ML20205E248
| ML20205E248 | |
| Person / Time | |
|---|---|
| Site: | 07109019 |
| Issue date: | 03/26/1999 |
| From: | Gruss K NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Kevin Ramsey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9904050108 | |
| Download: ML20205E248 (1) | |
Text
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l
.; March 26, 1999 MEMORANDUM TO: Kevin Ramsey, IMOB/IMNS/NMSS
-FROMi _ Kimberly A. Gruss, PCS/SFPO/NMSS
SUBJECT:
RESOLUTION OF REPORT MADE UNDER THE PROVISIONS OF 10 CFR 71.95 The provisions of 10 CFR 71.95(c) require that a licensee report any instances in which the conditions of approvalin the Certificate of Compliance were not observed in making a shipment. The following report was made under those provisions:
D7cket No.: 71-9019 Packaae Model No.: BU-7 Report dated: February 10,1999 Reoort oriainated by: GE Nuclear Energy Conditions not observed in makina a shioment:
During a routine inspection of the BU 7 containers, the following conditions in the area between the inner and outer container lids were discovered: (1) paint applied to the inner and outer lids and to the sides of the outer container was peeling and blistering, (2) the side wall of the outer drum, the inner lid, and the bolts and washers were badly corroded, and (3) a white crystalline residue was observed on the outer lid. Shipments were not being made with the packages when the non-compliance was identified.
The followina corrective actions were imolemented:
No shipments of the uranium oxide or other uranium-bearing material will be made using ;
the BU-7 packages. l GE Nuclear Fuels (cert:ficate holder), BWX Technology (registered user) and Eco-Pak /
Specialty (container fabricator) undertook investigations of the root cause of the reported conditions. However, since the parties were unable to determine the origin of the observed failures, GE Nuclear has requested that NRC terminate the certificate.
Staff agrees that the corrective action is adequate. Accordingly, Certificate of Compliance ,
No. 9019 has been terminated. Staff considers this report closed. l Docket No.: 71-9019 e. r-- .
Attachments: Report gig I h h h.,,,hh @
Distribution: SFPO r/f NMSS r/f Docket File 71-9019 PUBLIC
- C" = Copy without attachment / enclosure "E" = Cop / with attachmen%nclosure *N" = No copy OFC NMSS/SFPO g NMSS/SFPO C NMSS/SFPO/ NMSS/SFPO C NAME KAGruss M NLOsgood)\M ERZie[ CRCH N DATE 3/p/99 3/li/99 g/99 3 5 /99 i I
OFFICIAL RECORD COPY 9904050100 990326 PDR ADOCK 07109019 C PDR c
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. GE Nuclest Energy
{ ,
i February 10,1999 1
l Director Office of Nuclear Material Safety & Safeguards US Nuclear Regulatory Comminaion Washington, DC 20555-0001
Subject:
Reporting Pursuant to 10CFR71.95 and 10CFR21
References:
(1) Docket Number 71-9019 (2) NRC Certificate of Compliance 9019 for the Model No. BU-7 Packaging
Dear Sir:
1 l
On 1/12/99, BWX Technology, Navy Nuclear Fuel Division (NNFD) in Lynchburg, VA, 1 informed GE in Wilmington, N.C. that during a routine inspection of their BU-7 fleet, they discovered conosion, paint peeling / blistering and a white crystal formation. These conditions were observed in the area between the inner container lid and the outer container lid. This is the location where the phenolic foam insulating plug is located. Photographs of the as-discovered condition are provided in Attachment la. Additional details of the specific conditions found are described in Attachment ib provided by NNFD, dated 2/2/99.
Notwithstanding the NRC Statements of Considesation dated September 29,1995, pages 71 SC-12, and 13 that place the reporting responsibility on the shipper, GE has assumed the reporting responsibility based upon comments and suggestions made during telephone conversations with the NRC, BWX Technologies and Eco Pak. This was decided because we are the owner of the ccaificate holder, although we are not the manufacturer nor do we own or possess any BU-7's.
Shipments were not taking place with the packages at the time of this MS NNFD stated that their current fleet of BU-7 containers had been purchased in the spring of 1996 from Nuclear Containers Inc. (NCI) in Elizabethton, Tennessee. All of these BU 7's were fabricated within a 6 month period and no abnormalities were noted by NNFD during their inspections and quality related activities.
