ML17195A249
| ML17195A249 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Surry, North Anna, 07109233  |
| Issue date: | 07/10/2017 |
| From: | Mark D. Sartain Dominion Nuclear Connecticut, Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| 17-215 | |
| Download: ML17195A249 (13) | |
Text
Dominion Energy Services, Inc.
5000 Dominion Boulevard, Glen Allen, VA 23060 Dominion Energy.com July 10, 2017
~Dominion
~Energy U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Washington, DC 20555-0001 DOMINION NUCLEAR CONNECTICUT, INC Serial No.17-215 NRAff JS RO Docket Nos.
50-245,336,423 50-338,339 50-280,281 License Nos.
DPR-21,65, NPF-49 NPF-4,7 DPR-32,37 MILLSTONE POWER STATION UNITS 1. 2 AND 3
--, 14 2-3~
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 SURRY POWER STATION UNITS 1 AND 2 REPORT PURSUANT TO 10 CFR 71.95 (a)(3) AND (bl-FAILURE TO FOLLOW CONDITIONS OF TN-RAM PACKAGING CERTIFICATE OF COMPLIANCE No. 9233 Dominion Nuclear Connecticut, Inc. (DNC) and Virginia Electric and Power Company (VEPCO) are submitting this report pursuant to 10 CFR 71.95(a)(3) and (b) with respect to Certificate of Compliance (CoC) No. 9233, Revision 14, for the TN-RAM Packaging, Docket No. 71-9233. DNC and VEPCO are authorized users of the TN-RAM packaging under the provisions of 10 CFR 71.17, General license: NRC-approved package.
Only one TN-RAM package has been fabricated and in use since 1989. Since this time, impact limiter lifting lugs not intended for package lifting or tie-down were not rendered inoperable for transport operations as required by 10 CFR 71.87(h) and 49 CFR 173.41 (b). The failure to renderthe impact limiter lifting lugs inoperable was recently noted during routine operations. Further review of the packaging design determined that the attachment points intended for lifting the impact limiters will not withstand the static force required for lifting and tie-down per 10 CFR 71.45.
Upon discovery of the discrepancy described above, immediate action was taken by the CoC owner, AREVA I TN, to install a cover on each impact limiter lifting lug. The covers are retained by a bolt installed in the lifting lug through-hole, which renders the attachment point inoperable. In addition to installing the covers, a durable marking, stating "IMPACT LIMITER LIFTING ONLY," was placed near each impact limiter lifting lug to identify the intended use of the lifting lugs.
A written report, as required by 10 CFR 71.95(c), is provided as Attachment 1.
Specific instances documenting DNC and VEPCO use of the TN-RAM package during the affected time period are provided as Attachment 2.
Serial No.17-215 TN-RAM 71.95 Notification Page 2 of 3 If you have any questions or require additional information, please contact Mr. Thomas Szymanski at (804) 273-3065.
Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support Dominion Energy Nuclear Connecticut, Inc.
Virginia Electric and Power Company
References:
- 1. AREVA letter dated April 19, 2017, "Notification to Registered Users (Licensees) -
Failure to Follow Conditions of TN-RAM Packaging Certificate of Compliance No.
9233," (E-48377)
Attachments:
- 1. 10 CFR 71.95(c) Report for TN-RAM Package CoC No. 9233
- 2. DNC and VEPCO Shipments Using TN-RAM Package from 1989 to Present Commitments made in this letter: None cc: U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Blvd Suite 100 King of Prussia, PA 19406-2713 NRC Senior Resident Inspector Millstone Power Station (Units 2 and 3)
Ms. L. A. Kauffman I MPS - Unit 1 U.S. Nuclear Regulatory Commission Region 1 2100 Renaissance Blvd Suite 100 King of Prussia, PA 19406-2713
Mr. Richard Guzman NRC Senior Project Manager (MPS Units 2 and 3)
U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 C-2 11555 Rockville Pike Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Avenue, NE, Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector North Anna Power Station NRC Senior Resident Inspector Surry Power Station Mr. James R. Hall NRC Senior Project Manager (NAPS)
U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 G9A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Karen Cotton Gross NRC Project Manager (SPS)
U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 G9A 11555 Rockville Pike Rockville, MD 20852-2738 Mr. John Vera NRC Project Manager (TN-RAM Package)
U.S. Nuclear Regulatory Commission Two White Flint North, Mail Stop 4 834 11545 Rockville Pike Rockville, MD 20852-2738 TN AMERICAS LLC Attn: Don Shaw, Licensing Manager 7135 Minstrel Way - Suite 300 Columbia, MD 21045 Serial No.17-215 TN-RAM 71.95 Notification Page 3 of 3
Serial No.17-215 Docket Nos. 50-245,336,423,338,339,280,281 Page 1 of 8 ATTACHMENT 1 10 CFR 71.95(c) Report for TN-RAM Package CoC No. 9233 Millstone Power Station Units 1, 2 and 3, Dominion Nuclear Connecticut, Inc.
North Anna Power Station Units 1 and 2 Surry Power Station Units 1 and 2 Virginia Electric and Power Company
Serial No.17-215 Docket Nos. 50-245,336,423,338,339,280,281, Page 2 of 8 10 CFR 71.95(c) Report for TN-RAM Package CoC No. 9233 (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 71.78(h) regulatory requirements for Operating Controls and Procedures determined that use of the cask without rendering the impact limiter lugs inoperable is a practice not in accordance with 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. The package is a steel encased lead shielded cask with wood impact limiters attached at both ends. The impact limiters are a packaging component that is required 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 1 7 8 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 package is approximately 80,000 lbs. The structural evaluation for tie-down and lifting devices in the TN-RAM Safety Analyses Report (SAR) states that there are no other
Serial No.17-215 Docket Nos. 50-245,336,423,338,339,280,281, Page 3 of 8 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 use was on or about 1989. The lifting lugs were not rendered inoperable during the period of operation since first use. For DNC and VEPCO uses of the TN-RAM package see Attachment 2.
