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
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
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 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.
1
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:
- 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 2