CNL-20-102, 10 CFR 71.95 Report for 3-60B Casks User

10 CFR 71.95 Report for 3-60B Casks User

ML20350B778
Person / Time
Site:	Browns Ferry, Watts Bar, Sequoyah, 07109321
Issue date:	12/16/2020
From:	Polickoski J Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
CNL-20-102
Download: ML20350B778 (9)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-20-102 December 16, 2020 10 CFR 71.95 ATTN: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555 -0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328 Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License No. NPF-90 and NPF-96 NRC Docket No. 50-390 and 50-391

Subject:

10 CFR 71.95 Report for 3-60B Casks User

Reference:

Energy Solutions letter to NRC, 10 CFR 71.95 Report on the 3-60B cask (Docket 71-9321) dated October 20, 2020 (ML20294A184)

Tennessee Valley Authority (TVA) hereby submits the enclosed report pursuant to 10 CFR 71.95(a)(3) regarding instances in which the conditions in Certificate of Compliance 71-9321 for 3-60B casks were unknowingly not observed when making shipments from TVA sites. Energy Solutions informed TVA of this non-compliance on October 22, 2020.

The circumstances described in the Energy Solutions report (Reference), which is provided in , is applicable to the 3-60B casks used by TVA. TVA records indicate that a total of nine Class B shipments using the 3-60B cask were completed between February 2017 and September 2019. The affected shipments are listed in Enclosure 2.

Energy Solutions failure to perform periodic maintenance inspections has no safety consequence because such inspections were performed prior to each use of the 3-60B casks.

Additional details are provided in Enclosure 1.

U.S. Nuclear Regulatory Commission CNL-20-102 Page 2 December 15, 2020 There are no new regulatory commitments associated with this submittal. Please address any questions regarding this submittal to Jonathan Johnson, Senior Manager, Regulatory Compliance at jtjohnson0@tva.gov.

Respectfully, for James T. Polickoski Director, Nuclear Regulatory Affairs Enclosure(s): 1. ML20294A184 Energy Solutions 71.95 Notification to NRC dated 10-20-2020

2. TVA 10 CFR 71.95 Report cc (Enclosure):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Senior Resident Inspector - Sequoyah Nuclear Plant NRC Senior Resident Inspector - Watts Bar Nuclear Plant Energy Solutions - Cask Division Engineering/Licensing Manager (3-60B Certificate Holder)

Enclosure 1 ML20294A184 Energy Solutions 71.95 Notification to NRC dated 10-20-2020

October 20, 2020 ES/NRC 20-004 ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

10CFR 71.95 Report on the 3-60B cask (Docket 71-9321)

EnergySolutions hereby submits the attached report (Attachment 1) providing the information required by 10CFR71.95(a)(3) for instances in which conditions of approval in the Certificate of Compliance for the 3-60B cask have not been observed in making shipments.

The circumstances described in this report is applicable to EnergySolutions (as a license holder and periodic maintenance inspection provider) and may be applicable to all licensed users (licensees) of 3-60B cask.

Should you have any questions regarding this notice, please contact me at (803)591-9074.

This letter is submitted electronically via the NRC Electronic Information Exchange (EIE) system.

Sincerely, Aleksandr Gelfond Cask Division Engineering/Licensing Manager : Failure to Observe Certificate of Compliance Condition for the 3-60B cask periodic maintenance inspection, October 20, 2020 cc) Pierre Saverot, NRC Gerard van Noordennen, EnergySolutions 740 Osborn Road, Barnwell, SC 29812 www.energysolutions.com CNL-20-102 E-1 of 3

Attachment 1 to ES/NRC 20-004 Failure to Observe Certificate of Compliance Condition for the 3-60B cask periodic maintenance inspection October 20, 2020

1) Abstract During a recent NRC inspection of EnergySolutions Barnwell Logistics Facility (BLF), the inspection team identified that periodic maintenance performed for 3-60B casks (units #1 and #2) did not comply with Chapter 8 of the 3-60B cask Safety Analysis Report (SAR) requirements invoked by the latest revision of the Certificate of Compliance 71-9321 (CoC). Specifically, packaging markings (lid alignment markings), fasteners/threaded holes, exposed packaging interior and exterior surfaces were not inspected periodically as required by Table 8-1 of Chapter 8 of the 3-60B cask SAR.

