any dry storage cask the following tests must have been successfully completed:

Page 40 of 64

1) Each plate of neutron absorbers shall be visually inspected for damage (e.g.

scratches, cracks, burrs, peeled cladding, foreign materials embedded in the surface, voids, delamination and surface finish) as applicable.

2) The required Boron-I 0 content (areal density) of the neutron absorber panels for the MPC-HB shall be verified to be greater than or equal to 0.01 gm/cm2.

For BORAL that is used, after manufacturing a statistical sample of each Lot of BORAL shall be tested using wet chemistry and/or neutron attenuation testing to verify the minimum Boron-I 0 content (areal density) in samples taken from the ends of the panel.

For METAMIC that is used:

A) Verify that the boron carbide content in the METAMIC is not more than 33.0 weight percent B) Verify that all lost of boron carbide powder meets particle size distribution requirements.

C) Qualification testing shall be performed on the first production run of METAMIC panels to be used in a Holtec MPC to validate the acceptability and consistency of the manufacturing process as defined on page 3 of License SNM-2514.

D) For production runs of the panels to be used in the MPC-HB canisters the following tests shall be performed:

a) Testing of the mixed batches shall be performed on a statistical basis to verify that the correct B4C weight percent is being mixed.

b) Samples from random METAMIC panels taken from areas contiguous to the manufactured panels shall be tested via wet chemistry andlor neutron attenuation testing to verify the Boron-IO areal density. This testing shall be performed to verify the continued acceptability of the manufacturing process.

This requirement was achieved. Item 17 of Humboldt Bay License SNM-2514 specified 10 individual requirements that applied to the Metamic neutron absorbers that were used in the Humboldt Bay MPCs. Each of the requirements were addressed and found to be acceptable in Holtec Document HI-2084034.

Condition number eight below, however specified that the samples be taken from five different batches before the panels were cut the final size. The sampling requirements were not clearly documented in HI-2084034. To clarify the sampling methods used by Holtec, SAPN number 12471 16 was generated by the licensee. Holtec agreed that the sampling techniques met the license condition and the discussion in the SAPN correctly documented the sampling techniques that were used by Holtec.

Finding:

The first requirement was for each plate of the neutron absorbers to be visually examined for signs of damage. Holtec Document HI-2084034 stated that each shipment of Metamic panels that were used in the Humboldt Bay MPCs was certified in Line Item 2 of Holtec Purchase Order 10231H by the inspection requirements of Holtec Purchase Specification PS-9. A review of the requirement of PS-9 indicated that visual examinations were required of the Metamic to verify that no cracks, deep scratches, burrs, embedded debris, etc.

were visible on the surface of the panels.

The second requirement was that the required Boron-I 0 content (areal density)

of the neutron absorber shall be verified to be greater than or equal to 0.01 Page 41 of 64

gm/cm2. Section 7.2 of Hl-2084034 stated that the minimum Boron-I 0 areal density was calculated to be 0.01 1 gm/cm2 for the Metamic used in the Humboldt Bay MPCs.

The third requirement was to verify that the boron carbide content in the Metamic was not more than 33.0 weight percent. Section 7.3 of Hl-2084034 stated that all batches of powder mix used in the Metamic panels were tested for boron carbide. The Metamic panels for the Humboldt Bay MPCs were reported to have been from production run batches with the percentage of boron carbide of 25 or 32 weight percent.

The fourth requirement was to provide verification that all lots of boron carbide powder met the size distribution requirements. Section 7.4 of Hl-2084034 stated that all lots of the boron carbide powder were tested for particle size distribution requirements against a standard distribution. The report concluded that the test results of the boron carbide particle size distribution statistically compared with the standard size powder particle size distribution for boron carbide powder according to ANSI B74.10, "Specifications for the Grading of Abrasive Micro Grits," and therefore was acceptable.

The fifth requirement was that the boron carbide powder weight percent shall be verified by testing a sample from 40 different mixed batches. Section 7.5.1 of HI-2084034 documented that wet chemistry tests had been performed on more than 500 mixed powder batch samples. The results of the tests indicated that the boron carbide weight percent was a nominal 32 percent (+/- 0.23), which is below the specified maximum weight percent of 33 percent.

The sixth requirement was that the Boron-I 0 areal density shall be verified by testing a sample from one panel from each of 40 different mixed batches.

Section 7.5.2 of Hl-2084034 documented the results of testing 40 panels from 40 different batches containing nominal 25 percent and 32 percent boron carbide using the wet chemistry method. In addition the Boron-I 0 areal density was measured by performing neutron attenuation tests on panel samples. The report provided data that the Boron-I 0 areal density was above the minimum required values in the Metamic panels using both wet chemistry and neutron attenuation testing methods.

The seventh requirement was to verify the local uniformity of the boron particle dispersal, neutron attenuation measurements of random test coupons. Section 7.5.3 of Hl-2084034 documented the test results from 40 independent Metamic panels to determine the variation in Boron-I 0 areal density. The measured areal density agreed well with the calculated density, thereby concluding that the areal density of the panels is consistent with what was expected.

The eighth requirement was to verify the macroscopic uniformity of the boron particle distribution using wet chemistry or neutron attenuation. Report HI-2084034 provided test results in Appendix C, Tables 14 and 15. Section 7.5.4 of Hl-2084034 concluded that the variation between the five coupons associated with each of the 5 panels show a very high level of uniformity of boron carbide.

Page 42 of 64

The ninth requirement was to perform testing of mixed batches on a statistical basis to verity the correct boron carbide weight percent is being mixed. The vendor stated in Section 7.6.1 of HI-2084034 that each batch of powder mix was verified by wet chemistry tests to meet the acceptance levels of boron carbide weight percent.

The tenth and final requirement was that samples from random Metamic panels taken from areas contiguous to the manufactured panels be tested via wet chemistry andlor neutron attenuation testing to verify the Boron-I 0 areal density. Section 7.6.2 of HI-2084034 stated that during production random samples are tested for Boron-I 0 areal density using a neutron attenuation method. The report concluded that the areal density of the panels used in the Humboldt Bay MPCs were above the minimum specified.

Holtec Document HI-2084034, "Metamic Licensing Documentation," Revision 0; SAPN 12471 16, "Evaluation of Metamic to L-8 Requirement," Dated July 16, 2008 Documents Reviewed:

Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

Records Topic: Phvsical Inventow 10 CFR 72.72(b)

Each licensee shall conduct a physical inventory of all spent fuel, high-level radioactive waste, and reactor-related GTCC waste containing special nuclear material meeting the requirements in paragraph (a) of this section at intervals not to exceed 12 months unless otherwise directed by the Commission. The licensee shall retain a copy of the current inventory as a record until the Commission terminates the licensee.

This requirement was achieved. The inspector reviewed the physical inventory records of February 2008. Procedure STP 3.6.6 required the inventories to be conducted at intervals not to exceed 12 months. The physical inventory reviewed contained all SNM including the pool inventory, fission chamber inventory, and other inventory. One example reviewed was for an interim storage container (ISC18) where drudge containing SNM from the bottom of the pool was placed. All SNM was inventoried, but not whether or not it was GTCC.

The inspector verified that the physical inventory requirements were being met during the team inspection, except for GTCC waste Containing SNM. The licensee addressed this oversight by revising Procedure ISTP 3.6.6, to specifically require that the reactor-related GTCC waste containing special nuclear material be inventoried at intervals not to exceed 12 months.

Procedure HBAP E-I, revision 136, section 4.2.3 contains retention requirements that meet 10 CFR 72.72 (b).

