IR 05000445/2015009

IR 05000445/2015009, 05000446/2015009, 0720074/2015001, April 20-24, 2015, Comanche Peak, Units 1, 2, and Independent Spent Fuel Storage (ISFSI)

ML15138A348
Person / Time
Site:	Comanche Peak
Issue date:	05/18/2015
From:	Lee Brookhart, Simpson A NRC/RGN-IV/DNMS/RSFSB
To:	Flores R Luminant Generation Co
Kellar R
References
IR 2015001, IR 2015009
Download: ML15138A348 (21)

Text

May 18, 2015

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1, 2, AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

INSPECTION REPORT 05000445/2015009, 05000446/2015009, AND 07200074/2015001

Dear Mr. Flores:

This letter refers to a routine inspection conducted on April 20-24, 2015, of the dry cask storage activities associated with your Independent Spent Fuel Storage Installation (ISFSI).

The enclosed inspection report documents the inspection results which were discussed on April 23, 2015 with Mr. Ken Peters, Site Vice President and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspection reviewed compliance with the requirements specified in the Holtec International HI-STORM 100 Certificate of Compliance No. 1014 and the associated Technical Specifications, the HI-STORM 100 Final Safety Analysis Report (FSAR), and Title 10 of the Code of Federal Regulations (CFR) Part 72, Part 50, and Part 20. Within these areas, the inspection included a review of radiation safety, cask thermal monitoring, quality assurance (QA), your corrective action program, safety evaluations, observations of dry fuel loading activities, and changes made to your ISFSI program since the last routine ISFSI inspection that was conducted by the U.S.

Nuclear Regulatory Commission (NRC). The ISFSI facility was found to be in good physical condition. No violations of NRC regulations were identified.

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

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E LAMAR BLVD ARLINGTON, TX 76011-4511 Should you have any questions concerning this inspection, please contact the undersigned at 817-200-1191 or Mr. Lee Brookhart at 817-200-1549.

Sincerely,

/RA/

Ray L. Kellar, P.E., Chief Repository & Spent Fuel Safety Branch Division of Nuclear Materials Safety

Dockets: 50-445, 50-446, 72-74 Licenses: NPF-87, NPF-89

Enclosure:

Inspection Report 05000445/2015009; 05000446/2015009; 07200074/2015001

w/attachments:

1. Supplemental Information 2. Loaded Casks at Comanche Peak Nuclear Power Plant ISFSI

cc w/encl: Electronic Distribution

SUMMARY OF FINDINGS

IR 05000445/2015009, 05000446/2015009, and 07200074/2015001; 04/20-24/2015;

Comanche Peak Nuclear Power Plant Units 1, 2, and Independent Spent Fuel Storage Installation (ISFSI); Routine ISFSI Inspection Report

The report covers an announced inspection by one regional inspector and one inspector-in-training. The significance of any Part 50 findings are indicated by their color (Green, White,

Yellow, or Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process. The cross-cutting aspect is determined using IMC 0310, Components Within the Cross-Cutting Areas. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after the NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014. In accordance with the NRC Enforcement Policy, all of the Part 72 ISFSI inspection findings follow the traditional enforcement process and are not disposition through the Reactor Oversight Process or the Significance Determination Process.

NRC-Identified Findings and Self-Revealing Findings

No findings were identified.

Licensee-Identified Violations

None.

PLANT AND ISFSI STATUS

Comanche Peak Nuclear Power Plants (CPNPP) Independent Spent Fuel Storage Installation (ISFSI) stored 21 loaded Holtec HI-STORM 100 casks at the time of the routine inspection.

Comanche Peak was in the middle of a six cask loading campaign and were performing the loading operations associated with cask number 22 at the time of the routine inspection. The licensee utilized a general Part 72 license in accordance with the Holtec HI-STORM 100 System, approved under Certificate of Compliance 1014 License, Amendment 7 and Final Safety Analysis Report (FSAR), Revision 9. The version of the Holtec systems used at the CPNPP included the MPC-32, a 32 fuel bundle multi-purpose canister (MPC), and the HI-STORM 100S Version B overpack. The ISFSI pad was approximately 262 feet long by 102 feet wide and was designed to accommodate 84 storage casks. The storage casks were located outside the Part 50 facilities protected area within its own protected area.

