LR-N17-0104, Submittal of Report Pursuant to 10 CFR 71.95 (a)(3) and (B) - Failure to Follow Conditions of Tn RAM Packaging Certificate of Compliance No. 9233
| ML17167A135 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek, 07109233  |
| Issue date: | 06/16/2017 |
| From: | Carr E Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| LR-N17-0104 | |
| Download: ML17167A135 (9) | |
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PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 LR-N17-01 04 JUN 16 2017 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 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354 0PSEG Nuclear LLC 10 CFR 71.95
Subject:
Report Pursuant to 10 CFR 71.95 (a)(3) and (b) - Failure to Follow Conditions of TN RAM Packaging Certificate of Compliance No. 9233
References:
- 1. Certificate of Compliance No. 9233 for the TN-RAM Packaging, Revision 14.
- 2. Letter from TN Americas LLC to Registered Users for CoC Number 9233, Revision 14, Dated April 19, 2017.
PSEG Nuclear LLC (PSEG) is submitting the enclosed report pursuant to 10 CFR 71.95(a)(3) for potential instances in which conditions of approval in Certificate of Compliance (CoC) No. 9233, Revision 14, for the TN-RAM Packaging, Docket No. 71-9233 (Reference 1 ), may not have been observed in making eight shipments from the Hope Creek Generating Station between 2001 and 2015.
The condition described in the enclosed report was initially communicated to PSEG by the CoC holder in the Reference 2 letter and involves potential use of the TN-RAM
- package without rendering the impact limiter lifting attachment points inoperable. The certificate holder informed PSEG that the failure to render the impact limiter lifting lugs in'operable was noted during routine operations.
JUN 16 20!1 Page 2 LR-N17-01 04 10 CFR 71.95 Immediate action was taken by the CoC holder to install a cover on each impact limiter lifting lug retained by a bolt, which renders the attachment point inoperable. In addition, a durable marking was placed near each impact limiter lifting lug to identify the intended use of the lifting lugs. The CoC holder states that inadvertent use of the impact limiter lifting lugs for package lifting or tie-down is improbable based on the design and operation of the TN-RAM.
A written report, as required by CFR 71.95(c), is provided as Enclosure 1.
There are no regulatory commitments contained in this letter.
If you have any questions or require additional information, please contact Lee Marabella at 856-339-1208.
Eric Carr Vice President, Hope Creek
Enclosure:
- 1.
10 CFR 71.95 Written Report cc:
D. Dorman, Regional Administrator - NRC Region I L. Regner, Project Manager - Hope Creek, US NRC NRC Senior Resident Inspector - Hope Creek l5. Shaw, [icenslng Ma-nager, TN Americas LLC P. Mulligan - Chief, NJBNE Tom MacEwen - Hope Creek Commitment Coordinator Lee Marabella - Corporate Commitment Coordinator
LRN1701 04 10 CFR 71.95 Written Report
10 CFR 71.95 Written Report (1) Abstract The TN-RAM package has trunnions intended as attachment points for lifting and tie down. The trunnions are a structural part of the package that is designed to meet the requirements of the regulation for lifting and tie-down. Attachment points for lifting the impact limiters during installation and removal are a structural part of the impact limiters that are part of the TN-RAM package. An evaluation of the TN-RAM lifting attachment points demonstrates that the trunnions and impact limiter lifting lugs have been designed only for their intended use. Inadvertent use of the impact limiter lifting lugs to lift or tie-down the TN-RAM would impair the ability of the package to meet requirements for transport. However, operation of the TN-RAM has not included any controls to render the impact limiter lifting lugs inoperable during transport operations as required by transport regulations. An evaluation of the lifting and tie-down operations has been done to determine the extent of the condition and appropriate corrective actions to render the impact limiter lugs inoperable. A review of the NRC 10 CFR Part 71.87(h) regulatory requirements for Operating Controls and Procedures determined that use of the cask without rendering the impact limiter lugs inoperable is a practice that did not follow the conditions of the certificate of compliance.
