ENOC-10-00034, Entergy Operations, Inc., and Entergy Nuclear Operations, Inc., Follow-up Action to NRC Enforcement Discretion Letter EA-09-190, Holtec Elimination of Multi-Purpose Canister (MPC) Shop Helium Leak Rate Test

Entergy Operations, Inc., and Entergy Nuclear Operations, Inc., Follow-up Action to NRC Enforcement Discretion Letter EA-09-190, Holtec Elimination of Multi-Purpose Canister (MPC) Shop Helium Leak Rate Test

ML103090653
Person / Time
Site:	Indian Point, Grand Gulf, Arkansas Nuclear, River Bend, Vermont Yankee, FitzPatrick
Issue date:	11/02/2010
From:	Mccann J Entergy Nuclear Operations, Entergy Operations
To:	NRC/FSME, Office of Nuclear Reactor Regulation
References
EA-09-190, ENOC-10-00034
Download: ML103090653 (21)

Text

Entergy Entergy Operations, Inc Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Tel 914 272 3370 John F. McCann Vice President - Nuclear Safety, Emergency Planning and Licensing ENOC-10-00034 November 2, 2010 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Follow-up Action to NRC Enforcement Discretion Letter EA-09-190, Holtec Elimination of Multi-Purpose Canister (MPC) Shop Helium Leak Rate Test Arkansas Nuclear One Units 1 & 2 Docket Nos. 50-313, 50-368, & 72-13 License Nos. DPR-51 & NPF-6 Indian Point Nuclear Generating Units Units 1, 2, & 3 Docket Nos.50-003, 50-247, 50-286 & 72-51 License Nos. DPR-5, DPR-26, & DPR-64 River Bend Station Docket No. 50-458 & 72-49 License No. NPF-47 Grand Gulf Nuclear Station Docket No. 50-416 & 72-50 License No. NPF-29 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 & 72-12 License No. DPR-59 Vermont Yankee Nuclear Power Station Docket No. 50-271 & 72-59 License No. DPR-28

References:

1) NRC Letter to Holtec, "Exercise of Enforcement Discretion - Holtec International, EA-09-190," dated August 6, 2009

2) Holtec Letter to NRC, "Reply to EA-09-190," dated September 2, 2009

3) NRC Letter to Holtec, "Response to Holtec International (Holtec) Reply to EA-09-190," dated January 12, 2010.

Dear Sir or Madam:

The Nuclear Regulatory Commission (NRC) notified Holtec international (Holtec) regarding a violation of NRC requirements by letter dated August 6, 2009 (Reference 1). Specifically, Holtec eliminated shop helium leak testing of the multi-purpose canister (MPC) during fabrication without prior NRC approval. By letter dated September 2, 2009 (Reference 2),

tj f

ENOC-10-00034 Page 2 Holtec provided a response to the violation which included analysis that supports continued use of loaded MPCs that were not tested during fabrication.

Spent fuel storage activities are conducted at nuclear facilities operated by Entergy Operations, Inc. and Entergy Nuclear Operations, Inc. (Entergy) using the Holtec International HI STORM 100 Cask System. Entergy currently has loaded MPCs at independent spent fuel storage installations (ISFSIs) that were not helium leak tested.

Specifically, Arkansas Nuclear One (ANO), Grand Gulf Nuclear Station (GGNS), Indian Point (IPEC), James A. FitzPatrick (JAF), River Bend Station (RBS), and Vermont Yankee (VY) are the general licensees for the ISFSls at each of these facilities.

A teleconference was held on December 1, 2009, with NRC, Holtec, and the affected licensees. The NRC requested that general licensees with MPCs that were not helium leak tested during fabrication provide information related to their site-specific determinations that the MPCs could remain in service. Accordingly, the requested information is provided in Attachments 1 through,6 for each Entergy facility.

There are no new commitments contained in this submittal.

If you have any questions concerning this submittal, please contact me.

Sincerely, JFM/slp Attachments:

1.

NRC Requested Information for Arkansas Nuclear One

2.

NRC Requested Information for Grand Gulf Nuclear Station

3.

NRC Requested Information for Indian Point, Unit Nos. 1, 2, and 3

4.

NRC Requested Information for James A. FitzPatrick

5.

NRC Requested Information for River Bend Station

.6.

