ML21014A379

BWXT Nuclear Fuel Services, Inc., 60-Day Written Notification of Event

ML21014A379
Person / Time
Site:	Erwin
Issue date:	12/16/2020
From:	Knowles T BWXT Nuclear Fuel Services, Nuclear Fuel Services
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
21G-20-0151, ACF-20-0311, GOV-01-55-18
Download: ML21014A379 (8)

Text

BW Nuclear Fuel Services, Inc.

CERTIFIED MAIL 21 G-20-0151 RETURN RECEIPT REQUESTED GOV-01-55-18 ACF-20-0311 December 16, 2020 Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: Document Control Desk

Reference:

1) Docket No. 70-143: SNM License 124

2) U.S. NRC Certificate of Compliance No. 9315

Subject:

60-Day Written Notification of Event On November 11, 2020, the Y-12 National Security Complex made notification of an instance in which the conditions in a Certificate of Compliance (Reference Attachment) had not been followed during a shipment from the Nuclear Fuel Services, Inc., (NFS), facility in Erwin, Tennessee. This letter provides the 60-day written notification of that event as required by 10 CFR 71 95(a)(3).

If you or your staff have any questions, require additional information, or wish to discuss this matter further, please contact me or Ms. Amaryl Morie, Licensing Manager, at (423) 743-2579.

Please reference our unique document identification number (21 G-20-0151) in any correspondence concerning this letter.

Sincerely, NUCLEAR FUEL SERVICES, INC.

Tim Knowles Director, Safety and Safeguards BRG/pj

Attachment:

60-Day Notification of Reportable Event 1205 Banner H~I Rd, Erwm, TN 37650 People Strong t + 1 423 7-13 9141 f +1 423 743 0140 wwwnuciearfuel!:ervtees com INNOVATION DRIVEN >

21 G-20-0151 GOV-01-55-18 ACF-20-0311 Page 2 of 8 Copy:

Regional Administrator U.S. Nuclear Regulatory Commission Region II 245 Peachtree Center Avenue, NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Joel Rivera-Ortiz U.S. Nuclear Regulatory Commission Region II 245 Peachtree Center Avenue, NE, Suite 1200 Atlanta, GA 30303-1257 Dr. Robert Williams U.S. Nuclear Regulatory Commission Region II 245 Peachtree Center Avenue, NE, Suite 1200 Atlanta, GA 30303-1257 Mr. James Downs Technical Program Manager Fuel Manufacturing Branch Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety, Safeguards, and Environmental Review U.S. Nuclear Regulatory Commission Two White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Larry Harris NRC Senior Resident Inspector U.S. Nuclear Regulatory Commission

21G-20-0151 GOV-01-55-18 ACF-20-0311 Page 3 of 8 Attachment 60-Day Notification of Reportable Event (5 pages to follow)

21 G-20-0151 GOV-01-55-18 ACF-20-0311 Page 4 of 8 Attachment 60-Day Notification of Reportable Event

1. A brief abstract describing the major occurrences during the event, including all component or system failures that contributed to the event and significant corrective action taken or planned to prevent recurrence.

After being unloaded, closed, and prepared for shipment by Nuclear Fuel Services (NFS), forty (40) empty ES-3100 shipping drums were shipped to Y-12 on September 15, 2020. The NRC Certificate of Compliance for this radioactive material package is Certificate No. 9315, Revision 15. The package identification number is USA/9315/B(U)F-96. After Y-12 began unloading the ES-31 00s on November 4, 2020, Y-12 Refurbishment personnel noted that, on one (1) ES-3100 shipping package, seven (7)pfthe eight (8) outer lid bolts were found not tightened to the required 30 ft-lbs [+5 -5] of torque. The Y-12 Packaging Engineer was notified of the discrepancy on November 9, 2020. NFS was provided written notification on November 11, 2020. This is in violation of the ES-3100 Shipping Package Safety Analysis Report section 7 .1.2.2. No issues were found with the torque of the other outer lid bolt on this ES-3100 or any of the other thirty-nine (39) ES-3100 packages on the shipment. No issues were found with the torque of the inner containment vessel (CV) closure nuts on any of the forty (40) ES-3100 drums on this shipment. Investigations by NFS indicated human failure as the probable cause. Additional administrative controls including an independent torque verification have been established to ensure compliance with torque requirements.

2. A clear, specific, narrative description of the event that occurred so that knowledgeable readers conversant with the requirements of part 71, but not familiar with the design of the packaging, can understand the complete event The narrative description must include the following specific information as appropriate for the particular event (i) Status of components or systems that were inoperable at the start of the event and that contributed to the event; After being sent to Refurbishment, Y-12 personnel observed that seven (7) of the eight (8) outer lid bolts were not tightened to the required 30 ft-lbs [+5 -5] of torque required by the Safety Analysis Report for the ES-3100.

21G-2~151 GOV-01-55-18 ACF-20-0311 Page 5 of 8 (ii) Dates and approximate times of occurrences; NFS delivered the shipment of empty ES-3100s from Erwin, TN, to Oak Ridge, TN, on September 15, 2020. Y-12 made the observation on November 4, 2020, at approximately 14:00 hours while preparing to open the ES-3100. NFS was notified on November 11, 2020, at 12:39 hours.

(iii) The cause of each component or system failure or personnel error, if known; The probable cause was human error (i.e., failure to tighten a bolt to the required amount of torque).