Procedure STP 3.6.6, "SNM Inventory," Revision 25; Procedure HBAP E-I,

"Retention and Storage of HBPP Unit 3 and ISFSI Records," Revision 13B; Procedure HBAP D-7, "Control and Accountability of Special Nuclear Material Page 43 of 64

and Waste Shipment," Revision 20; Procedure ISTP 3.6.6, "SNM Inventory-ISFSI," Revision 0; Physical Inventory Records Category:

Records Topic: QA Records Reference:

10 CFR 72.1 74 Requirement: The licensee shall maintain sufficient records to furnish evidence of activities affecting quality. The records must include the following: design records, records of use, and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analysis. The records must include closely related data such as qualifications of personnel, procedures, and equipment.

Inspection and test records must identify the inspectoddata recorder, type of observation, results, acceptability, and actions taken concerning deficiencies.

Records must be maintained until termination of the license.

This requirement was achieved. The inspector verified that the requirement to maintain the QA records had been established with appropriate retention periods in Section 4.2.3 and in Appendix 7.1 of Procedure HBAP E-I. Several examples of the types of records that were reviewed are described below:

Finding:

The High Level Vault Liner Design Change documentation was reviewed (HB3-M-596) in accordance with both HBAP E-I and HBAP C-I.

Training records were reviewed. A sample of training or waivers from training was reviewed in accordance with HBAP E-I.

A test record was reviewed - "No. 1 Fire Pump Monthly Test Data Sheet" - in accordance with both HBAP E-I and HBAP C-3.

Based on these reviews, the inspector determined that the requirement was achieved.

Procedure HBAP -I,

"Retention and Storage of HBPP Unit 3 and ISFSI Records," Revision 13B; Procedure HBAP C-I, "Design Changes," Revision 22; Procedure HBAP C-3, "Conduct of Plant and Equipment Tests," Revision 19A Documents Reviewed:

Category:

Safetv Reviews Topic: Chanqes, Tests, and Experiments Reference:

10 CFR 72.48(~)(1)

Requirement: A licensee can make changes to their facility or storage cask design if certain criteria are met as listed in 10 CFR 72.48.

Finding:

This requirement was achieved. The licensee provided a copy of HBAP C-19, which is the site procedure for complying with 10 CFR 72.48. The procedure and associated attachments included the applicable criteria from 10 CFR Part 72.

No 10 CFR Part 72 evaluations had been conducted as of the date of the ISFSI Dry Run inspection. The inspector selected two of eight procedural screenings and four of thirteen hardware screenings for review to determine if the screening Page 44 of 64

process was being adequately applied.

Licensee Engineering Staff provided a copy of the electronic database that was maintained of the 72.48 reviews that were provided by the cask vendor. The licensee described how the engineering staff reviewed the Holtec 72.48 reviews.

HBAP C-I 9, "Licensing Bases Impact Evaluation (LBIE)," Revision 23A; DCPP Units I

& 2 FSAR Update, Chapter 17, Section(s) 17.2.4, 17.3, and 17.5 Documents Reviewed:

Category:

Safetv Reviews Topic: Part 50 Operating License Reference:

License SNM-2514, Condition 13 Requirement: Fuel and cask movement and handling activities that are to be performed in the Humboldt Bay Power Plant refueling building will be governed by the requirements of the Humboldt Bay Power Plant Unit 3 Facility Operating License (DPR-7) and associated Technical Specifications.

This requirement was achieved by the licensee prior to fuel loading. The major change to the existing Part 50 facility was the installation of the DAVIT crane to move the HI-STAR cask system. The licensee provided a 10 CFR 50.59 Evaluation that evaluated the design changes that had been made to the DAVIT crane since the license amendment was issued by the NRC. The major change was using a single strand jack to lift the HI-STAR instead of the three strand jacks as originally proposed by the licensee. The use of a single strand jack eliminated several of the original concerns of how the three strand jacks would be operated in unison.

10 CFR 50.59 Evaluation Number 08-01, "Installation and Testing of the DAVIT Finding:

Documents Reviewed:

Crane," Revision 1 Category:

Slinqs Topic: Slinq Heavv Load Reauirements Reference:

NUREG 0612, Section 5.1.6 (1) (b)

Requirement: Dual or redundant slings should be used such that a single component failure or malfunction in the sling will not result in an uncontrolled lowering of the load, OR the load rating of the sling should be twice the sum of the static and dynamic loads.

This requirement was achieved. There were three major lifts made with slings during the loading process. The placement of the MPC lid required four 3/4" diameter wire rope slings, each with a vertical capacity of 7,070 pounds. The weight of the MPC lid was I O, 350 pounds, therefore three of the slings would be sufficient to keep the MPC lid from an uncontrolled descent if one sling experienced a failure.

Finding:

During the lowering of the HI-STAR lid onto the HI-STAR overpack, there were four slings that were used, each with specified minimum vertical rating of 6,000 pounds. The slings that were used during the demonstration for this lift had a rated capacity of 13,200 pounds in a vertical configuration. Based on the 60 degree angle of use, each sling had an associated capacity of 11,432 pounds.

The HI-STAR lid weight was 9,000 pounds, therefore, three of the slings would Page 45 of 64

be sufficient to keep the HI-STAR lid from an uncontrolled descent if one sling experienced a failure. The licensee also imposed a requirement that the HI-STAR lid not be lifted more than 12 inches above the HI-STAR.

At the ISFSI vault, eight slings were used to lower the vault lid onto the ISFSI vault. Each of the slings had a rating of 8,400 pounds in a vertical configuration. The slings were used at a 60 degree angle, and the associated sling capacity at this angle was 7,250 pounds each. The vault lid was reported to weigh 22,750 pounds, therefore seven of the slings would be sufficient to keep the ISFSI vault lid from an uncontrolled descent if one sling experienced a fai I ure.

Procedure HPP-1125-400, "Procedure for HI-STAR Sealing, Processing and Transport to the Storage Vault at Humboldt Bay Nuclear Power Plant," Revision 0; Procedure HPP-1125-200, "Procedure For MPC Loading At Humboldt Bay Unit 3," Revision 0 Documents Reviewed:

Category:

Slinqs Topic: Slinq Inspections - Frequent Reference:

ASME B30.9, Section 9-6.9.2 Requirement: A visual inspection for damage shall be performed each day or shift the sling is used.

Finding:

This requirement was achieved. The licensee used Procedure M-I 19 to inspect rigging and to perform annual inspections. Section 5.1 specified that the rigging equipment was to be inspected on a daily basis when in use. From a practical standpoint, the plant personnel would only be working on a single shift while the heavy lifts were being performed with slings and therefore the procedure was determined to be satisfactory.

Procedure M-I 19, "Rigging and Hoisting Equipment Inspection," Revision 1 A Documents Reviewed:

Category:

Slings Topic: Slinq Load Ratinq Reference:

Requirement: In selecting the proper sling, the load used should be the sum of the static and NUREG 061 2, Section 5.1.I (5)

maximum dynamic load. The rating identified on the sling should be in terms of the "static load" which produces the maximum static and dynamic load.

This requirement was achieved. The inspector reviewed the slings selected for movement of the HI-STAR lid and the ISFSl vault lid. The minimum requirements for the sling sizes were specified in Procedure HPP-1125-400.

The inspector reviewed the slings in use during the demonstrations and found that the safety factor of the slings rated load versus the load of the HI-STAR and vault lids were well over 2.0. The slings used for the HI-STORM lid lift were each rated at 13,200 pounds in a vertical capacity and the slings used for the ISFSI vault were each rated at 8,400 pounds in a vertical capacity. A review of selected sling certifications revealed that the slings had been proof tested to twice the rated load.