NRC Requested Information for Vermont Yankee

ENOC-10-00034 Page 3 cc:

Mr. William Dean Regional Administrator U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 NRC Senior Resident Inspector Arkansas Nuclear One P. 0. Box 310 London, AR 72847 NRC Senior Resident Inspector Indian Point Energy Center 450 Broadway P. 0. Box 249 Buchanan, NY 10511-0249 NRC Senior Resident Inspector River Bend Station PO Box 1050 St. Francisville, LA 70775 Mr. John Boska Project Manager NRC NRR DORL Mr. Bhalchandra Vaidya Project Manager NRC NRR DORL Mr. Elmo Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 NRC Senior Resident Inspector James A. FitzPatrick Nuclear Power Plant PO Box 136 Lycoming, NY 13693 NRC Senior Resident Inspector Vermont Yankee Entergy Nuclear Vermont Yankee, LLC PO Box 157 Vernon, Vermont 05354 Mr. James Kim Project Manager NRC NRR DORL Mr. Kaly Kalyanam Project Manager NRC NRR DORL Mr. Alan Wang Project Manager NRC NRR DORL ENOC-10-00034 NRC Requested Information for:

Arkansas Nuclear One, Units 1 and 2 to ENOC-10-00034 PAge 1 of 2 A teleconference was held by the NRC with Holtec and general licensees with loaded MPCs that were not subjected to helium leak testing during fabrication for the purpose of discussing continued use of the affected MPCs. The following list, taken from the NRC Conversation Record (ML0935100008), identifies the information requested by the NRC. The requested information for Arkansas Nuclear One (ANO), Units 1 and 2, is provided immediately following the NRC requested information below:

1. NRC Request:

Information that the thermal heat load for the spent fuel and internal helium conditions that had been loaded into the MPCs was bounded by the thermal and over pressure helium analyses provided by Holtec in their corrective action response to the NRC Enforcement Discretion letter dated August 6, 2009; for MPCs loaded above 21 kilowatts (kW) the NRC requested that the site. provide information regarding the length of time that would elapse before the spent fuel heat load would dec~ay below 21 kW.

ANO Response:

ANO currently has seven MPCs loaded with spent fuel in the independent spent fuel storage installation (ISFSI) that were not helium leak tested during fabrication. These casks were loaded in accordance with the requirements of Certificate of Compliance (CoC) 1014, Amendments 2 and 5. Of the seven MPC's, two MPC's have been loaded with a heat load above 21 kw. The maximum heat load for these MPCs is 27.637 kW. Accordingly, these casks are bounded by the thermal and overpressure helium analyses provided by Holtec letter to the NRC dated September 2, 2009. The heat load for these casks is projected to be less than 21 kW by December 1, 2015.

2. NRC Request:

Information that the site radiological monitoring programs had not detected any adverse effluent conditions associated with the use of the MPCs, and that all measured site radiological parameters were within the limits provided in 10 CFR 72.104.

ANO Response:

Entergy has reviewed the results of the Annual Radiological Environmental Operating Reports since the beginning of Holtec ISFSI storage operations in 2003. The results of this review determined that there is no discernable increase in dose to the public as the result of storage of casks that were not helium leak tested. Results contained in the Annual

• Radiological Environmental Operating Report for this period were within the limits specified in 10 CFR 72.104. Based on the use of stringent and consistent fabrication requirements, leakage from these casks is not considered credible. Accordingly, these casks are bounded by the existing analysis for compliance with 10 CFR 72.104.

to ENOC-10-00034 Page 2 of 2

3. NRC Request:

Information that the sites dispositioned the deficiency through their non-conforming and corrective action process and determined that continued use of the MPCs was found to be acceptable.

ANO Response:

Condition Reports CR-ANO-C-2009-00307 and CR-ANO-C-2009-01531 were initiated for the Holtec failure to perform the required helium leak test during fabrication. A prompt-determination of operability was prepared and a determination made that the affected MPCs would perform their intended safety function. This determination was based on an operability review.