REPORT DETAILS

4OA5 Other Activities

.1 Operations of an Independent Spent Fuel Storage Installation at Operating Plants

(60855.1)

a. Inspection Scope

(1) Quality Assurance (QA) Audits and Surveillances

An on-site review of the QA audit and QA surveillance reports related to dry cask storage activities at the CPNPP ISFSI was performed by NRC inspectors. Since the last NRC ISFSI inspection in September 2013, CPNPP had issued two Nuclear Oversight Evaluation Reports. The first report was issued as evaluation number EVAL-2013-008, Fuel Management During UFO2. This audit reviewed dry cask storage controls, dry cask storage operations, cross functional areas, and training related to the second dry fuel storage campaign conducted at CPNPP during 2013.

All of the areas evaluated were found to have been either effectively or adequately implemented by the auditing staff. Two minor issues were identified during the audit that resulted in condition reports (CRs) being placed into the CPNPP corrective actions program (CAP).

The second report was issued as evaluation number EVAL-2013-009, Core Performance Engineering and Fuel Management. Four of the audit reports 11 evaluated areas overlapped with the dry fuels program. The overlapping areas included: 1) special nuclear material accountability program during movement and transference and the inventory system; 2) fuel handling during outage and dry cask storage operations; 3) quality management system, including procedure and document effectiveness; and 4) software quality assurance. All four of the areas that included dry fuel storage were found to have been effectively implemented and managed. Several CRs and recommendations related to this audit were generated and placed into the sites CAP. However, no significant deficiencies were identified that related to dry cask storage operations at CPNPP.

NRC inspectors reviewed two QA surveillances documented by the Nuclear Oversight Office related to dry fuel storage activities. The first surveillance was performed on the lifting and rigging practices of contract personnel moving dry cask storage equipment inside the fuel building in the 2013 campaign and resulted in no findings. The second surveillance was performed on the rigging and maintenance activities associated with the preparation and movement of dry cask storage equipment for the 2015 campaign that resulted in two CRs being placed into the CAP. Both CRs issues were properly addressed by the licensee.

The NRC inspectors reviewed 19 vendor surveillances and their evaluations that were performed by the Holtec Users Groups QA inspector at the Holtec Manufacturing Division facility located in Turtle Creek, PA. There were four instances where unsatisfactory conditions were identified that impacted materials being manufactured for use in dry fuel storage at CPNPP. All four conditions were corrected as part of in process work prior to being accepted for use at CPNPP.

The QA audit reports, surveillances, and vendor surveillances resulted in several CRs. There were no significant CRs related to dry cask storage activities at CPNPP. NRC inspectors reviewed the corrective actions resulting from the CRs to ensure that the identified deficiencies were properly categorized based on their safety significance and properly resolved. All identified deficiencies had been properly categorized and resolved by the licensee.

(2) Radiological Conditions Related to Stored Casks

The CPNPP ISFSI was located approximately 0.6 miles east-southeast of the two unit reactor site. The ISFSI resides in its own protected area (PA), outside the reactors PA. The ISFSI pad is roughly 102 feet wide and 262 feet long with the capacity to hold 84 HI-STORM 100S spent fuel storage casks configured in a 6 by 14 array. The ISFSI outer fence was properly posted as a Radiological Controlled Area/Radioactive Materials Area. No flammable or combustible materials, debris, or vegetative growth were observed on or in close proximity to the ISFSI pad. Twenty-one casks were loaded with spent fuel at the time of the inspection. The current ISFSI loading campaign planned to add three additional casks to the pad this year, bringing the total to 24. The NRC inspector found all 21 casks to be in excellent physical condition with no visible signs of degradation.

Inspectors reviewed the radiological conditions at the CPNPP ISFSI through documentation of the most recent radiological survey and three years of thermoluminescent dosimeter (TLD) monitoring data from around the ISFSI. There were TLD monitoring locations, roughly centered, on all four sides of the ISFSI outer fence.

A dry cask loading supervisor and two radiation protection (RP) technicians accompanied the NRC inspector during a walk-down of the ISFSI pad. A radiological survey was performed by one RP technician with a telescoping Geiger-Mueller detector to record gamma exposure rates in milliroentgens per hour (mR1/h). The RP technician also carried a small portable instrument that measured gamma exposures in microroentgens per hour (µR/h). The NRC inspector verified that both instruments were properly calibrated under the licensees program.

