ML22147A141
| ML22147A141 | |
| Person / Time | |
|---|---|
| Site: | 07105797 |
| Issue date: | 05/18/2022 |
| From: | Iddins B Oak Ridge, US Dept of Energy (DOE) |
| To: | Johari Moore Office of Nuclear Material Safety and Safeguards, Oak Ridge, US Dept of Energy (DOE) |
| P SAVEROT NMSS/DFM/STLB 3014157505 | |
| Shared Package | |
| ML22147A140 | List: |
| References | |
| DE-AC05-00OR22725 | |
| Download: ML22147A141 (12) | |
Text
ENCLOSURE 1 Oak Ridge National Laboratory, UT-Battelle, LLC Notification Report in 10 CFR 71.95 Format Regarding Errors Identified in HFIR Fresh Fuel Shipping Container Certification Drawing Referenced in Certificate of Compliance No. 5797 10 CFR 71 Packaging and Transportation of Radioactive Material
§71.95 Reports.
(a) The licensee, after requesting the certificate holder's input, shall submit a written report to the Commission of -
(3) Instances in which the conditions of approval in the Certificate of Compliance were not observed in making a shipment.
10 CFR 71.95(c) identifies reporting requirements for NRC packaging for consistency and completeness the following information is provided:
(c) These written reports must include the following:
(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.
On 3/25/2022, ORNL Quality Assurance identified nonconformances of the as-built Tie Down Band (TDB) hardware configuration and components relative to its drawing, M-20978-EL-008E, Rev. C, Shipping Container for Unirradiated Out/In HFIR Element Details. The TDB (M-20978-EL-008E, Parts List Find No.
5 and 6) is an optional accessory for blocking and bracing a HFIR Shipping Container in the transport vehicle. The specific non-conformances relative to M-20978-EL-008E, Rev. C, are detailed below:
- Size of the shackles (2 places) in the as-built configuration do not conform to the drawing: In View B-B, the 3/4-inch shackle with welded pin was found to be a 7/16-inch shackle in the field; and the 1-inch shackle in View B-B was found to be a 5/8-inch shackle in the field.
- Orientation of the shackles (2 places) on the drawing is incorrect:
o The orientation of the 3/4-inch shackle in View B-B is shown with its bow through the tab hole on the TDB and its pin connected to the bow of the 1-inch shackle. This orientation is incorrect because the ear or pin of a 3/4-inch shackle would be too large to pass through the tab hole (9/16 inch).
o The orientation of the shackles on the as-built configuration is correct but does not conform to the drawing. The pin of the 7/16-inch shackle is installed through the tab hole on the TDB and its bow is connected to pin of the 5/8-inch shackle.
- Thickness of the TDB end tabs (4 places) on the as-builts do not conform to the drawing: The end tab thickness shown in Section A-A is 1/2 inch, whereas the end tab thickness on the as-built TDB is 1/4 inch.
The immediate actions taken were notification of registered users and ceasing use of the shipping containers. The corrective action will be to update the subject drawing to eliminate the discrepancy in the next revision of the SAR (Safety Analysis Report for Packaging the ORNL HFIR Unirradiated Fuel Element Shipping Container, ORNL/TM-11656).
(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.
There were no components or systems that were inoperable or that contributed to the event.
(ii) Dates and approximate times of occurrences.
The error was identified on March 25, 2022, at approximately 12:00 ETZ (iii) The cause of each component or system failure or personnel error, if known.
There were no component or system failures. However, the design drawing M20798EL008E is incorrect and cannot be built as drawn.
(iv) The failure mode, mechanism, and effect of each failed component, if known.
There were no component failures.
(v) A list of systems or secondary functions that were also affected for failures of components with multiple functions.
There were no component failures or effects to systems or secondary functions.
(vi) The method of discovery of each component or system failure or procedural error.
ORNL Quality Assurance identified nonconformances of the as-built TDB while consulting with fabrication staff.
(vii) For each human performance-related root cause, a discussion of the cause(s) and circumstances.
From a user point of view, there were no human performance-related causes for this discovery.
(viii) The manufacturer and model number (or other identification) of each component that failed during the event; and There were no failed components.
(ix) For events occurring during use of a packaging, the quantities, and chemical and physical form(s) of the package contents.
No event occurred leading to the discovery of the drawing errors. Following the discovery of the nonconformances with the TDB, registered users of the package were notified by ORNL to suspend use of the packaging pending further evaluation. ORNL confirmed that there were no packages in transit when the error was identified.
(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.
No components or systems failed.
The TDB is not a structural part of the package and is not a credited safety component in the SAR (Rev. 11) or NRC CoC No. 5797 (Rev 22). The HFIR package design meets the requirements of 10 CFR Part 71, Subpart E, Package Approval Standards, without the TDB.
SAR - The TDB is not credited or evaluated in the SAR as an important-to-safety packaging component for HFIR Shipping Containers. In other words, the package does not rely on the TDB to meet Subpart E. However, the TDB is shown and referenced on three SAR/CoC drawings:
- M-20978-EL-002E, Rev E - Parts List Find No. 17 and Section A,
- M-20978-EL-003E, Rev F - Parts List Find No. 16 and Section A, with a note For Shipping Purposes Only, and
- M-20978-EL-008E, Rev. C - Parts List Find Nos. 5 & 6 (for the HFIR Inner and Outer Shipping Containers) and Tie Down Band with Section A-A and View B-B.