ENOC-1 0-00034 NRC Requested Information for:

Grand Gulf Nuclear Station to ENOC-10-00034 Page 1 of 2 A teleconference was held by the NRC with Holtec and general licensees with loaded MPCs that were not subjected to helium leak testing during fabrication for the purpose of discussing continued use of the affected MPCs. The following list, taken from the NRC Conversation Record (ML0935100008), identifies the information requested by the NRC. The requested information for Grand Gulf Nuclear Station (GGNS) is provided immediately following the NRC requested information below:

1. NRC Request:

Information that the thermal heat load for the spent fuel and internal helium conditions that had been loaded into the MPCs was bounded by the thermal and over pressure helium analyses provided by Holtec in their corrective action response to the NRC Enforcement. Discretion letter dated August 6, 2009; for MPCs loaded above 21 kilowatts (kW) the NRC requested that the site provide information regarding the length of time that would elapse before the spent fuel heat load would decay below 21 kW.

GGNS Response:

GGNS currently has seven MPCs loaded with spent fuel in the independent spent fuel storage installation (ISFSI) that were not helium leak tested during fabrication.

These casks were loaded in accordance with the requirements of CoC 1014, Amendment 2. The maximum heat load for these MPCs is 21.8197 kW.

Accordingly, these casks are bounded by the thermal and overpressure helium analyses provided by Holtec letter to the NRC dated September 2, 2009. The heat load for these casks was below the 21 kW heat load on June 18, 2008.

2. NRC Request:

Information that the site radiological monitoring programs had not detected any adverse effluent conditions associated with the use of the MPCs, and that all measured site radiological parameters were within the limits provided in 10 CFR 72.104.

GGNS Response:

GGNS has reviewed the results of the Annual Radiological Environmental Operating Reports since the beginning of ISFSI storage operations in 2006. The results of this review determined that there is no discernable increase in dose to the public as the result of storage of casks that were not helium leak tested. Results contained in the Annual Radiological Environmental Operating Report for this period were within the limits specified in 10 CFR 72.104. Based on the use of stringent and consistent fabrication requirements, leakage from these casks is not considered credible.

Accordingly, these casks are bounded by the existing analysis for compliance with 10 CFR 72.104.

to ENOC-10-00034 Page 2 of 2

3. NRC Request:

Information that the sites dispositioned the deficiency through their non-conforming and corrective action process and determined that continued use of the MPCs was found to be acceptable.

GGNS Response:

Condition Report CR-GGN-2009-03928 was initiated for the Holtec failure to perform the required helium leak test during fabrication. A prompt determination of operability was prepared and a determination made that the affected MPCs would perform their intended safety function. This determination was based on an operability review.

ENOC-1 0-00034 NRC Requested Information for:

Indian Point, Unit Nos. 1, 2, and 3 to ENOC-10-00034 Page 1 of 2 A teleconference was held by the NRC with Holtec and general licensees with loaded multi-purpose canisters (MPCs) that were not subjected to helium leak testing during fabrication for the purpose of discussing continued use of the affected MPCs. The following list, taken from the NRC Conversation Record (ML0935100008), identifies the information requested by the NRC. The requested information for Indian Point (IPEC) is provided immediately following the NRC requested information below:

1. NRC Request:

Information that the thermal heat load for the spent fuel and internal helium conditions that had been loaded into the MPCs was bounded by the thermal and over pressure helium analyses provided by Holtec in their corrective action response to the NRC Enforcement Discretion letter dated August 6, 2009; for MPCs loaded above 21 kilowatts (kW) the NRC requested that the site provide information regarding the length of time that would elapse before the spent fuel heat load would decay-below 21 kW.

IPEC Response:

IPEC currently has eight (five Unit 1 and three Unit 2) MPCs loaded with spent fuel in the independent spent fuel storage installation (ISFSI) that were not helium leak tested 'during fabrication. These casks were loaded in accordance with the requirements of Certificate of Compliance (CoC) 1014, Amendments 2 and 4. The maximum heat load for these MPCs is 14.839 kW. Accordingly, these casks are bounded by the thermal and overpressure helium analyses provided by Holtec letter to the NRC dated September 2, 2009.

2. NRC Request:

Information that the site radiological monitoring programs had not detected any adverse effluent conditions associated with the use of the MPCs, and that all measured site radiological parameters were within the limits provided in 10 CFR 72.104.