Survey measurements were taken around the ISFSI outer fence, around the perimeter of the ISFSI pad, at selected areas between casks, and at TLD monitoring locations.

General area gamma background readings outside of the radiation controlled area (RCA) prior to entry were 6 µR/h. Upon arrival at the ISFSI site entry location at its west fence, ambient radiation levels rose to near 20 µR/h. The 21 storage casks were situated along the northern edge and northeast corner of the ISFSI pad.

Radiation readings taken along the fence-line showed levels ranging from 21 µR/h, at locations distant from the spent fuel casks, to 94 µR/h on the east fence-line closer to the storage casks. General area measurements on the pad ranged from 260 µR/h, at the radiation area boundary rope, to 2.2 mR/h, between casks. Based on the exposure rate measurements and radiological postings displayed inside and outside of the ISFSI outer fence, all postings met the requirements of 10 CFR Parts 20.1902(a) and 20.1902(e). The measurements taken by the RP technician and witnessed by the NRC inspector confirmed the measurements recorded on the most recent ISFSI site survey. The radiological conditions in and around the ISFSI were as expected for the age and heat-load of the 21 currently loaded spent fuel storage casks.

The licensee provided personnel dose information associated with the 11 casks loaded during the previous and current ISFSI loading campaigns of 2013 and 2015.

The results of the worker accumulated dose per cask could be tracked to the functional group that the dose was assigned to. The cask loading contractor accrued the majority of the dose, ranging from 81 - 90% of the dose for the current campaign. The loading of the most recent 11 casks presented occupational exposures that ranged from 0.114 to 0.195 person-rem per cask (see Attachment 2 of this report), averaging 0.146 person-rem. This value was below the average seen on the first loading campaign of 0.182 person-rem per cask. CPNPPs RP group has continued to implement improved practices to lower personnel dose and keep dose As Low as Reasonably Achievable (ALARA).

(3) Environmental Radiological Monitoring Program

The primary purpose of the CPNPP Radiological Environmental Monitoring Program (REMP) was to evaluate the radiological impacts that reactor operations and stored radioactive materials have on the local environment. The REMP focused on measuring airborne (gaseous and particulate), liquid effluent, and direct radiation levels at or near the site boundary and at selected offsite locations. By design, there were no airborne or liquid effluents released from CPNPP ISFSI. However, the ISFSI was responsible for measurable direct radiation levels produced on-site.

1 For the purposes of making comparisons between NRC regulations based on dose-equivalent and measurements made in Roentgens, it may be assumed that one Roentgen equals one rem. (http://www.nrc.gov/about-nrc/radiation/protects-you/hppos/qa96.html)

The REMP monitored direct radiation impacts locally and offsite using TLDs. The ISFSI site was also monitored using TLDs. The monitoring data for the ISFSI and the REMP were handled by two different site programs for different purposes. The ISFSI-specific TLD monitoring was performed by the General Area Monitoring Program (GAM) to track radiological exposures at the ISFSI boundary and to ensure that NRC occupational limits for unmonitored individuals were not exceeded.

TLDs were placed at four monitoring locations on the ISFSI outer fence, where they could be easily accessed outside of the ISFSI boundary. The monitoring results from 2012, 2013, and 2014 for those locations were reviewed by NRC inspectors.

The TLDs were collected and replaced quarterly. That data has been compiled into a yearly format, displayed in a milliroentgens per year (mR/yr) in Table 1, below.

Table 1 TLD Monitoring Results for CPNPP ISFSI in mR/yr2 TLD #

Location 2012 2013 2014 101 North Fence 210 438 832 102 East Fence 311 639 780 103 South Fence 418 181 353 104 West Fence 331

The NRC Inspector verified the radiation exposure rates at each TLD monitoring location during the ISFSI walk-down. The highest reported and measured dose rate was recorded at the ISFSI north fence monitoring location, 832 mR/yr. Applying an occupational occupancy factor of 2.3 X 10-1 (2000 work hours per year onsite divided by 8760 total hours in a year) to that dose resulted in an occupational value of approximately 190 mrem per year. As a result, all accessible areas of the ISFSI fall below the 10 CFR 20.1502(a)(1) limit for unmonitored individuals, which is 500 mrem per year.