(iv) The failure mode, mechanism, and effect of each failed component, if known; The probable failure mode was a failure to tighten a bolt to the required amount of torque.

(v) A list of systems or secondary functions that were also affected for failures of components with multiple functions; Not applicable to this event.

(vi) The method of discovery of each component or system failure or procedural error; While preparing to open the outer lid from the ES-3100, Y-12 personnel observed that seven (7) of the eight (8) outer lid bolts were not tightened to the required 30 ft-lbs [+5 -5] of torque specified in the Safety Analysis Report for the ES-3100. The NFS investigation team discussed the procedure for tightening outer lid bolts with the Material Handlers along with any previous experiences with similar failures. NFS has not had previous events with meeting the torque requirements for the ES-3100.

(vii) For each human performance-related root cause, a discussion of the cause(s) and circumstances; The probable cause was human error (i.e., failure to tighten a bolt to the required amount of torque). It is a requirement in NFS' procedure for closing ES-3100 packages to tighten outer lid bolts to 30 ft-lbs [+5 -5] of torque.

21 G-20-0151 GOV-01-55-18 ACF-20-0311 Page 6 of 8 (viii) The manufacturer and model number (or other identification) of each component that failed during the event: and, The reference for the ES-3100 is identified by NRG Package Identification Number USA/9315/B(U)F-96.

(ix) For events occurring during use of a packaging, the quantities and chemical and physical form(s) of the package contents.

The ES-3100 (Package Serial Number 61083) was empty.

3. An assessment of the safety consequences and implications of the event This assessment must include the availability of other systems or components that could have performed the same function as the components and systems that failed during the event.

Following is an excerpt from Section 2.4.2 of the Safety Analysis Report for the ES-3100 Shipping Package:

"The ES-3100 package, as delivered for transport, has no tie-down devices that are structural parts of the package. Therefore, the tie-down requirements of 10 CFR 71 .4G are not applicable. Safe tie down and transport of the package is accomplished by methods explained in the Sandia National Laboratory (SNL) Tie-Down Manual [Tie-down Procedures for Type B Containers Shipped in Safe-Secure Trailer/Safeguards Transporter (SST/SG1)] ... Another method of securing the ES-3100 package is by the use of the Cargo-Restraint Transporter (CRT) or Cargo Pallet Assembly (CPA). In these methods, a frame is positioned around the base and top of either five or six packages.

These frames are then chained or locked to the floor as depicted in SNL Tie-Down Manual. Tension is applied to the chains to eliminate any slack.

The downward load resulting from the chain tensioning is insignificant when compared to the compression loading as specified in 10 CFR 71.7(c)(9)."

The ES-3100 for the subject shipment was empty and secured by CRTs such that under Normal Conditions of Transport any potential contents of the ES-3100 would not have been compromised. Additionally, the inner containment vessel has a lid closure nut which was appropriately torqued to 120 ft-lbs [+5 -5]

as required by Section 7.1.2.1 of the Safety Analysis Report (SAR) for the ES-3100 Shipping Package.

21 G-20-0151 GOV-01-55-18 ACF-20-0311 Page 7 of 8

4. A description of any corrective actions planned as a result of the event, including the means employed to repair any defects, and actions taken to reduce the probability of similar events occurring in the future.

1. This event was documented in NFS' Corrective Action Program as Problem 81073.

2. The Checklist for Returning Empty Shipping Containers (FM-WST-010) for ES-3100 Serial Number 61083 was checked and verified that the inner containment vessel closure nut was installed and torqued to 120 ft-lbs, as required by NFS Operating Procedure NFS-WST-026, Section 4.4.7.

3. Interviews were conducted with Transportation and Waste Management Material Handlers regarding any unusual events that may have occurred with ES-3100 61083.

4. Personnel involved in Transportation and Waste Management were briefed on the issue.

5. The Transportation and Waste Management Shipping Unit Manager stopped all outgoing ES-3100 shipments until torque could be verified using a two (2) person independent verification. Transportation and Waste Management Material Handlers, using a Specific Work Instruction (SWI),

perfomied a two (2) party, independent torque verification of all eight (8) outer lid bolts of every ES-3100 currently in the queue for shipment.

These torque verifications have been documented on a pre-populated log and returned to the Transportation and Waste Management Shipping Unit Manager.

6. NFS-WST--026, Handling and Shipping Instruction for the ES-3100 Drum, is being revised to require a second, independent Material Handler to conduct a torque verification of the bolts on the outer lid. During the interim and until this revision is complete, the previously mentioned SWI will be used to accomplish this verification on drums entering the queue for shipment. Subsequent independent torque verifications will be documented on a blank log and turned in to the Transportation and Waste Management Shipping Unit Manager.

5. Reference to any previous similar events involving the same packaging that are known to the licensee or certificate holder.

NFS has not had previous events with meeting the torque requirements for the ES-3100.

6. The name and telephone number of a person within the licensee's organization who Is knowledgeable about the event and can provide additional information.

Steve McKee, NFS Transportation & Waste Shipping Unit Manager, (423) 735-5638.

218-20-0151 GOV-01-55-18 ACF-20-0311 Page 8 of 8

7. The extent of exposure of individuals to radiation or to radioactive materials without identification of individuals by name.

Not applicable to this event.