Finding:

Page 46 of 64

Documents Reviewed:

Procedure HPP-1125-400, "HI-STAR Sealing and Transport Procedure,"

Revision 5; I&I Slingmax sling certifications dated February 28, 2008 for TPXC6000, TPXC2000, TPXC7000 slings Category:

Slinqs Topic: Slinq Temperature Limits Reference:

ASME B30.9, Section 9-6.8.1 Requirement: Synthetic slings shall not be used in contact with objects that exceed the temperature limit of the sling.

Finding:

This requirement was achieved. The licensee utilized Procedure M-I 19 to inspect rigging and to perform annual inspections. Section 5.1.3 contained directions on how to perform the daily sling inspections. Section 5.5 contained directions on how to perform the annual inspection of synthetic slings. Included in this section was to inspect the slings for evidence of burned or charred areas.

Included in the note were instruction that the synthetic slings were not to be exposed to temperatures in excess of 180 degrees F, unless the slings were rated for higher temperatures.

Procedure M-I 19, "Rigging and Hoisting Equipment Inspection," Revision 1 A Documents Reviewed:

Category:

Slinqs Topic: Slinq User Traininq Reference:

ASME B30.9, Section 9-6.1 Requirement: Sling users shall be trained in the selection, inspection, cautions to personnel, Finding:

effects of environment and rigging practices.

This requirement was achieved. The qualified riggers at Humboldt Bay were required to complete a reading list that included Procedure M-I 19, "Rigging and Hoisting Equipment." Instructions for inspection of rigging equipment and slings were included in Procedure M-I 19. Prior to completing rigger qualification, the rigger had to successfully complete JPMlOl, which required the rigger candidate to demonstrate the ability to inspect and use slings.

Pacific Gas & Electric Company Humboldt Bay Power Plant Job Performance Measure RIG1 01, "Rigging," Revision 0; Memorandum on Qualifying Rigging Operators Documents Reviewed:

Category:

SI i nqs Topic: Svnthetic Round Slinq Removal from Service Reference:

ASME B30.9, Section 9-6.9.4 Requirement: A synthetic round sling shall be removed from service if any of the following conditions are present: a) missing or illegible sling identification; b) acid or caustic burns; c) heat damage; d) holes, tears, cuts abrasive wear or snags that expose the core yarns; e) broken or damaged core yarns; f) weld splatter that exposes core yarns; g) round slings that are knotted; h) discoloration and brittle or stiff areas which may mean chemical or ultraviolet/sunlight damage; or i) fittings that are pitted, corroded, cracked, bent, twisted, gouged or broken.

This requirement was achieved. The licensee utilized Procedure M-I 19 to inspect rigging and to perform annual inspections. Section 5.1.3 contained Finding:

Page 41 of 64

directions on how to perform the daily sling inspections. Section 5.4 contained directions on how to perform the annual inspection of synthetic slings, which also included continuous round slings. The required annual inspection included verification that the identification tag was present, an examination of the end fittings for distortion or damage, and the examination for signs of general damage from burns, snagged or torn areas and evidence of excessive wear.

The inspector determined that a rigger, which had been trained in sling inspection techniques would discover any sling discrepancies during the required daily or annual sling inspection.

Procedure M-I 19, "Rigging and Hoisting Equipment Inspection," Revision 1A Documents Reviewed:

Category:

Slinqs Topic: Wire Rope Slinq Removal From Service Reference:

ASME B30.9, Section 9-2.9.4.

Requirement: A wire rope sling shall be removed from service if any of the following conditions are present: a) missing or illegible sling identification; b) broken wires: c) severe localized abrasion or scraping: d) kinking, crushing, bird caging, or any other damage to the rope structure; e) heat damage; f) end attachments that are cracked deformed or worn to the extent that the strength of the sling is substantially affected; or g) severe corrosion of the rope end attachments or fittings.

This requirement was achieved. The licensee utilized Procedure M-I 19 to inspect rigging and to perform annual inspections. Section 5.1.3 contained directions on how to perform the daily sling inspections. Section 5.3 contained directions on how to perform the annual inspection of wire rope slings. The required annual inspection included verification that the identification tag was present, an examination of the end fittings for distortion or damage, and the examination for signs of general damage from burns, snagged or torn areas and evidence of excessive wear. The directions also included specific rejection criteria for the number of broken wires that were found in any rope lay. The inspector determined that a rigger, which had been trained in sling inspection techniques would discover any sling discrepancies during the required daily or annual sling inspection.

Procedure M-I 19, "Rigging and Hoisting Equipment Inspection," Revision 1 A Finding:

Documents Reviewed:

Category:

Special Liftinq Devices Topic: Acceptance Testinq - Critical Loads Reference:

ANSI N14.6, Section 6.3.1 Requirement: Prior to initial use, special lifting devices used for lifting a critical load using a single path hoisting system shall be subjected to a load test equal to 300% of the maximum service load. If the special lifting device design is such that while handling the critical load, a single component failure or malfunction would not result in an uncontrolled load, the load test shall be equal to 150% of the maximum service load. After sustaining the load for a period of not less than 10 minutes, critical areas, including load bearing welds, shall be subjected to nondestructive testing using liquid penetrant or magnetic particle examination.

This requirement was achieved. The licensee provided documentation that the Finding:

Page 48 of 64

lift yoke, which was used for lifting a critical load using a single path hoisting system had been subjected to a load test equal to 300% of the maximum service load along with satisfactory NDE test reports.

Procedure HPP 1073-1 0, "Diablo Canyon Lift Yoke Load Test Procedure,"

Revision 1 ; Material Test Report, MTR-0524-3; "Diablo Canyon Lift Yoke Load Test Procedure," Revision 1; Holtec Manufacturing Division HMD CoC No. 0524-001, "Diablo Canyon Lift Yoke," Revision 0 Documents Reviewed:

Category:

Special Lifting Devices Topic: Ferritic Metal NDT Reference:

ANSI N14.6, Section 4.2.6 Requirement.: Unless exempted by the provisions of paragraphs AM 214 and 218 and table ABM-I of the ASME B&PV Code, 1989,Section VIII, Division 2, ferritic metals for load bearing members shall be subjected to a drop weight test in accordance with ASTM E 20884 or a Charpy impact test in accordance with ASTM A 370-77. The nil ductility transition (NDT) temperature, as determined by the drop weight test shall be at least 40 degrees F below the anticipated minimum service temperature.

This requirement was achieved. The licensee provided documentation of Charpy Impact testing of the lift yoke that had been performed at -40 degrees F, per the certified material test report that had been prepared by MittaI Steel.

HOLTEC HB-HI-STAR Lift Link Set DOC-I 027-5070-1 85R0 Finding:

Documents Reviewed:

Category:

Special Liftinq Devices Topic: Inspection Prior to Use Reference:

ANSI N14.6, Section 5.3.6 Requirement: Special lifting devices shall be visually inspected by operating personnel prior to Finding:

each use, for indications of damage or deformation.

This requirement was met. The inspector reviewed Attachment 10.1 of Procedure ITP 2008-02 and Appendix 9.3 of ITP 2008-1 I and found requirements for the performance of visual inspections of the special lifting devices for damage prior to each use.

Procedure ITP 2008-02, "Transporter Operating Procedure," Revision Draft; Procedure ITP 2008-1 1, "Davit Crane Operations and Maintenance," Revision Draft Documents Reviewed:

Category:

Special Liftinq Devices Topic: Load Testinq -Cask Trunnions Reference:

ANSI N14.6, Section 5.2.1 Requirement: Prior to initial use, each trunnion shall be subjected to a load test equal to 150%

of the maximum service load. After sustaining the load for a period of not less than ten minutes, critical areas, including load bearing welds, shall be subjected to non destructive testing using the liquid penetrant or magnetic particle methods.