(2) Description of the event (i)
Status of components or systems that were inoperable at the start of the event and that contributed to the event The TN RAM cask system is a Type B transportation package design approved by the NRC (71-9233). The package is a steel encased lead shielded cask with wood impact limiters attached at both ends. The impact limiters are a tYackaginf component that is-requtred by the NRC approval of the-package design. Impact limiters protect the cask shell and contents by absorbing shocks from impacts incidental to normal and accident transportation conditions. The cask shell is a right circular cylinder with trunnions welded to the outer shell for lifting and tie-down. The overall dimensions of the packaging are approximately 178 inches long and 92 inches in diameter with the impact limiters installed. The cask body is approximately 129 inches long with an outer diameter of 51 inches. The maximum gross weight of the 1
and lifting devices in the TN-RAM Safety Analysis Report (SAR) states that there are no other structural parts of the package which can be used for tie down attachments.
(ii)
Dates and approximate times of occurrences The TN-RAM package first industry use was on or about 1989. The lifting lugs were not rendered inoperable during the period of operation since first use. PSEG shipments from Hope Creek using the TN-RAM package were made on the following dates:
February 15, 2001 March 13, 2001 March 28, 2001 September 22, 2011 October 10, 2011 December 08, 2011 September 9, 2015 September 23, 2015 (iii)
The cause of each component or system failure or personnel error The TN-RAM SAR contains loading and handling guidelines that include general instructions for removal of the impact limiters using a "suitable crane and two legged sling," rotating and lifting the cask using a "suitable crane hook" to "engage the lift beam to the two front trunnions," and removal and installation of "front and rear trunnion tie-downs." The Operations and Maintenance Manual for the TN-RAM (OM-7) expands on the handling guideline and describes the trunnions intended purpose for lifting and tie down of the cask. OM-I-also describes the -impact limiter-lifting lugs_as "located such that the limiter is balanced when it is lifted." The glossary of terms in OM-7 defines lifting lugs as "attachments provided on the impact limiters for handling operations," lift beams as "devices for cask lifting and handling operations," and trunnions as "handling attachments provided for cask primary lifting, support and tie-down." These definitions describe the intended purpose of attachment points. The design of the impact limiter rigging equipment is sized for attachment to the lifting lugs, and lift beams 2
are specialized lifting devices that are designed for attachment to the trunnions. A dynamometer is installed between the crane hook and sling that is attached to the lifting lugs. The dynamometer is used to support the weight to allow removal of impact limiter bolts, and the procedure directs handling personnel to "lift up on the sling until a reading of 3700, +0, -100 pounds is indicated on the dynamometer." Any attempt to lift the weight of the TN-RAM package would exceed 3700 pound reading on the dynamometer. Tie-down members for the TN-RAM are trailer support pedestals specially designed for attachment to the trunnions.
The tarp installed over the support frame during transport has been considered a control to render the impact limiter lugs inoperable. The tarp, when installed, blocks access to the impact limiter lugs, but the lifting lugs are accessible when the tarp and support frame are removed for handling operations. Transport operations include the preparation of the package for transport (installing impact limiters), securing the package to the trailer for transit (tie-down), and receiving the package (removing impact limiters).
During preparation for transport and receipt of the TN-RAM, the impact limiters are installed without the tarp in place. Prior to removal of the impact limiters and after installation, the lift lugs are accessible.
Rigging equipment or tie-down members could inadvertently be attached to the lift lugs. However, lifting or tie-down of the TN-RAM using the lifting lugs would require intentional misuse of the rigging equipment and tie-down members, and violate operational controls and procedures for handling the cask. A method for rendering the lift lugs inoperable is required to prevent attachment to these points during preparation and receipt phases of transport operations. The tarp does not meet the intent of the requirement in the regulation to render the attachment-point inoperable during-all phases-of transport operations.
(iv)
The failure mode, mechanism, and effect of each failed component The impact limiter attachment points are intended only for lifting the impact limiter during removal and installation while the TN-RAM package is attached to the transportation trailer. Each impact limiter weighs approximately 3700 3
lbs. The impact limiter shell is a structural part of the packaging that retains the wood shock absorber. The shell is sealed to protect the wood material from environmental conditions incident to routine use.