(iii) The cause of each component or system failure or personnel error The TN-RAM SAR contains loading and handling guidelines that inc_lude 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-7 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 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 requires "lift up on the sling until a reading of 3700, +O, -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
Serial No.17-215 Docket Nos. 50-245,336,423,338,339,280,281, Page 4 of 8 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 renderthe 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 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 lifting lugs were not intended to tie-down the TN-RAM during trarisport. 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(a) 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
Serial No.17-215 Docket Nos. 50-245,336,423,338,339,280,281, Page 5 of 8 The impact limiter 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 Failure to render the impact limiter lifting lugs inoperable was noted during routine 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 impact limiter lifting lugs during nearly 30 years operating experience.
(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.
(ix) For events occurring during use of a packaging, the quantities and chemical and physical form(s) of the package contents Quantities of radioactive material in the form of activated metals shipped during use of the package varied during use. During this period of use, the package contents were limited to about 14,000 Ci Co-60 equivalent activity.
This limit was recently increased in 2015,to a allow up to 30,000 Ci Co-60 equivalent activity.
(3) Safety Significance The impact limiter lifting lugs when used as intended have been evaluated to meet industry standards for rigging and material handling. Attempting to lift the TN-RAM using these lifting *lugs would result in a yielding and tensile failure of the lifting lugs. The structural shell *of the impact limiter would not likely be damaged due to attempting to lift the package using these lifting lugs.
Stresses generated in the impact limiter shell when used as a tie-down attachment point for securing the 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.
Serial No.17-215 Docket Nos. 50-245,336,423,338,339,280,281, Page 6 of 8 Undetected during the normal use or periodic inspections, damage due to impact limiters from improper use of the lifting lugs could 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 (Figure 1).
Figure 1-Lifting Lug Cover 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" (Figure 2).
Additionally a statement will be added in the SAR Chapter 7-Operations and Operations and Maintenance Manual, OM-07 "TN RAM Operations Manual" subsection 8.5 that would require rendering the impact limiter lifting lugs inoperable and stating the allowed attachment points for lifting and tie-down of the TN-RAM. The SAR Chapter 7 is a condition of the § 71.17, "General license:
Serial No.17-215 Docket Nos. 50-245,336,423,338,339,280,281, Page 7 of 8 NRG-approved package," and OM-7 is provided to the cask users as a guide with more detailed instructions on implementing the operations requirements in the SAR.
Neither TN-RAM SAR, Ch. 7 "Operations," or previous versions of Operations and Maintenance manual OM-7, include a requirement to render attachment points inoperable that are a structural part of the package and not designed for intended package lifting or tie-down. The most recent version of OM-7, however, did add a requirement to render the lifting lugs inoperable by installing a bolt through the lug or other similar method.
Figure 2 - Lifting Lug Marking (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.
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
Serial No.17-215 Docket Nos. 50-245,336,423,338,339,280,281, Page 8 of 8 the impact limiters are installed after lifting operations to place the cask shell on the trailer are complete. Handling is performed by persons trained in operation of the TN-RAM at the loading facility and unloading facilities, and transport is by use of a specialized trailer. \\
(6) Contact Information Please contact Mr. Thomas Szymanski at 804-273-3065 for additional information.
(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.
Serial No.17-215 Serial No.17-215 Docket Nos. 50-245,336,423,338,339,280,281 Page 1of2 ATTACHMENT 2 DNC and VEPCO Shipments Using TN-RAM Package from 1989 to Present Millstone Power Station Units 1, 2 and 3 Dominion Nuclear Connecticut, Inc.
North Anna Power Station Units 1 and 2 Surry Power Station Units 1 and 2 Virginia Electric and Power Company
Serial No.17-215 Docket No. 50-245,336,423,338,339,280,281, Page 2 of 2 DNC and VEPCO Shipments Using TN-RAM Package from 1989 to Present Station Destination Date of Shipment NAPS Chem-Nuclear, Barnwell, SC 04/03/1999 NAPS Chem-Nuclear, Barnwell, SC 04/09/1999 NAPS Chem-Nuclear, Barnwell, SC 04/16/1999 NAPS Chem-Nuclear, Barnwell, SC 11/08/1999 NAPS Chem-Nuclear, Barnwell, SC 11/15/1999 NAPS Chem-Nuclear, Barnwell, SC 12/01/1999 SPS Chem-Nuclear, Barnwell, SC 01/29/1999 SPS Chem-Nuclear, Barnwell, SC 02/08/1999 SPS Chem-Nuclear, Barnwell, SC 12/05/2003 MPS Chem-Nuclear, Barnwell, SC 12/05/1989 MPS Chem-Nuclear, Barnwell, SC 01/16/1990 MPS Chem-Nuclear, Barnwell, SC 05/07/1990 MPS Chem-Nuclear, Barnwell, SC 10/13/1992 MPS Chem-Nuclear, Barnwell, SC 04/14/2000 MPS Chem-Nuclear, Barnwell, SC 05/08/2000 MPS Chem-Nuclear, Barnwell, SC 05/19/2000 MPS Chem-Nuclear, Barnwell, SC 0610712000 MPS Chem-Nuclear, Barnwell, SC 07/17/2000