This requirement was achieved. The inspector reviewed the documents listed documents and found that the load test had been conducted at 300 percent of the rated load for ten minutes. Therefore, each trunnion was load tested at 150 Finding:

Page 49 of 64

of the maximum service load. Following the load test the non destructive tests had been performed.

HOLTEC Report HI-2033042 "Miscs. Calculations for the HI-STAR HB",

for the Fabrication of HI-STAR HB," Revision 3 Documents Reviewed:

Revision 3; HOLTEC Purchase Specification PS-5043, Purchase Specification Category:

Special Liftinu Devices Topic: Stress Desiun Factors Reference:

Requirement: The load bearing members of special lifting devices shall be capable of lifting ANSI N14.6, Section 3.2.1.I three (3) times the combined weight of the cask plus the weight of the intervening components of the special lifting device, without generating a combined shear stress or maximum tensile stress at any point in the device in excess of the corresponding minimum tensile yield strength of the material of construction. They shall also be capable of lifting five (5) times the weight without exceeding the ultimate tensile strength of the materials.

This requirement was achieved. The load bearing members of the special lifting devices were designed to meet a minimum of three times the combined weight, not to exceed the Yield strength (Fy), and five times the combined weight, not to exceed the Ultimate strength (Fu). The CoC from the designer and fabricator indicated incorporation of the required stress design safety factors for the design of the special lifting devices.

Holtec Report, HI-2033042 "Miscs. Calculations for the HI-STAR HB," Revision Fabrication of HI-STAR HB, "Revision 3; Holtec Report HI-2063505, I' Structural Analysis of Diablo Canyon Lift Yoke," Revision 1 Finding:

Documents Reviewed:

3; Holtec Purchase Specification PS-5043, Purchase Specification for the Category:

SDecial Liftins Devices Topic: Stress Desiun Factors - Critical Load Reference:

ANSI N14.6, Section 6.2 Requirement: The special lifting device used to lift a Critical Load shall either (I) have all the load bearing members with twice the normal stress design factors (6 for material yield and 10 for material ultimate strength) for handling the critical load or (2) use a dual load path system such that two separate and distinct load paths are provided in the event that one path fails, the second path will continue to hold the load for transport to a set down area.

This requirement was achieved. The review of the listed documents indicated that the structural assessment of the lift yoke was accomplished using formulations of strength of materials. The applied load for the lift yoke was the lifted payload plus the dynamic impact load or the hoist load. The analysis was conducted using the MATHCAD 11 software. Since there is no redundancy in the load path for Humboldt Bay special lifting device, the allowable tensile stress in the lift yoke load path components should have been limited to lower of either 1/10 of the material ultimate strength or 1/6 of the material yield strength. The inspector reviewed Section 9.0 "Summary of Results", in HI-2063595 and found that all the stress design factors for the lift yoke components met or exceeded the requirements. HMD CoC 0524-001 indicated that the fabricator's certificate Finding:

Page 50 of 64

of compliance incorporated the correct stress design factors for the design of the special lifting devices.

Holtec Report HI-2063595, "Structural Analysis of Diablo Canyon Lift Yoke,"

Revision 1 ; Holtec Report HI-2073674, Structural Evaluation of HI-STORM Lifting Bracket for Diablo Canyon," Revision 2; Purchase Specification, PS-5056, Purchase Specification for Diablo Canyon HI-TRAC/HI-STAR Lift Yoke,"

Revision 3; Purchase Specification, PS-5101, "Purchase Specification for HB Lift Anchor," Revision 2; Holtec Manufacturing Division HMD CoC No. 0524-001, Rev. 0 (dated lO/l5/2007)

Documents Reviewed:

Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

Special Liftina Devices Topic: Transfer Cask Trunnion Safetv Factors NUREG 0612, Section 5.1.6 (3)

Redundant or dual lifting lugs (cask trunnions), designed such that the loss of one will not result in a load drop, shall have an ultimate strength of 5 times the maximum combined concurrent static and dynamic load. Non-redundant or non-dual lifting lugs or cask trunnions shall have an ultimate strength of 10 times the maximum combined concurrent static and dynamic load.

The requirement was achieved. The cask trunnions were designed such that the lifting lugs were non-redundant and thus required an ultimate strength of 10 times the maximum combined concurrent static and dynamic loads. The inspector found in Supplement 7, "Lifting Trunnion Stress Analysis for HI-STAR HB," located in HI-2033042 that the stipulated requirements of NUREG 0612 for non-redundant lifting lugs were achieved. Section 9 of HI-2063505 provided documentation that the stress safety factors for the lifting yoke were met.

HOLTEC Report HI-2033042 "Miscs. Calculations for the HI-STAR HB",

Revision 3; HOLTEC Purchase Specification PS-5043, 'I Purchase Specification for the Fabrication of HI-STAR HB," Revision 3; Holtec Report, HI-2063505 I'

Structural Analysis of Diablo Canyon Lift Yoke," Revision 1.

Category:

Special Topics Topic: Reporting of Defects Reference:

10 CFR 21.6 Requirement: Each corporation shall post current copies of the 10 CFR Part 21 regulations and the procedures adopted pursuant to the 10 CFR Part 21 regulations.

Finding:

The inspection team discovered that the licensee was not meeting the regulatory requirements. During the team inspection it was observed that the licensee had not posted the 10 CFR Part 21 regulations as required by 10 CFR 21.26(a)(I)(i).

The licensee wrote SAPN 1246508 upon discovery of the noncompliance and immediately posted the required information. Procedure HBAP-3 specified that the regulations of Part 21 were to have been posted in a conspicuous position, however the licensee was not in compliance with the procedure.

The inspectors also found that there were no Humboldt Bay procedures that provided specific instructions or references to other corporate procedures for guidance on reporting defects or noncompliance's as required by 10 CFR 21.26(a)(I)(iii). Procedure OM7.ID11 was a corporate level procedure that did Page 51 of 64

provide instructions for evaluating deviations and failures to comply that might be reportable to the NRC, however it was not referenced by any Humboldt Bay procedures. Following the identification of the finding, the licensee revised Procedure HBAP C-I 1, Appendix 7.3 to include specific instructions for reporting of defects and noncompliance's as well as a reference to Procedure OM7.ID11.

Regulation 10 CFR 21.6(a)(l) required in part that the licensee post current copies of 10 CFR Part 21 regulations and post copies of the procedures adopted pursuant to the regulations of 10 CFR Part 21. Contrary to the this, the inspectors found on April 29, 2008, that the licensee had not posted current copies of the 10 CFR Part 21 regulations and had not posted the procedures pursuant to the regulations of 10 CFR Part 21 or posted a notice of where the procedures could be examined. The inspectors found that the licensee did not have approved site procedures that provided instructions for reporting defects or noncompliance's per the requirements of 10 CFR Part 21. The licensee had entered the issues into their corrective action system as SAPN 1246508. This Severity level IV violation is being treated as a Non-Cited Violation, consistent with Section V1.A of the NRC Enforcement Policy.

Procedure HBAP C-I 1, "Non-Routine Notification and Reporting to the Nuclear Regulatory Commission (NRC)," Revision 10 and 11 ; Procedure HBAP E-3,

"Posting of Notices to Employees," Revision 5; Procedure OM7.ID11, " I O CFR 21 Reportability Review Process," Revision 2A Documents Reviewed:

Category:

Tech Spec Programs Topic: Cask Transportation Evaluation Program Reference:

HB Technical Specification 5.1.5 Requirement: A program to evaluate and control the transportation of loaded SFSCs between the Humboldt Bay Refueling Building and the ISFSI storage vault will be implemented. Included in this program will be the transportation route road surface conditions, onsite hazards along the transportation route and controls for severe weather.