Failure to perform periodic maintenance inspection of these items has no safety consequence because such inspections were performed prior to each use of 3-60B cask. Although, such inspections were performed prior to each use, EnergySolutions failed to inspect these items periodically as required in condition of approval in the CoC 71-9321. As such, condition of approval in the Certificate of Compliance was not observed in making a shipment which is addressed by 10CFR71.95 (a)(3).

2) Narrative Description of the Event a) Status of Components 3-60B cask units #1 and # 2 have been removed from service until required periodic inspections (in accordance with Chapter 8 of the SAR) are completed.

b) Dates of Occurrences The dates of occurrences for affected packagings are as follows:

3-60B cask Dates of Occurrences (shipments) Number of Shipments

1. 1 March 2016 to June 2020 27

1. 2 July- September 2019 3 c) The cause of each component or system failure or personnel error, if known.

EnergySolutions Cask Book Procedure (TR-OP-052) provides a subset of operational, inspection, test and maintenance procedures for 3-60B cask operations. Among these procedures are:

x EnergySolutions Procedure No. CS-FP-PR-016, 3-60B Shipping Cask: Periodic Inspection and Maintenance of Fastener and Threaded Holes x EnergySolutions Procedure No. CS-FP-PR-017, 3-60B Shipping Cask: Periodic Maintenance of Exposed Surfaces.

These procedures were inadvertently omitted from the use by the cask maintenance personnel during periodic maintenance inspections.

1 CNL-20-102 E-2 of 3

Attachment 1 to ES/NRC 20-004 d) Failure Mode, Mechanism, and Effect of each failed component, if known Not applicable; no 3-60B packaging components failed.

e) Systems or Secondary Functions Affected Not applicable.

f) Method of Discovery of the Error The error/condition was identified by the NRC inspection team during an audit of EnergySolutionss Barnwell Logistics Facility (Barnwell, SC).

3) Assessment of Safety Consequences Failure to perform periodic inspection of packaging markings (lid alignment markings),

fasteners/threaded holes, exposed packaging interior and exterior surfaces has no safety consequence because such inspections were performed prior to each use of 3-60B cask.

4) Planned Corrective Actions The following corrective actions are planned by EnergySolutions:

x EnergySolutions has removed 3-60B cask units #1 and #2 from service until appropriate annual inspections are performed.

x EnergySolutions has evaluated the condition for reportability under 10CFR 71.95 and has concluded that it is reportable.

x EnergySolutions (as the 3-60B cask license holder and periodic maintenance provider) will submit this report to NRC.

x EnergySolutions will contact licensees (cask users) that have made shipments using the affected 3-60B cask units with request to evaluate reportability under 10CFR71.95 process.

x EnergySolutions will perform an apparent cause analysis and identify additional corrective actions to prevent reoccurrence.

x All required inspections will be performed on the affected casks prior to placing them back into service.

5) Previous Similar Events Involving the 3-60B casks No previous similar events have been identified.

6) Contact for Additional Information Aleksandr Gelfond EnergySolutions Cask Division Engineering/Licensing Manager (803)591-9074 axgelfond@energysolutions.com

7) Extent of Exposure of Individuals to Radiation or Radioactive Materials

None 2

CNL-20-102 E-3 of 3

Enclosure 2 TVA 10 CFR 71.95 Report (1) Abstract- §71.95(c)(1)

Tennessee Valley Authority (TVA) was notified by Energy Solutions on October 22, 2020, that a notification was made to the NRC in accordance with 10 CFR 71.95, regarding instances in which conditions in the Certificate of Compliance (CoC) for the 3-60B casks were not observed in making shipments. The subject non-compliance subsequently affected shipments made from TVA sites.

On October 2, 2020, during a 10 CFR 71 program audit at Energy Solutions, the NRC inspection team identified that periodic maintenance performed for 3-60B casks (units #1 and

1. 2) did not comply with Chapter 8 of the 3-60B cask Safety Analysis Report (SAR) requirements invoked by the effective revision of the CoC 71-9321. Specifically, packaging markings (lid alignment markings), fasteners/threaded holes, exposed packaging interior and exterior surfaces were not inspected periodically as required by Table 8-1 of Chapter 8 of the 3-60B cask SAR.

