ML20294A184
| ML20294A184 | |
| Person / Time | |
|---|---|
| Site: | 07109321 |
| Issue date: | 10/20/2020 |
| From: | Gelfond A Energy Solutions |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| ES/NRC 20-004 | |
| Download: ML20294A184 (3) | |
Text
740 Osborn Road, Barnwell, SC 29812 www.energysolutions.com 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
1 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 March 2016 to June 2020 27
- 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:
EnergySolutions Procedure No. CS-FP-PR-016, 3-60B Shipping Cask: Periodic Inspection and Maintenance of Fastener and Threaded Holes 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. to ES/NRC 20-004
2 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:
EnergySolutions has removed 3-60B cask units #1 and #2 from service until appropriate annual inspections are performed.
EnergySolutions has evaluated the condition for reportability under 10CFR 71.95 and has concluded that it is reportable.
EnergySolutions (as the 3-60B cask license holder and periodic maintenance provider) will submit this report to NRC.
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.
EnergySolutions will perform an apparent cause analysis and identify additional corrective actions to prevent reoccurrence.
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 to ES/NRC 20-004