The REMP monitoring was performed to provide an annual assessment of CPNPPs total impacts to the local environment. Those impacts included the direct radiation contributions of the ISFSI. The yearly results of the REMP were issued in the CPNPP Annual Radiological Environmental Operating Report (AREOR). The NRC inspectors reviewed the CPNPP AREORs for 2013 (ML14127A068), issued April 24, 2014 and 2014 (ML15133A101), issued April 30, 2015.

The ISFSI was located approximately 0.6 miles from the center of the Units-1 and -2 reactor buildings in the in the east-southeast REMP monitoring sector. Only one of the 43 total REMP TLD monitoring sites was located at a site boundary location in reasonably close proximity to the ISFSI: monitoring site R-11, located 0.5 miles from the reactor site in the east sector.

2 The data compiled for this table was from sources where monitoring periods overlapped. As such certain monitoring periods may be slightly higher or lower than represented here. The relative differences between monitoring locations, however, are valid.

Table 2, REMP Monitoring Results near CPNPP ISFSI in mR/yr TLD#

Station and Location 2013 2014 R-11 East Sector, 0.5 miles from reactor

Control Locations Various

Average background (control) dose measurements for both 2013 and 2014 were 49 mR/yr. Correcting for background, between the control locations and R-11, shows only a slight increase in ambient radioactivity at monitoring location R-11 of 1 mrem/yr each year. This value was well below the 10 CFR 72.104

(a) dose standard, which limits total radiation from the ISFSI to less than 25 mrem per year above background at the owner controlled boundary. Offsite doses due to the radiological influence of the ISFSI were well below regulatory limits.

(4) Records Related to Fuel Stored in the Casks

NRC inspectors reviewed the records for one randomly selected previously loaded dry fuel storage cask at CPNPP to assess data retrievability of ISFSI records. In addition, NRC performed a review of the dry fuel storage records for six casks loaded at the ISFSI, since the last NRC ISFSI inspection, to determine whether adequate descriptions of the spent fuel was documented as a permanent record as required by 10 CFR 72.212(b)(12). The spent fuel contents of the six most recently loaded HI-STORM casks (prior to the current loading campaign) were recorded in two documents, Cask Acceptability Report and Comprehensive Assembly Specifications Supplement, NUC-212-3, Rev. 0 and NUC-212-4, Rev. 4, respectively. These documents contained MPC loading maps and fuel assembly specific information such as qualification data, identification, decay heat (kW),cooling time (years), average U-235 enrichment (%), burn-up values (MWd/MTU),and other information. A complete set of forms was reviewed for seven of the 21 casks loaded at CPNPP. Some of that fuel data is tracked along with other information on Attachment 2 of this inspection report. The licensee was in compliance with all applicable Technical Specifications and FSAR requirements for spent fuel stored at their ISFSI and all regulatory requirements for retrievability of cask records.

(5) Technical Specification A.3.1.2, Cask Temperature Monitoring

Technical Specification (TS) A.3.1.2 required either a daily inspection of the inlet and outlet vents for blockage or daily verification that the temperature difference between the HI-STORM outlet temperature and ISFSI ambient temperature was 155 degrees F for all casks loaded under Certificate of Compliance 1014, Amendment 7. The licensee performed either vent inspections or temperature surveillances daily and the data was recorded daily on form OPT-102A-1, Rev. 37.

NRC inspectors reviewed documentation for the (randomly selected) months of November 2013 and June of 2014. Of the months selected for review, the licensee typically met the technical specification requirement by the daily review of temperature monitoring data, with only one instance where the licensee performed vent inspections on a single cask. The worksheet associated with that cask noted that the vents were visually verified to be clear of any blockages.

No issues were identified with CPNPP compliance to the TS A.3.1.2 surveillance requirement for temperature monitoring.

(6) Corrective Action Program

A list of CRs issued since the last NRC inspection conducted in September 2013, was provided by the licensee for the cask handling crane and the ISFSI operations.

Issues were processed in accordance with Procedure STA-422, Processing Condition Reports, Revision 32. When a problem was identified the licensee would document the issue as a CR in the licensees corrective action program.