This requirement was initially not met, but was achieved prior to loading.

Procedure ITP 2008-05 provided the requirements that must be met before beginning the transport of the loaded HI-STAR. Included in the procedure were the major potential explosive sources listed in the Humboldt Bay FSAR.

However, the licensee had not initially provided information in the procedure to delineate either the amount or distance of any flammable or combustible material that might be located along the transport route. The procedure was revised to define combustible material volume requirements along with a specific minimum distance which the material must be separated from the cask transport path as being acceptable to leave in place during the transport operations. The combustible material was defined according to the licensee's existing fire protection program and evaluated against the Part 72 explosive requirements in SAPN 1247041.

Finding:

The NRC inspection team identified some procedural discrepancies that were discussed at the debrief meeting for resolution by Humboldt Bay personnel. The team identified that multiple sections of the FSAR referred to the Cask Page 52 of 64

Transportation Evaluation Program (CTEP) as being located in Section 10.2; however, that section of the FSAR did not involve the CTEP. The FSAR was subsequently revised to eliminate the reference to section 10.2, as the CTEP is a self-contained program incorporated into procedure ITP 2008-05. The team also noted that the draft procedure ITP 2008-05 stated that if additional hazards are identified during inspections and walkdowns, then Plant Engineering shall evaluate them using RG 1.91 risk acceptance criteria; however, RG 1.91 is only used for evaluating risk from explosions, not from combustible loadings or other hazards.

The inspection also noted that initially there were no procedural requirements for the amount of diesel fuel in the mobile crane that was used to place the ISFSI vault lid. This was corrected in Revision 1 to specify that the amount of diesel fuel in the mobile crane must be less than 50 gallons.

Procedure ITP 2008-05, "Cask Transportation Evaluation Program," Revision 1 ;

SAPN 1247041, Dated July 18, 2008 Documents Reviewed:

Category:

Reference:

Requirement.

Finding:

Documents Reviewed:

Tech Spec Proqrams Topic: ISFSI Operations Proqram HB Technical Specification 5.1.4 A program to implement the Humboldt Bay ISFSI FSAR requirements for ISFSI operations will be established and maintained to include the SFSC cask storage location and the design basis ISFSI parameters consistent with the ISFSI FSAR analysis.

This requirement was achieved. The licensee had established controls for ISFSI operations that included the cask storage location and design basis ISFSI parameters in Procedures HPP-1125-200, 300 and 400. The separate work orders that controlled the loading operations for each cask supplemented the controls for any changes that might be necessary for the loading operations. To ensure that changes made to procedures were controlled such that the FSAR requirements were not inadvertently changed, the licensee used the Licensing Basis Impact Evaluation (LBIE) screen document to determine when a 10 CFR 72.48 evaluation was necessary.

Procedure HPP-1125-200, "Procedure for MPC Loading at Humboldt Bay Unit 3," Revision 2; Procedure HPP-1125-300, "Procedure for Drying, Backfill and Sealing the MPC," Revision 4; Procedure HPP-1125-400, "Procedure For HI-STAR Sealing, Processing and Transport to the Storage Vault at Humboldt Bay Nuclear Power Plant," Revision 2; SAPN 1246432, Task 02, "Fuel Loading-HI-STAR Position #I Category:

Tech Spec Proqrams Topic: Tech Spec Bases Control Proqram Reference:

HB Technical Specification 5.1.I Requirement: A program to review changes to the Tech Spec Bases that are made without prior NRC approval shall be established, implemented and maintained.

Finding:

This requirement was achieved prior to loading operations. During the NRC team inspection, Procedure HBAP E-9 was found to only address changes to TS Page 53 of 64

bases for Humboldt Bay's Part 50 program. The requirements of the Humboldt Bay Technical Specification 5.1.I under Part 72 license requirements had not been incorporated. Procedure HBAP E-9 was revised to incorporate the Part 72 TS requirements in revision 1 to the procedure.

Procedure HBAP E-9, Vol. 1, "Revision of Technical Specification Bases,"

Documents Reviewed:

Revision 1 Category:

Training Topic: Certification of Personnel Reference:

10 CFR 72.190 Requirement: Operations of equipment and controls that have been identified as important to safety in the SAR and in the license must be limited to trained and certified personnel or be under the direct visual supervision of an individual with training and certification in the operation. Supervisory personnel who personally direct the operation of equipment and controls that are important to safety must also be certified in such operations.

This requirement was achieved. Procedure IAP B-300 provided the requirements of the licensee's ISFSI training program. The ISFSI training and certification program included three major elements consisting of 1 ) ISFSI fundamentals which provided a general overview of the ISFSI, 2) ISFSI loading which provided job specific knowledge to implement the operational procedures and 3) ISFSI operations which involved the maintenance and ongoing operations of the Humboldt Bay ISFSI. The ISFSI operations portion of training also included a two year frequency on retraining.

Finding:

The Humboldt Bay ISFSI training program utilized the Systems Approach to Training (SAT) as required by the Humboldt Bay FSAR. The training program allowed personnel to perform ISFSI system operations after satisfactory completion of related course material. Job Performance Measures (JPMs) had been established to evaluate the competence of the trainees in the assigned tasks. Following successful completion of course material and applicable JPMs, the individual was considered to be qualified for the applicable operation.

Personnel were allowed to perform ISFSI operations without ISFSI certification while under direct supervision of an individual who was certified in the ISFSI operation which was being performed.

Prior to the initial loading efforts, the inspector verified ihai the majority of the loading team had completed the respective training and JPM requirements and were completely qualified to operate the ISFSI equipment.

10 CFR 72.1 90; IAP B-300, "ISFSI Training and Certification Program,"

Revision 0; Procedure HBAP B-2, Attachment. 5, "Training Session Record(s),"

Revision 17; HBPP Information / Qualifications System (Computer Record);

JPM 213-01, "VCT Operations," Revision 0; JPM ISFSI-217, "Davit Crane Operations," Revision 0; ITP 2008-01, "Installation and Testing of the Holtec Davit Crane," Revision 2; Procedure HPP-1125-400, "Procedure for Hi-Star Sealing, Processing and Transport to the Storage Vault at Humboldt Bay Power Plant," Revision 0; ITP 2008-02, "Transporter Operating Procedure," Draft; Documents Reviewed:

Page 54 of 64

Course # ISFSI-203, "Davit Crane Operations," Revision 0; Course # ISFSI-207,

"Hi-Star Component Handling," Revision 0 Category:

Train inq Topic: Health Requirement for Certified Personnel Reference:

10 CFR 72.1 94 Requirement: The physical condition and the general health of personnel certified for the operation of equipment and controls that are important to safety must not be such as might cause operational errors that could endanger other in plant personnel or the public health and safety. Any condition that might cause impaired judgment or motor coordination must be considered in the selection of personnel for activities that are important to safety. These conditions need not categorically disqualify a person if appropriate provisions are made to accommodate such defect.

This requirement was achieved. Humboldt Bay Procedure HBAP A-I 6, Section 4.8 required that personnel involved in spent fuel and cask handling for the ISFSI shall be medically qualified to ANSI N546-1976. The medical requirements of ANSI N546-1976 included examinations for mental alertness; freedom from incapacity in the areas of respiratory, cardiovascular, endocrine, neurological and mental disorders. Specific minimum capacities of the personnel were also specified.

Finding:

The inspector reviewed licensee records indicating that the individuals that were planned to operate Important to Safety equipment had received medical examinations in accordance with ANSI N546-1976.