IPEC Response:

Entergy has reviewed the results of the Annual Effluent and Waste Disposal Reports since the beginning of ISFSI storage operations in 2007. The results of this review determined that there is no discernible increase in dose to the public as the result of storage of casks that were not helium leak tested. Results contained in the Effluent and Waste Disposal Report for this period were within the limits specified in 10 CFR 72.104. Based on the use of stringent and consistent fabrication requirements, leakage from these casks is not considered credible. Accordingly, these casks are bounded by the existing analysis for compliance with 10 CFR 72.104.

to ENOC-10-00034 Page 2 of 2

3. NRC Request:

Information that the sites dispositioned the deficiency through their non-conforming and corrective action process and determined that continued use of the MPCs was found to be acceptable.

IPEC Response:

Condition Report CR-IP2-2009-2983 was initiated for the Holtec failure to perform the required helium leak test during fabrication. A prompt determination of operability was prepared and a determination made that the affected MPCs would perform their intended safety function. This determination was based on an operability review.

ENOC-1 0-00034 NRC Requested Information for:

James A. FitzPatrick to ENOC-10-00034 Page 1 of 2 A teleconference was held by the NRC with Holtec and general licensees with loaded multi-purpose canisters (MPCs) that were not subjected to helium leak testing during fabrication for the purpose of discussing continued use of the affected MPCs. The following list, taken from the NRC Conversation Record (ML0935100008), identifies the information requested by the NRC. The requested information for James A. FitzPatrick (JAF) is provided-immediately following the NRC requested information below:

1. NRC Request:

Information that the thermal heat load for the spent fuel and internal helium conditions that had been loaded into the MPCs was bounded by the thermal and over pressure helium analyses provided by Holtec in their corrective action response to the NRC Enforcement Discretion letter dated August 6, 2009; for MPCs loaded above 21 kilowatts (kW) the NRC requested that the site provide information regarding the length of time that would elapse:before the spent fuel heat load would decay below 21 kW.

JAF Response:

JAF currently has two MPCs loaded with spent fuel in the independent spent fuel storage installation (ISFSI) that were not helium leak tested during fabrication.

These casks were loaded in accordance with the requirements of Certificate of Compliance (CoC) 1014, Amendment 5. The maximum heat load for these MPCs is 15.937 kW. Accordingly, these casks are bounded by the thermal and overpressure helium analyses provided by Holtec letter to the NRC dated September 2, 2009.

2. NRC Request:

Information that the site radiological monitoring programs had not detected any adverse effluent conditions associated with the use of the MPCs, and that all measured site radiological parameters were within the limits provided in 10 CFR 72.104.

JAF Response:

Entergy has reviewed the results of the Annual Radiological Environmental Operating Reports since the beginning of ISFSI storage operations in 2002. The results of this review determined that there is no discernible increase in dose to the public as the result of storage of casks that were not helium leak tested. Results contained in the Annual Radiological Environmental Operating Report for this period were within the limits specified in 10 CFR 72.104. Based on the use of stringent and consistent fabrication requirements, leakage from these casks is not considered credible. Accordingly, these casks are bounded by the existing analysis for compliance with 10 CFR 72.104.

to ENOC-10-00034 Page 2 of 2

3. NRC Request:

Information that the sites dispositioned the deficiency through their non-conforming and corrective action process and determined that continued use of the MPCs was found to be acceptable.

JAF Response:

Condition Report CR-JAF-2009-002669 was initiated for the Holtec failure to perform the required helium leak test during fabrication. A prompt determination of operability was prepared and a determination made that the affected MPCs would perform their intended safety function. This determination was based on an operability review.

ENOC-1 0-00034 NRC Requested Information for:

River Bend Station to ENOC-10-00034 Page 1 of 2 A teleconference was held by the NRC with Holtec and general licensees with loaded multi-purpose canisters (MPCs) that were not subjected to helium leak testing during fabrication for the purpose of discussing continued use of the affected MPCs. The following list, taken from the NRC Conversation Record (ML0935100008), identifies the information requested by the NRC. The requested information for River Bend Station (RBS) is provided immediately following the NRC requested information below:

1. NRC Request:

Information that the thermal heat load for the spent fuel and internal helium conditions that had been loaded into the MPCs was bounded by the thermal and over pressure helium analyses provided by Holtec in their corrective action response to the NRC Enforcement Discretion letter dated August 6, 2009; for MPCs loaded above 21 kilowatts (kW) the NRC requested that the site provide information regarding the length of time that would elapse before the spent fuel heat load would decay below 21 kW.