Of the list of CRs provided relating to the ISFSI and the cask handling cranes, 30 documents were selected by the NRC inspectors for further review. The CRs were related to a variety of issues. The CRs reviewed were well documented and properly categorized based on the safety significance of the issue. The corrective actions taken were appropriate for the situations. Based on the level of detail of the corrective action reports, the licensee demonstrated a high attention to detail in regard to the maintenance and operation of their ISFSI program and the cask handling crane. No NRC safety concerns were identified related to the CRs reviewed.

(7) Preparation of Loading Activities

The inspectors requested documentation related to maintenance of the fuel building cask handling crane, the annual maintenance of the licensees special lifting devices, and the calibration of various gauges associated with the loading activities.

Documents were provided that demonstrated the fuel building cask handling crane was inspected on an annual basis in accordance with the requirements of the American Society of Mechanical Engineers (ASME) B30.2 prior to the 2015 loading campaign. CPNPP utilized Work Order (WO) 4772141, dated January 15, 2015, to perform the annual maintenance on January 6, 2015.

The annual maintenance as required by American National Standards Institute (ANSI) N14.6 for special lifting devices was completed for the following special lifting devices: the HI-TRAC lifting trunnions, lift yoke, lift yoke extension, and the HI-STORM lifting brackets. Documentation reviewed included WO 4877704, WO 4877724, and WO 4878574. All equipment passed the visual inspection, the dimensional testing, and either the magnetic particle or liquid penetrant non-destructive examination (NDE).

Calibration documentation of the hydrostatic pressure gages and the forced helium dehydration drying system gages were reviewed to ensure the equipment had been properly calibrated prior to the loading operations. All calibration certificates reviewed through WO 4877661 demonstrated that the gages were properly calibrated prior to the loading campaign.

(8) HI-STORM and ISFSI Yearly Maintenance

Final Safety Analysis Report (FSAR), Section 9.2, Maintenance Program, specified the HI-STORM maintenance schedule in Table 9.2.1. Among other tasks, the schedule required an annual visual inspection of the storage casks external surfaces and identification markings for signs of damage or degradation. NRC inspectors reviewed the documentation related to the annual visual examination of Comanche Peaks HI-STORM casks for 2014. Those documents included work order #4757002 and included filled out copies of Dry Cask Storage Procedure DCS-110, HI-STORM In-service Annual Inspection and Maintenance, Rev. 3. In 2014, 14 out of 18 HI-STORM over-packs required the vent screens to be removed and replaced to facilitate painting to address rust stains leaching from open threaded holes in the HI-STORM vent openings. The NRC inspectors determined that the licensees yearly maintenance activities and records met the requirements of the Holtec FSAR. The casks were also visually inspected as part of the NRC ISFSI pad walk-down. All casks appeared to be in good physical condition.

(9) Cask Loading Observations

Various loading activities were observed by the NRC inspectors during the course of the routine ISFSI inspection. CPNPP was in the process of transporting the already loaded canister #21 to the ISFSI pad on Monday April 20, 2015. Inspectors observed the vertical cask transporter (VCT) transport the cask to the ISFSI pad.

Additionally, personnel in the fuel handling building were preparing to load fuel assemblies into canister #22 on that Monday. NRC inspectors observed the loading and other associated activities with canister #22 throughout the remaining work week. The NRC inspectors observed the fuel movement activities to place spent fuel assemblies into canister. The licensees staff was experienced in moving the spent fuel assemblies and was proficient in locating the correct assembly, verifying the assembly, moving the assembly from the rack to the canister, and inserting the assembly into the assigned canister slot.

Selected welding and non-destructive examination activities were observed during the loading activities associated with canister #22. An automated welding process was used to weld the canister lid. The automated welding machine used one weld head to weld the lid to shell weld utilizing a Gas Tungsten Arc Welding process.

The welders operated the equipment remotely in a low dose rate area. Hydrogen monitoring was performed during the welding of the root weld and additional passes until the lid to shell weld was completed. NRC inspectors observed the non-destructive dye penetrant exams conducted on the lid-to-shell weld, the welds on the vent and drain port covers, and the closure lid weld. The NDE examinations did not identify any welding defects.

Other activities that were observed by NRC inspectors during the loading of canister

1. 22 included the draining of the MPC, drying of the MPC using forced helium dehydration, lifting the transfer cask and fully loaded MPC out of the cask loading pit, and downloading of the MPC into the HI-STORM storage cask. The licensees cask handling crane was able to handle the heavy load without any observed problems.

b. Findings

No findings were identified.