The impact limiter lifting lugs are designed for a safety factor against yield that is consistent with accepted industry standards for material handling using standard rigging equipment. The nominal design weight of the impact limiter is 3695 lbs. The most likely failure mechanism or "weak link" in the attachment point on the impact limiter would be a tensile breakage of the lifting lug. Attempting to lift the package using the impact limiter lifting lugs would not result in damage to the structural impact limiter shell that would impair the ability to meet transport requirements.
The trunnions on the TN-RAM cask are designed for tie-down to the transport trailer. The impact limiter lifting lugs were not intended to tie-down the TN-RAM for transport. The stress applied to the lifting lugs used at attachment points for tie-down would be different than for the intended use to lift the impact limiters. A review of the impact limiter lifting design basis indicates that the lifting lugs would not withstand the stress applied by static forces required for tie-down in 71.45(b) or static force required by DOT for Protection Against Shifting and Falling Cargo (49 CFR 393).
{v)
A list of systems or secondary functions that were also affected for failures of components with multiple functions Lifting lugs are designed for the single purpose of lifting the impact limiter.
{vi)
The method of discovery of each component or system failure or procedural error F_aiLure to render th? impact limiter lugs_ inoperable wa§ noted_during_rol.Jtin operation of the TN-RAM.
{vii)
For each human performance-related root cause, a discussion of the cause{s) and circumstances Approved operational procedures and controls in place were followed since first use of the cask. There is no known instance of lifting or tie-down of the TN-RAM using the lifting lugs during nearly 30 years operating experience.
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(viii)
The manufacturer and model number (or other identification) of each component that failed during the event No failure of the impact limiter lifting lugs occurred on the TN-RAM No. 001.
(3) Safety Significance The impact limiter lifting lugs when used as intended have been evaluated to me.et industry standards for rigging and material handling. Attempting to lift the TN-RAM using the lifting lugs would result in a yielding and tensile failure of the lifting lug. The structural shell of the impact limiter would not likely be damaged due to attempting to lift the package using the lifting lugs. Stresses generated in the im'pact limiter shell, if used as a tie-down attachment point for securement of load during transport, have not been analyzed. Using the impact limiter lifting lugs as tie-down attachment points could generate stresses in the impact limiter shell that could result in tears or cracks. If undetected during the normal use or periodic inspections, these defects would allow moisture ingress and eventual degradation of the wood impact absorbing material that would impair the performance of the package during normal and accident transport conditions.
(4) Corrective Actions Both engineering and administrative controls have been implemented to prevent inadvertent use of the impact limiter lugs for lifting or tie-down of the package. The engineering control is a cover for each impact limiter lifting lug that is retained by a bolt installed in the lifting lug through hole to render the attachment point inoperable. The lifting lug covers prevent attachment of rigging equipment or tie down members to the impact limiters lift lugs during transport. An administrative control identifies the intended use of the impact limiter lifting lugs by a durable marking near each impact limiter lifting lug stating "IMPACT LIMITER LIFTING ONLY."
(5) Extent of the Condition Operating procedures and design of the lift beam that are intended for lifting the cask and the lifting lugs make it improbable that the lift beam would be attached to the lifting lugs. Furthermore, the trailer trunnion pedestals are tie-down members specifically designed for attachment to the trunnions, making it improbable that generic tie-down members attached to the lifting lugs would be used to secure the TN-RAM to the trailer.
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The design and operation of the TN-RAM limits the possibility of inadvertent use of the impact limiter lifting lugs as package lifting or tie-down attachment points. All lifting and tie-down operations are controlled by detailed operating procedures and performed by trained and qualified personnel. The TN-RAM cask shell is lifted without the impact limiters installed. Impact limiters are removed from the cask shell prior to lifting operations to remove the cask shell from the trailer, and likewise the impact limiters are installed after lifting operations to place cask shell on the trailer are complete. Handling is done exclusively by persons trained in operation of the TN-RAM at the loading facility and unloading facilities, and transport is by exclusive use on a specialized trailer.
(6) Contact information If you have any questions or require additional information, please contact Lee Marabella at 856-339-1208.
(7) Extent of exposure of individuals to radiation or to radioactive materials No individuals were exposed to radiation or to radioactive materials as a consequence of not rendering the impact limiter lifting lugs inoperable during transport operations.
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