RBS Response:

RBS currently has eight MPCs loaded with spent fuel in the independent spent fuel storage installation (ISFSI) that were not helium leak tested during fabrication. These casks were loaded in accordance with the requirements of Certificate of Compliance (CoC) 1014, Amendments 2 and 5. The maximum heat load for these MPCs is 18.980 kW. Accordingly, these casks are bounded by the thermal and overpressure helium analyses provided by Holtec letter to the NRC dated September 2, 2009.

2. NRC Request:

Information that the site radiological monitoring programs had not detected any adverse effluent conditions associated with the use of the MPCs, and that all measured site radiological parameters were within the limits provided in 10 CFR 72.104.

RBS Response:

Entergy has reviewed the results of the Annual Radiological Environmental Operating Reports since the beginning of ISFSI storage operations in 2005. The results of this review determined that there is no discernible increase in dose to the public as the result of storage of casks that were not helium leak tested. Results contained in the Annual Radiological Environmental Operating Report for this period were within the limits specified in 10 CFR 72.104. Based on the use of stringent and consistent fabrication requirements, leakage from these casks is not considered credible. Accordingly, these casks are bounded by the existing analysis for compliance with 10 CFR 72.104.

to ENOC-10-00034 Page 2 of 2

3. NRC Request:

Information that the sites dispositioned the deficiency through their non-conforming and corrective action process and determined that continued use of the MPCs was found to be acceptable.

RBS Response:

Condition Report CR-RBS-2009-003386 was initiated for the Holtec failure to perform the required helium leak test during fabrication. A prompt determination of operability was prepared and a determination made that the affected MPCs would perform their intended safety function. This determination was based on an operability review.

ENOC-10-00034 NRC Requested Information for:

Vermont Yankee to ENOC-10-00034 Page 1 of 2 A teleconference was held by the NRC with Holtec and general licensees with loaded multi-purpose canisters (MPCs) that were not subjected to helium leak testing during fabrication for the purpose of discussing continued use of the affected MPCs. The following list, taken from the NRC Conversation Record (ML0935100008), identifies the information requested by the NRC. The requested information for Vermont Yankee (VY) is provided immediately following the NRC requested information below:

1. NRC Request:

Information that the thermal heat load for the spent fuel and internal helium conditions that had been loaded into the MPCs was bounded by the thermal and over pressure helium analyses provided by Holtec in their corrective action response to the NRC Enforcement Discretion letter dated August 6, 2009; for MPCs loaded above 21 kilowatts (kW) the NRC requested that the site provide information regarding the length of time that would elapse before the spent fuel heat load would decay below 21 kW.

VY Response:

VY currently has five MPCs loaded with spent fuel in the independent spent fuel storage installation (ISFSI) that were not helium leak tested during fabrication.

These casks were loaded in accordance with the requirements of Certificate of Compliance (CoC) 1014, Amendment 2. The maximum heat load for these MPCs is 10.231 kW. Accordingly, these casks are bounded by the thermal and overpressure helium analyses provided by Holtec letter to the NRC dated September 2, 2009.

2. NRC Request:

Information that the site radiological monitoring programs had not detected any adverse effluent conditions associated with the use of the MPCs, and that all measured site radiological parameters were within the limits provided in 10 CFR 72.104.

VY Response:

Entergy has reviewed the results of the Annual Radiological Environmental Operating Reports since the beginning of ISFSI storage operations in 2008. The results of this review determined that there is no discernible increase in dose to the public as the result of storage of casks that were not helium leak tested. Results contained in the Annual Radiological Environmental Operating Report for this period were within the limits specified in 10 CFR 72.104. Based on the use of stringent and consistent fabrication requirements, leakage from these casks is not considered credible. Accordingly, these casks are bounded by the existing analysis for compliance with 10 CFR 72.104.

to ENOC-1 0-00034 Page 2 of 2

3. NRC Request:

Information that the sites dispositioned the deficiency through their non-conforming and corrective action process and determined that continued use of the MPCs was found to be acceptable.

VY Response:

Condition Report CR-VTY-2009-002648 was initiated for the Holtec failure to perform the required helium leak test during fabrication. A prompt determination of operability was prepared and a determination made that the affected MPCs would perform their intended safety function. This determination was based on an operability review.