.2 Review of 10 CFR 72.212(b) Evaluations at Operating Plants (60856.1)

a. Inspection Scope

The 10 CFR 72.212 Evaluation Report was reviewed to verify site characteristics were still bounded by the Holtec HI-STORM 100 cask systems design basis.

Comanche Peaks 10 CFR 72.212 Evaluation Report at the time of the inspection was Revision 8, dated April 16, 2015. Three revisions had been performed to the 72.212 Evaluation Report since the last NRC routine ISFSI inspection and were reviewed during this inspection. The associated 10 CFR 72.48 screening for each revision were reviewed.

All screenings were determined to be adequate and changes to the 72.212 report were found to be still bounded by the Holtec design basis.

b. Findings

No findings were identified.

.3 Review of 10 CFR 72.48 Evaluations

a. Inspection Scope

The licensees 10 CFR 72.48 screenings and evaluations for ISFSI program changes since the last NRC routine ISFSI inspection were reviewed to determine compliance with regulatory requirements. CPNPP had performed thirteen 72.48 screens associated with changes to ISFSI equipment or operations. The licensee had performed one 72.48 full safety evaluations for the ISFSI since the last NRC inspection in September of 2013.

This evaluation was performed to address a calculation error on a previous 72.48 evaluation for the use of the wheeled VCT that was used at CPNPP. The results of the site-specific fire accident showed that the MPC confinement boundary remained intact and the potential loss of shielding due to fire damage to the overpack remained small.

The fuel cladding and MPC confinement boundary continued to meet the existing numerical design basis limits for performance as described in the Holtec FSAR.

Inspectors reviewed the thirteen 72.48 screens provided by the licensee. The licensee utilized Procedure STA-707, 10 CFR 50.59 and 72.48 Reviews, Revision 20 to perform the 10 CFR 72.48 safety screenings. None of the screenings reviewed required a full 10 CFR 72.48 safety evaluation. All screenings were determined to be adequately evaluated.

The NRC inspectors determined that the licensee had made no 10 CFR 50.59 screenings or evaluations associated with the fuel building cask handling crane since the last inspection.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On April 23, 2015, the inspectors presented the inspection results to Mr. Ken Peters, Site Vice President, and other members of the licensee staff. The licensee acknowledged the inspection details presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT

Licensee Personnel

B. Henley, Project Manager T. Hope, Manager of Regulatory Affairs J. Hull, Refueling Work Window Manager D. Keating, Ops Procedures C. Lemons, Engineering T. McCool, Engineering K. Peters, Site Vice President M. Ragan, Outage Management J. Seawright, Regulatory Affairs

INSPECTION PROCEDURES USED

IP 60855.1

Operations of an ISFSI at Operating Plants IP 60856.1 Review of 10 CFR 72.212(b) Evaluations at Operating Plants IP 60857

Review of 10 CFR 72.48 Evaluations

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Discussed

None

Closed

None LIST OF

DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does

not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that

selected sections of portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

4OA5.1 Other Activities

Drawings

NUMBER

TITLE

DATE

15-04-0127

Survey - Dry Cask Storage Pad

4/06/2015

15-04-0446

Survey - Dry Cask Storage Pad

4/20/2015

Procedures

NUMBER

TITLE

REVISION

DCS-100

Dry Fuel Storage Campaign Guidelines

Revision 5

DCS-110

HI-STORM Annual Inspection and Maintenance

Revision 3

DCS-201

Transporting Loaded and Unloaded HI-STORM

Revision 6

DCS-202

MPC Preparing for Loading

Revision 3

DCS-203

MPC Handling and Fuel Loading Operations

Revision 6

DCS-204

MPC Closure Operations

Revision 6

DCS-205

Stack-up and Transfer of Loaded MPC

Revision 7

DCS-301

Dry Cask Storage Equipment Malfunction, Loop,

LOCA, and Contingencies guidance

Revision 6

HSP-504

Procedure to Perform Closure Welds on MPC and

MPC Lid

Revision 24

HSP-506

Liquid Penetrant Examination For MPC Welding

Revision 10

HSP-507

Visual Weld Examination for MPC Field Welding

Revision 6

OPT-102A

Mode 1 and 2 Shiftly Surveillances (60 days worth)