10 CFR 72.1 94; IAP B-300, "ISFSI Training and Certification Program,"

Revision 0; HBAP A-I 6, "Medical Examinations," Revision 14; ANSI N546,

"Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants," Revision 1976; I Q Screen Print of ISFSI Medical Examinations on July 15, 2008.

Documents Reviewed:

Category:

Train i nq Topic: NRC Approved Traininq Program Reference:

10 CFR 72.44(b)(4)

Requirement: The licensee shall have a training program in effect that covers the training and certification of personnel that meet the requirements of subpart I before the licensee receives spent fuel at the ISFSI This requirement was achieved. The licensee's training program addresses the areas delineated in subpart I of the regulations.

10 CFR 72.44(b)(4), 72.190, 72.192, and 72.1 94; IAP B-300, "ISFSI Training and Certification Program," Revision 0 Finding:

Documents Reviewed:

Category:

Unresolved Items Topic: URI 72-027/0701-01 Reference:

N/A Requirement: During the inspection of the third and final concrete placement for the Humboldt Page 55 of 64

Bay ISFSI, a minor deviation was identified that involved the number of mixing revolutions of the concrete mixing truck that had been used to produce the Important-To-Safety (ITS) concrete. The deviation was determined to be non-safety significant based on the expectation that the concrete would meet or exceed the required minimum 28 day compressive strength of 4,000 psi. NRC Unresolved Item (URI) 72-027/0701-01 was opened to track and confirm that the minimum concrete compressive strength requirements were achieved.

The inspector reviewed the 28 day compression test results from the concrete cylinders that were cast on August 16, 2007. The results of the average compressive breaking strength for the two cylinder sets that were tested at 28 days were 8,200 psi; 8,070 psi; 6,495 psi and 7,280 psi.

Finding:

The licensee discovered that one of the set of compressive test results for the 28 day tests associated with specimen C1967E appeared to be low with a breaking strength of 4,690 psi. The other concrete cylinder that had been cast at the same time, C1967D broke under a compressive load of 8,300 psi. The average of the two 7 day cylinder breaks for concrete specimen numbers C2967A and C2967B exceeded 6,400 psi. The licensee tested a third concrete cylinder from this same set at 35 days to confirm the concrete compressive strength was not low. The third concrete cylinder was specimen number C2967F which was tested at 35 days and broke at 9,090 psi. All of the concrete compressive test results exceeded the minimum requirements of ACI 349 and the minimum compressive strength requirements of 4,000 psi. URI 72-027/0701-01 is closed.

SHN Compression Test Results for Specimen Numbers C2968, C2967, C2969 Documents Reviewed:

and C2966 Category:

Unresolved Items Topic: URI 72-02710701-02 Reference:

N/A Requirement: During the inspection of the concrete placement activities for the Humboldt Bay ISFSI vault, several minor deviations from the ISFSl design documents, ACI code and ASTM standard requirements were identified by the licensee and the inspector. These deviations were entered into the licensee corrective action system to ensure that the changes were appropriately tracked. NRC URI 72-027/0701-02 was opened to track and confirm that the deviations did not impact the ability of the ISFSI vault to perform its intended function and that the licensee can approve the changes through the I O CFR 72.48 process.

The licensee documented their review and disposition of the identified discrepancies that had occurred during ISFSI construction in Document HBPP 2006-01. Addressed in the document were the reinforcing bar interferences and the concrete mix design inconsistencies. The licensee had performed a 50.59/72.48 screening and determined that prior NRC approval was not required for the deviations. The inspector reviewed the 72.48 screening and found that the licensee disposition was in general appropriate, however it did not address the potential license basis impacts from minor deviations encountered in concrete construction methods prescribed by ACI 349. This discrepancy was documented by the licensee in SAPN 1245801 and is not safety significant due to the minor variations encountered that did not impact the Important-To-Safety Finding:

Page 56 of 64

(ITS) attributes of the concrete. This condition constitutes a violation of minor significance that is not subject to enforcement in accordance with Section IV of the Enforcement Policy.

Two additional SAPN Numbers 1242591 and 1244216 were reviewed which documented potential discrepancies of the concrete density in the ISFSI vault lids and port plugs below the specified minimum dry density of 146 pounds per cubic feet. The concrete density of the vault lids and the port plugs were determined to be adequate by the licensee, however the concrete density of the port plugs was determined to be 141 pounds per cubic feet. The port plugs were located near the edge of the ISFSI vault lid and the licensee had determined that the reduced concrete density of these small items would not contribute to an increased dose rate. At the inspector's request ISFSI Pad Survey Number 2008-0583 was taken which indicated that the dose rate near the edge of the ISFSI vault lid was relatively constant. URI 72-027/0701-02 is closed.

Humboldt Bay Document HBPP 2--6-01, "Specification for Construction of an Independent Spent Fuel Storage Installation (ISFSI)," Revision 1 ; SAPN 1244216, "ISFSI Lids Concrete Density Deviation," Dated August 16, 2007; SAPN 1242591, "NCR for vault liner closure lid concrete," Dated February 28, 2007; SAPN 1245801, "Unresolved Item: 72.48 Evaluation," Dated August 21, 2008 Documents Reviewed:

Category:

Weld inq Topic: Hydrosen Purse & Monitorinq Reference:

Requirement: To preclude hydrogen ignition during welding or cutting, the operating HB FSAR, Section 4.6.1.I procedures for the Humboldt Bay ISFSI required that the space beneath the MPC be purged or exhausted before and during the MPC lid welding or cutting operations. In addition, appropriate combustible gas monitoring is performed during these operations.

This requirement was achieved prior to fuel loading operations. As a result of the findings during the initial welding demonstration, Procedure PI-900971-01 was revised to include improved methods for ensuring that hydrogen did not accumulate during the welding process. Section 8.1 0 of PI-900971-01 specified that an inert gas be introduced beneath the MPC lid and monitored during the entire MPC lid-to-shell weld. Welding operations were to be stopped if the combustible gas readings exceeded 50 percent of the lower explosive limit.

Procedure PI-900971 -01, "Closure Welding of Multi-Purpose Canisters at Humboldt Bay," Revision 2; Certificate of Conformance for H2Scan Model 1700, Dated June 20,2008 Finding:

Documents Reviewed:

Category:

Reference:

Requirement:

Weldinq Topic: Welding and NDE Requirements HB FSAR, Section 4.2.3.3 All references to the ASME Code are to the 1995 Edition with 1996 and 1997 addenda. Activities for Section V (NDE) and IX (Welding) are performed in accordance with the latest edition of the Code.

Page 57 of 64

Finding:

This requirement was achieved. In Revision 2 of Procedure PI-900971-01 the requirement was stated that all the weld filler material must comply with ASME Section Ill, Subsection NB, 1995 Edition with 1996 and 1997 Addenda.

Procedure PI-900971 -01, "Closure Welding of Multi-Purpose Canisters at Documents Reviewed:

Humboldt Bay," Revision 2 Category:

Weld i nu Mate rials Topic: Minimum Delta Ferrite Content Reference:

Requirement: A delta ferrite determination must be made for A-No.8 consumable inserts, bare ASME Ill, Article NB-2433; Reg Guide 1.31 electrode, rod, or wire filler metal. Exceptions: 1) A-No.8 metal used for weld metal cladding; 2) SFA-5.4 and SFA-5.9 metal; 3) Type 16-8-2 metal. The minimum acceptable delta ferrite content is 5 FN and it must be stated in the certification records.