Director
' Of5ce of Nuclear Material Safety & Safeguards l
February 10,1999 Page 2'of 3 NNFD reviewed their BU-7 fleet to determine if there was a difference in the population. They stated that there did not seem to be a difference in the BU-7's physical condition: (1) based upon l storage location such as trailers out of the weather in uncontrolled atmosphere, Sea / land containers, and one in an area that was *=~pMcally controlled or (2) those containers that were storing SNM and those BU-7 that were empty. De BU-7's that had been loaded eighteen months prior to this event were opened for IWon four momas after their closure, and only minor corrosion was observed at that time; however, nothing approaching a conditum that would constitute a rejection of the package. The:refore, it had been fourteen months since the containers were last opeced for inspection. NNFD also stated that no shipments have tren made with BU.
7's in this condition, and there are no plans to ship the existing BU-7's. It was also determined that the BU-7's at NNFD are the only ones in existence fabricated by NCI, therefore the problem population is believed to have been isolated and controlled. As of 1/18/99, approximately 15 BU-7's had been opened and all exhibited the same general degree of deterioration.
NNFD notified their on-site resident NRC inspector of the situation on 1/13/99. As a result of this action, NRC management was informed of the event, and contacted NNFD for further informatic.2.
On 1/20/99, a BU-7 was cut open at NNFD to inspect the condition of the inner wall of the outer and the outer wall of the inner. Present were representatives from the NRC, Eco Pak, NNFD (who cut open the container) and GE. The conditions on the inner metal surfaces, that were in direct contact with the foam, contained surface rust that did not appear to diminish the wall thickness (see Attachment Ib).
Notwithstanding 10CFR71.43(d), the physical conditions of the packages indicate that these requirements were not met in that a chemical reaction did occur between the package components. De condition is not believed to have had a significant reduction in effectiveness of the package inspected at the time of observation, however, over time, the condition could continue to deteriorate. NNFD has stated that they have attempted to evaluate the condition as required by 10CFR21, and concluded that they cannot detemiine if the corrosion constitutes a substantial safety hazard. At this time, GE does not believe the condition of the BU-7 represents l a substantial safety hazard and therefore, is not a reportable situation under the criteria of l
1 Eco Pak obtained the following information and on 2/1/99 forwarded them to us: ,
- 1) A report dated 2/1/99 from LEIS to Eco Pak that described the analytical processes used and the test results. See Attachment 3.
- 2) A letter dated 1/29/99 from Schenectady Intemational, Inc. to Eco-Pak provided two volumes of a 1969 publication describing the chemistry ofpbenolic foams. See Attachment 6.
DirCClor Office of Nuclear Material Safety & Safeguards February 10,1999 Page 3'of 3 b.
GE has obtained limited infonnation on the white residue and on the chemistry of the resin (see Attachments 4,5 and 7 respectively).
Attachment 8 contains correspondence between GE and Eco-Pak dated 2/3/99 and 2/4/99. This
- w. =;+*=+ involves questions and answers for clarification regarding the foam and paint.
Attachment 9 contains Eco-Pak's letter to the NRC dated I/29/99, reporting the results of their incpection of an unassembled 55-gallon drum that they had in storage at their facility.
Attachment 10 contains GE's' discussion of the BU-7 package based on the findings to date.
At this time, based on the investigations conducted and the information available, we are unable to conclusively state the cause of the white crystalline substance, corrosion or paint blistering.
There is however very clear evidence of the corrosien that took place occurring on all closed packages, packed or unpacked. The white crystalline substance is clearly visible and most likely I is a hydrated form of zine formate. The failure of the protective paint is still unresolved, including veri 6 cation that an ec ,eble paint was used.
There have been several changes in the formulation of the foam over the years, and while physical characteristics and performance have been verified, it does not appear that the chemistry has received attention. The paint may have been changed without adequate evaluation and possibly without sensitivity to its purpose in the package.
Based upon the lack of technical information that would enable GE to develop a recovery and corrective action program, GE respectfully requests the certificate be withdrawn at this time until such time that a root cause(s) and corrective action (s) can be identified. We also request thet the GE submittals to the NRC for the BU-7 dated 12/16/98 and 12/30/98 be withdrawn. Registered users should be so notified and made aware of the conditions detected in these packages.
Sincerely, GE NUCLEAR ENERGY' d M/[ y Charles M.Vaughan, anager Facility Licensing
/zb attachments cc: CMV 99 006 u