Revision 37

STA-422

Processing Condition Reports

Revision 32

STA-707

CFR 50.59 and 72.48 Reviews

Revision 20

Design Basis Documents

NUMBER

TITLE

REVISION

CFR 72.212 Evaluation Report Docket # 72-74

Revision 8

Certificate of Compliance 72-1014 HI-STORM 100

Cask System

Amendment 7

Holtec International Final Safety Analysis Report for

the HI-STORM 100 Cask System

Revision 9

- 2 -

Miscellaneous Documents

NUMBER

TITLE

REVISION / DATE

Multiple

Resident Vendor Surveillance Trip Plan/Report (19)

Multiple

Multiple

Evaluation of HMD Surveillance Reports (14)

Multiple

SURV-2015-0066

Conduct of Maintenance; INPO 12-013 QAS

03/17/2015

SURV-2015-0057

Conduct of Maintenance; INPO 12-013 QAS

03/05/2015

EVAL-2013-008

Fuel Management During UFO2

11/16/2013

EVAL-2013-009

Core Performance Engineering and Fuel Mgmt

2/06/2014

GAM Report for 2011-2012

04/26/2015

GAM Report for 2012-2013

10/03/13

GAM Report for 2013-2014

08/28/14

GAM Report for 2014

05/05/15

RPI-710-2

2013 Annual Radiological Environmental Operating

Report

04/06/2014

RPI-710-2

2014 Annual Radiological Environmental Operating

Report

04/15/2015

UFO3 Does Trend Chart

NUC-212-3

Cask Acceptability Report - Cask 7

Rev. 0

NUC-212-3

Cask Acceptability Report - Cask 13

Rev. 0

NUC-212-3

Cask Acceptability Report - Cask 14

Rev. 0

NUC-212-3

Cask Acceptability Report - Cask 15

Rev. 0

NUC-212-3

Cask Acceptability Report - Cask 16

Rev. 0

NUC-212-3

Cask Acceptability Report - Cask 17

Rev. 0

NUC-212-3

Cask Acceptability Report - Cask 18

Rev. 0

NUC-212-4

Comprehensive Assembly Specification Supplement

For Cask 7

Rev. 3

NUC-212-4

Cask Acceptability Report, attachment for Cask 13

Rev. 4

NUC-212-4

Cask Acceptability Report, attachment for Cask 14

Rev. 4

NUC-212-4

Cask Acceptability Report, attachment for Cask 15

Rev. 4

NUC-212-4

Cask Acceptability Report, attachment for Cask 16

Rev. 4

NUC-212-4

Cask Acceptability Report, attachment for Cask 17

Rev. 4

NUC-212-4

Cask Acceptability Report, attachment for Cask 18

Rev. 4

2.48 Screenings and 72.48 Evaluations

FDA-2009-000859-02-02

FDA-2009-000859-29-01

FDA-2009-000859-13-07

FDA-2009-000859-38-01

FDA-2009-000859-39-00

FDA-2009-000859-40-00

FDA-2009-000859-41-00

FDA-2009-000859-42-00

FDA-2009-000859-43-00

FDA-2009-000859-44-01

FDA-2009-000859-45-00

FDA-2009-000859-46-00

FDA-2009-000859-47-00

EV-CR-2013-009020-2

EV-CR-2014-005590-2

Work Orders

WO 4877661

WO 4878574

WO 4877724

WO 4877704

WO 4757002

- 3 -

CRs

CR-2013-002706

CR-2013-009512

CR-2013-009593

CR-2013-009651

CR-2013-009670

CR-2013-009733

CR-2013-010033

CR-2013-010165

CR-2013-010181

CR-2013-010623

CR-2013-010859

CR-2013-011604

CR-2013-011638

CR-2014-000974

CR-2014-002549

CR-2014-004570

CR-2014-005583

CR-2014-007671

CR-2014-010189

CR-2014-000974

CR-2014-006381

CR-2014-006535

CR-2015-000246

CR-2013-009276

CR-2013-009364

CR-2013-009418

CR-2013-009666

CR-2013-010054

CR-2013-010722

CR-2014-000970

CR-2014-000971

LIST OF ACRONYMS

ADAMS

Agencywide Documents Access and Management System

AREOR

Annual Radiological Environmental Operating Report

ASME