This requirement was implemented. The two 35 pound spools of 0.035" ER308/308L welding wire contained a delta ferrite content of 8 FN. The two 10 pound spools of 0.035" ER308L welding wire contained a delta ferrite content of 12 FN. The 1/8" X 36" cut lengths of ER308L welding wire contained a delta ferrite content of 10.7 FN. The 3/32" X 36" cut lengths of ER308L welding wire contained a delta ferrite content of 13.2 FN.

Arcos Industries Certified Material Test Report dated February 20, 2005; Techalloy Certified Material Test Reports (2) dated September 18, 2001 Finding:

Documents Reviewed:

Category:

Welding Personnel Qual Topic: Expiration Reference:

ASME Section IX, Part QW-322.1 Requirement: The performance qualification of a welder or welding operator, for any process, shall expire when he has not welded with that process for six months or more.

Finding:

This requirement was achieved. Procedure PCI-WCP-2, Section 7.1 1.8 specified that a welder's or welding operator's qualification would expire if the individual had not welded with that process for six months or more. The Welder Maintenance Log (WML) records were reviewed by the inspector for the three welders present during the welding demonstration. The WML records indicated that the welders met the above requirements.

Procedure PCI-WCP-2, "Welder / Welding Operators Performance Qualification," Revision 1 1 and the Welder Maintenance Log (WML)

Documents Reviewed:

Category:

Weldina Personnel Qual Topic: Welder Performance Qual Test (WPQ)

Reference:

Requirement: The welder performance qualification test shall be welded in accordance with a ASME Section IX, Part QW-301.2 qualified welding procedure specification (WPS), unless preheat or post weld heat treatment is specified.

This requirement was implemented. PCI had supplied three welders to the Humboldt Bay ISFSI project. All three were qualified for machine GTAW welding and two of the three were qualified for manual GTAW welding.

Finding:

Page 58 of 64

The Welder Performance Qualification (WPQ) Records for the three welders were reviewed. The machine GTAW welder performance qualification tests were welded in accordance with Welding Procedure Specification (WPS) 1 -MC-GTAW, Revision 3. The manual GTAW welder performance qualification tests were welded in accordance with WPS 8-MN-GTAWKMAW Revision 3. Preheat or post weld heat treatment were not specified for either manual or machine welding.

PCI Energy Services ASME Section IX Welder Performance Qualification Documents Reviewed:

(WPQ) Records C ateg 0 ry :

We Id i n q P e rso n ne I Qua I To pic : We Id e r P e rfo r m a n ce Qua I if i ca t i o n ( W P Q 1 Reference:

ASME Section IX, Parts QW-301.4, 356, 452.1, 6 Requirement: The record of welder performance qualification (WPQ) tests shall include the essential variables listed in QW-350, the type of test and test results, and the ranges qualified in accordance with QW-452. The essential variables for manual GTAW welding are: (1) Backing; (2) Base metal P-number; (3) Filler metal F number; (4) Consumable inserts; (5) Filler metal form; (6) Maximum weld deposit thickness; (7) Welding positions; (8) Welding progression; (9) inert gas backing; and (IO) Current type and polarity. Two side bend tests are required for groove weld test coupons 3/8 inch thick or greater. Groove weld tests qualify fillet welds.

This requirement was implemented. PCI had supplied three welders to the Humboldt Bay ISFSI project. All three were qualified for machine Gas Tungsten Arc Weld (GTAW) process and two of the three were qualified for manual GTAW process welding.

Finding:

The Welder Performance Qualification (WPQ) Records for the two welders qualified for manual GTAW process welding were reviewed. The welder performance qualification tests contained all the essential variables required by ASME Section IX for manual GTAW process welding. Radiography and side bend tests were used to qualify the welds.

PCI Energy Services ASME Section IX Welder Performance Qualification Documents Reviewed:

(WPQ) Records Category:

Weldinq Personnel Qual Topic: Weldinq Operator Performance Qualification Reference:

Requirement: The record of welding operator performance qualification (WOPQ) tests shall ASME Section IX, Parts QW-301.4, 361.2, include the essential variables listed in QW-360, the type of test and test results, and the ranges qualified in accordance with QW-452. The essential variables for machine welding are: (1) welding process; (2) direct or remote visual control; (3) automatic arc voltage control (GTAW); (4) automatic joint tracking; (5) position qualified; (6) consumable inserts; (7) backing; and (8) single or multiple passes per side. Two side bend tests are required for groove weld test coupons 3/8 inch thick or greater. Groove weld tests qualify fillet welds.

Page 59 of 64

Finding:

This requirement was implemented. PCI had supplied three welders for the Humboldt Bay ISFSI demonstration. All three were qualified for machine GTAW welding and two of the three were qualified for manual GTAW welding.

The Welder Performance Qualification (WPQ) Records for the three welders qualified for machine GTAW welding were reviewed. The welder performance qualification tests contained all the essential variables required by ASME Section IX for machine GTAW welding. Radiography and side bend tests were used to qualify the welds.

PCI Energy Services ASME Section IX Welder Performance Qualification Documents Reviewed:

(WPQ) Records Category:

Weld ins Procedures Topic: Governing Code Years Reference:

HB FSAR, Section 4.2.3.3 Requirement: All references to the ASME Code are to the 1995 Edition with 1996 and 1997 addenda. Activities for Section V (NDE) and IX (Welding) are performed in accordance with the latest edition of the Code.

This requirement was implemented before the end of the welding inspection.

The inspectors found at the beginning of the inspection that the welding materials provided by the welding contactor had not been procured to the 1995 edition of the ASME code with addenda through 1997, and a code reconciliation had not been performed.

Finding:

The two 35 pound spools of 0.035" ER308/308L welding wire met the requirements of ASME Section I l l, 2004 edition with no addenda. The two 10 pound spools of 0.035" ER308L welding wire met the requirements of ASME Section I l l, 1986 edition with no addenda. The 1/8" X 36" and 3/32" X 36" cut lengths of ER308L welding wire met the requirements of ASME Section I l l, 1998 edition with addenda through 2000.

During the inspection, the welding contractor performed a code year reconciliation by comparing the chemical composition of the welding wire supplied during the demonstration, with the chemical composition of welding wire specified by the 1995 edition of the ASME code with addenda through 1997.

The chemical composition was the same. To preclude a similar problem during the MPC welding operations, Section 8.4 of Procedure Pl-900971-01 was revised to have Quality Control verify that the materials were certified to the correct Code years and if not, a Code reconciliation had been performed.

Procedure Pl-900971-01, "Closure Welding of Multi-Purpose Canisters at Humboldt Bay," Revision 2; PCI Energy Services Certificate of Conformance No. 900971 -01 dated February 12, 2008; Weldstar Certificate of Compliance dated March 12, 2006; Arcos Industries Certified Material Test Report dated February 20, 2005; Techalloy Certified Material Test Reports (2) dated September 18, 2001 Documents Reviewed:

Page 60 of 64

Category:

Weldinq Procedures Topic: GTAW Essential Variables Reference:

Requirement: The welding procedure specification (WPS) for Gas Tungsten Arc Welding ASME Section IX, Part QW-256 (GTAW) shall describe the following essential variables: (1) Base metal thickness range; (2) Base metal P number; (3) Filler metal F number; (4) Filler metal A number; (5) Filler metal product form (flux, metal, powder); (6)

Maximum weld deposit thickness; (7) Minimum preheat temperature; (8) PWHT conditions; (9) Shielding gas mixture; and (IO) Trailing Shielding gas mixture and flow rate.

This requirement was achieved. The inspector reviewed the WPS and determined that the required GTAW essential variables were adequately addressed.