Failure to perform periodic maintenance inspection of these items has no safety consequence because such inspections were performed prior to each use of 3-60B cask. Although such inspections were performed prior to each use, Energy Solutions failed to inspect these items periodically as required in condition of approval in the CoC 71-9321. As such, condition of approval in the CoC was not observed in making a shipment which is required by 10CFR 71.95(a)(3).

(2) Narrative Description - §71.95(c)(2)

(i) Status of components or systems that were inoperable at the start of the event and that contributed to the event:

Energy Solutions 3-60B cask units #1 and # 2 have been removed from service until required periodic inspections (in accordance with Chapter 8 of the SAR) are completed.

(ii) Dates and approximate times of occurrences and model numbers:

PLANT DATE Watts Bar 3-60B-1: 2 shipments 2/24/2017 1/26/2018 3-60B-2: 1 shipment 9/27/2019 Browns Ferry 3-60B-1: 5 Shipments 6/25/2019 7/10/2019 7/24/2019 8/14/2019 8/18/2019 Sequoyah 3-60B-1: 1 Shipment 6/13/2017 CNL-20-102 E2- 1 of 3

(iii) The cause of each component or system failure or personnel error, if known:

The Energy Solutions procedures were inadvertently omitted from use by the cask maintenance personnel during periodic maintenance inspections. TVAs internal processes do not check the specific maintenance inspections when receiving the cask shipments.

(iv) The failure mode, mechanism, and effect of each failed component, if known:

Not applicable; no 3-60B packaging components failed.

(v) A list of systems or secondary functions that were also affected for failures of components with multiple functions:

Not applicable; no other systems or secondary functions affected.

(vi) The method of discovery of each component or system failure or procedural error:

TVA was notified by Energy Solutions on October 22, 2020, that a notification was made to the NRC in accordance with 10 CFR 71.95. The non-compliance that led to the 10 CFR 71.95 report was discovered during an NRC audit completed on October 2, 2020, assessing implementation of 10 CFR 71 program at the Energy Solutions Barnwell Logistics Facility.

(vii) For each human performance-related root cause, a discussion of the cause(s) and circumstances:

The vendor documentation reviewed as part of the TVA receipt process was performed in accordance with the TVA procedure. The cause for the documentation non-compliance is discussed in Energy Solutions notification to the NRC dated October 22, 2020.

(viii) The manufacturer and model number (or other identification) of each component that failed during the event:

No casks or component failed.

(ix) For events occurring during use of a packaging, the quantities and chemical and physical form(s) of the package contents.

Not applicable.

(3) An assessment of the safety consequences and implications of the event. This assessment must include the availability of other systems or components that could have performed the same function as the components and systems that failed during the event.

Failure to perform periodic inspection of packaging markings (lid alignment markings),

fasteners/threaded holes, exposed packaging interior and exterior surfaces has no safety consequence because such inspections were performed prior to each use of 3-60B cask.

CNL-20-102 E2- 2 of 3

(4) A description of any corrective actions planned as a result of the event, including the means employed to repair any defects, and actions taken to reduce the probability of similar events occurring in the future.

This event was captured in TVAs corrective action program under Condition Report (CR) 1646788. TVA contacted Energy Solutions to amend our contract with an additional requirement for the vendor to provide a letter/data validating they are in compliance with the Certificate of Compliance. A step will be added to TVAs procedure to confirm the additional requirement.

(5) Reference to any previous similar events involving the same packaging that are known to the licensee or certificate holder.

No previous similar events have been identified.

(6) The name and telephone number of a person within the licensee's organization who is knowledgeable about the event and can provide additional information.

Sandra Koss TVA Corporate Functional Area Manager, Rad Waste/Rad Shipping sskoss@tva.gov (7) The extent of exposure of individuals to radiation or to radioactive materials without identification of individuals by name.

No exposure as a result of this event.

CNL-20-102 E2- 3 of 3