American Society of Mechanical Engineers

CAP

Corrective Action Program

CFR

Code of Federal Regulations

CPNPP

Comanche Peak Nuclear Power Plant

CR

Condition Report

DNMS

Division of Nuclear Material Safety

F

Fahrenheit

FSAR

Final Safety Analysis Report

GAM

General Area Monitoring

IMC

Inspection Manual Chapter

IP

inspection procedure

ISFSI

Independent Spent Fuel Storage Installation

kW

killo-watt

mR

milliRoentgen

micro(µ)R/h

microRoentgen per hour

MPC

multipurpose canister

mrem

milliRoentgen equivalent man

MWD/MTU

megawatt days/metric ton uranium

NDE

non-destructive examination

NRC

U.S. Nuclear Regulatory Commission

PA

Protected Area

QA

quality assurance

RCA

Radiological Controlled Area

REMP

Radiological Environmental Monitoring Program

RP

radiation protection

TLD

thermoluminescent dosimeter

TS

Technical Specification

VCT

Vertical Cask Transporter

WO

work order

ATTACHMENT 2:

LOADED CASKS AT THE COMANCHE PEAK NUCLEAR POWER PLANT ISFSI

LOADING

ORDER

MPC

SERIAL No.

HI-STORM

No.

DATE

ON PAD

HEAT LOAD

(Kw)

BURNUP

MWd/MTU (max)

MAXIMUM FUEL

ENRICHMENT %

PERSON-REM

DOSE

MPC-156

Serial No.

465

2/28/12

17.813

2,278

4.50

0.332

MPC-158

Serial No.

467

03/12/12

24.842

49,268

4.82

0.359

MPC-157

Serial No.

553

04/02/12

25.031

49,518

4.82

0.315

MPC-202

Serial No.

550

04/09/12

25.133

49,561

4.82

0.195

MPC-199

Serial No.

549

04/14/12

25.216

49,509

4.82

0.230

MPC-196

Serial No.

557

05/07/12

25.470

49,750

4.82

0.116

MPC-195

Serial No.

556

05/14/12

25.378

49,961

4.82

0.120

MPC-200

Serial No.

551

05/21/12

27.203

49,584

4.82

0.098

MPC-198

Serial No.

2

06/18/12

27.657

49,888

4.80

0.549

MPC-197

Serial No.

29

9/04/13

2.283

49,949

4.74

0.191

MPC-307

Serial No.

730

9/16/13

2.225

49,814

4.82

0.110

MPC-289

Serial No.

731

9/23/13

2.949

49,691

4.82

0.135

MPC-304

Serial No.

2

10/07/13

27.534

49,216

4.82

0.170

MPC-291

Serial No.

733

10/12/13

27.883

49,173

4.80

0.195

- 2 -

LOADING

ORDER

MPC

SERIAL No.

HI-STORM

No.

DATE

ON PAD

HEAT LOAD

(Kw)

BURNUP

MWd/MTU (max)

MAXIMUM FUEL

ENRICHMENT %

PERSON-REM

DOSE

MPC-308

Serial No.

734

10/29/13

27.805

49,964

4.9

0.131

MPC-309

Serial No.

554

11/04/13

27.939

49,921

4.9

0.135

MPC-194

Serial No.

555

11/11/13

27.512

48,909

4.9

0.126

MPC-201

Serial No.

466

11/16/13

27.997

49,430

4.9

0.128

MPC-306

Serial No.

758

4/16/15

23.572

49,848

4.9

0.114

MPC-292

Serial No.

757

4/14/15

24.259

49,037

4.95

0.116

MPC-288

Serial No.

754

4/20/15

28.313

49,428

4.82

0.170

MPC-293

Serial No.

755

5/05/15

27.836

49,246

4.82

0.182

NOTES:

Heat load (kW) is the sum of the heat load values for all spent fuel assemblies in the cask

Burn-up is the value for the spent fuel assembly with the highest individual discharge burn-up

Fuel enrichment is the spent fuel assembly with the highest individual initial enrichment percent of U-235

All casks were loaded and are currently maintained under Certificate of Compliance 1014, License Amendment 7 and the Final Safety Analysis

Report, Revision 9