WPS for 8MC-GTAWI, Revision 10 Finding:

Documents Reviewed:

Category:

Weldinq Procedures Topic: GTAW Non Essential Variables (1-14)

Reference:

Requirement: The welding procedure specification for Gas Tungsten Arc Welding (GTAW)

ASME Section IX, Part QW-256 must describe the following non-essential variables: (1) Joint design; (2)

Backing; (3) Backing material; (4) Root spacing; (5) Retainers; (6) Filler metal size; (7) Consumable inserts; (8) Filler metal SFA specification number; (9)

Filler metal AWS classification number; (1 0) Welding positions; ( I 1) Welding progression; (1 2) Trailing Shielding gas composition and flow rate; (1 3) Pulsing current; (14) Current type and polarity; This requirement was achieved. The inspector reviewed the WPS and determined that the required GTAW non essential variables were adequately addressed.

WPS for 8MC-GTAWI, Revision 10, Finding:,

Documents Reviewed:

Category:

Weldinq Procedures Topic: GTAW Non Essential Variables (15-27)

Reference:

Requirement: The welding procedure specification for Gas Tungsten Arc Welding (GTAW)

ASME Section IX, Part QW-256 must also describe the following non-essential variables: (1 5) Amperage range; (1 6) Voltage range; (1 7) Tungsten size; (1 8) String or weave bead; (1 9) Orifice or gas cup size; (20) Method of initial and interpass cleaning; (21) Method of back gouging; (22) Oscillation width; (23) Multiple or single pass per side; (24)

Multiple or single electrodes; (25) Electrode spacing; (26) Travel mode and speed; and (27) Peening.

The requirement was met. The inspector reviewed the WPS for 8MC-GTAWI and determined that it complied with the ASME Code requirements.

WPS for 8MC-GTAWI, ASME Section IX Procedure Specification, Revision. 10 Finding:

Documents Reviewed:

Category:

Weldinq Procedures Topic: GTAW Supplementaw Essential Variables Reference:

ASME Section IX, Part QW-256 Page 61 of 64

Requirement: The welding procedure specification for Gas Tungsten Arc Welding (GTAW)

must describe the following supplementary essential variables, when required:

(I)

Base metal group number; (2) Base metal thickness range; (3) Welding positions; (4) Maximum interpass temperature; (5) PWHT conditions; (6)

Current type and polarity); (7) Multiple or single pass per side; and (8) Multiple or single electrodes.

This requirement was achieved. The inspector reviewed the WPS and determined that the required GTAW supplementary essential variables were adequately addressed.

WPS for 8MC-GTAWI, Revision I O Finding:

Documents Reviewed:

Category:

Welding Procedures Topic: Procedure Qualification Record (PQR)

Reference:

Requirement: Each manufacturer or contractor shall prepare a Procedure Qualification Record ASME Section IX, Part QW-200.2 (PQR) for each procedure. The completed PQR shall document all essential and, when required, all supplementary essential variables of QW-250 through QW-280 for each welding process used during the welding of the test coupon.

Non essential variables may be documented at the contractor's option. The PQR shall be certified accurate by the manufacturer or contractor.

This requirement was achieved. The applicable documents associated with the PQR had been approved by the PCI Principle Welding Engineer, the PCI QA Manager and Holtec. The inspector reviewed the PQR and determined that it met the ASME Code requirements stated above.

WPS for 8MC-GTAWI, ASME Section IX Procedure Specification, Revision 10 PCI-PI-900971-01, 'Closure Welding of Multi-Purpose Canisters at Humboldt Bay," Revision 0.

PQR-O46R/3, Procedure Qualification Record PQR-O62R/3, Procedure Qualification Record PQR-600R/4, Procedure Qualification Record Finding:

Documents Reviewed:

Category:

Welding Procedures Topic: Tack Welds Reference:

ASME Section I l l, Article 1\\18-4231.I Requirement: Tack welds used to secure alignment shall either be removed completely when they have served their purpose, or their stopping and starting ends shall be properly prepared by grinding or other suitable means so that they may be satisfactorily incorporated into the final weld. When tack welds are to become part of the finished weld, they shall be visually examined and defective tack welds shall be removed.

This requirement was not met during the welding demonstration, but was corrected prior to loading operations. During the inspection of the welding demonstration, Procedure PI-900971-01 did not specify that the starting and stopping ends of the tack welds be properly prepared by grinding or other suitable means before incorporation into the final weld. This finding was brought to the attention of the licensee.

Finding:

Page 62 of 64

In Revision 2 to the PCI Procedure, the note was added to Section 9.1.I 1 that the tack weld ends must be grinded prior to the start of the root pass weld.

PCI Procedure PI-900971 -01, "Closure Welding of Multi-Purpose Canisters at Documents Reviewed:

Humboldt Bay," Revision 2, Category:

Reference:

Requirement:

Finding:

Documents Reviewed:

Weldinq Procedures Topic: Weld Repairs - Base Metal Defects ASME Section I l l, Article NB-4132 Weld repairs exceeding in depth the lesser of 3/8 inch (IO mm) or 10 percent of the section thickness, shall be documented on a report which shall include a chart which shows the location and size of the prepared cavity, the welding material identification, the welding procedure, the heat treatment, and the examination results of the weld repair.

This requirement was not met at the time of the welding demonstration, but was achieved before cask loading. Prior to the loading operations the inspector received Procedure PCI GWS-1, which provided instructions for repair of base metal material, including limitations on depth of defect and the requirement to perform a PT or MT of the repaired area after repair.

PCI Procedure PI-900971 -01, "Closure Welding of Multi-Purpose Canisters at Humboldt Bay," Revision 0; PCI General Welding Standard GWS-1 "ASME Applications," Revision 3 Category:

Weldinq Procedures Topic: Weld Repairs - Surface Defects Reference:

Requirement: Surface defects may be removed by grinding or machining without weldout ASME Section I l l, Article NB-4452; NB-2538.c provided the minimum section thickness is maintained, the depression is blended and liquid penetrant testing is performed to ensure the defect is removed.

Finding:

Documents Reviewed:

Areas ground to remove oxide scale or other mechanically caused impressions for appearance or to facilitate proper ultrasonic testing need not be examined by the magnetic particle or liquid penetrant test method.

This requirement was not met during the welding demonstration, but was achieved prior 'to cask welding. The PCI Procedure PI-900971-01 used during the welding demonstration did not include the stated requirement or allowance to remove surface defects as described above. Prior to welding the canister loaded with fuel, the PCI crew produced PCI GWS-1, which provided instructions for the repair of weld metal defects without welding.

PCI Procedure PI-900971 -01, "Closure Welding of Multi-Purpose Canisters at Humboldt Bay," Revision 0; PCI General Welding Standard GWS-1, "ASME Applications," Revision 3 Page 63 of 64

Category:

Weldins Procedures Topic: Weldins Procedure Specification (WPS)

Reference:

Section IX, Part QW-200.1 Requirement: Each manufacturer or contractor shall prepare written Welding Procedure Finding:

Documents Reviewed:

Specifications for making production welds to code requirements. Welding Procedure Specifications shall include the essential, non-essential, and (when required) supplementary essential variables for each welding process. The variables are listed in QW-250 through QW-280 and are defined in Article IV, Welding Data.

This requirement was achieved. The documents had been approved by the PCI Principle Welding Engineer and the QA Manager. The WPS adequately included the requirements of the supporting PQR's.

WPS for 8MC-GTAWI, ASME Section IX Procedure Specification, Revision 10 PCI-PI-900971-01, "Closure Welding of Multi-Purpose Canisters at Humboldt Bay," Revision 0.

PQR-O46R/3, Procedure Qualification Record PQR-O62R/3, Procedure Qualification Record PQR-600R/4, Procedure Qualification Record Page 64 or64