Use of the TDB is optional per the SAR, Chapter 7, Section 7.1 Step 11 (see below) and the TDB is referred to as the removable shoring ring:
- 11. HFIR unirradiated fuel element container when loaded with fuel, are shipped off-site in a "sole-use" vehicle. The HFIR fuel element container is provided with a removal shoring ring which may be used to shore or tiedown the container
during shipments. Appropriate shoring shall be used in the transportation of those containers.
The as-built configuration of the TDB, although not compliant with the SAR drawing, is appropriate shoring (i.e., blocking and bracing) based on the safe shipping history of HFIR Shipping Containers since at least c.1989. The maximum gross weight of the HFIR Shipping Container is 1,050 lb. The working load limit of a 7/16-inch shackle is approximately 1-1/2 metric tons (3,300 lb.), so with two 7/16-inch shackles per TDB, the shoring is appropriate for transportation of the containers.
CoC 5797 - The TDB detail is shown on Drawing M-20978-EL-008E, Rev. C and this drawing is explicitly referenced in CoC Section 5(a)(3)(i) and 5(a)(3)(ii) with the HFIR Inner and Outer Shipping Containers drawings.
Despite the non-conformance of the as-built TDB with its drawing, the as-built configuration meets the requirements of CoC Condition 7(b):
(b) Each package shall be operated and prepared for shipment in accordance with the Operating Procedures in Chapter 7 of the application.
That is, the as-built configuration of the TDB is appropriate shoring (i.e., blocking and bracing) therefore meets the Operating Procedures in Chapter 7 (Step 11), based on the safe shipping history of HFIR Shipping Containers since at least c.1989.
(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.
- ORNL has issued a non-conformance report on the as-built TDBs in accordance with its Quality Assurance Program and is revising HFIR drawing M-20978-EL008E, Rev. C, Shipping Container For Unirradiated Out/In HFIR Element Details, to match the field configuration.
- ORNL prepared an application for a letter amendment for DOE for submittal to NRC to authorize use of the as-built TDB. The letter amendment was submitted on April 8, 2022 (ADAMS Accession No: ML22101A250) and issued by NRC on April 15, 2022 (ML22105A053).
- ORNL will prepare a SAR amendment to correct, clarify, or remove the TDB from the SAR since it is not a credited packaging component.
(5) Reference to any previous similar events involving the same packaging that are known to the licensee or certificate holder.
There are no known similar events that relate to the 5797 packages.
(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.
Primary ORNL Technical Point of
Contact:
Brandon Kendrick (865) 576-8597 (7) The extent of exposure of individuals to radiation or to radioactive materials without identification of individuals by name.
There is no radiation or radioactive material exposure as a result of this discovery.
ENCLOSURE 2 LETTER FROM NRC RE:
AUTHORIZATION FOR SHIPMENTS OF FRESH FUEL USING THE MODEL NO. INNER HFIR UNIRRADIATED FUEL ELEMENT SHIPPING CONTAINER, AND OUTER HFIR UNIRRADIATED FUEL ELEMENT SHIPPING CONTAINER
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 15, 2022 Dr. James M. Shuler Manager, DOE Packaging Certification Program U.S. Department of Energy Office of Packaging and Transportation EM-4.24, 270CC - Rm 3113 Washington, DC 20585
SUBJECT:
AUTHORIZATION FOR SHIPMENTS OF FRESH FUEL USING THE MODEL NO. INNER HFIR UNIRRADIATED FUEL ELEMENT SHIPPING CONTAINER, AND OUTER HFIR UNIRRADIATED FUEL ELEMENT SHIPPING CONTAINER
Dear Dr. Shuler:
As requested by your letter dated April 8, 2022 (ADAMS Accession No: ML22101A250),
pursuant to Title 10 of the Code of Federal Regulations Part 71, the Certificate of Compliance (CoC) No. 5797, Revision No. 22, for the Model No. Inner HFIR (High Flux Isotope Reactor) unirradiated fuel element shipping container and outer HFIR unirradiated fuel element shipping container package is amended to authorize shipments, as follows:
(1) Authorization is for an unlimited number of shipments of fresh fuel to the High Flux Isotope Reactor to support continued operations.
(2) The package may be used with the as-built configuration of the Tie Down Band with its design shown on licensing drawings (M-20978-EL-008E, Rev. C, M-20978-EL-002E, Rev. E, M-20978-EL-003E, Rev. F, as referenced in Condition Nos. 5(a)(3)(i) and 5(a)(3)(ii) of the CoC.
(3) All other conditions of CoC No. 5797 shall remain the same.
(4) This authorization shall expire on January 31, 2023.
J Shuler 2 If you have any questions regarding this authorization, please contact Pierre Saverot of my staff at (301) 415-7505.
FOR THE U.S. NUCLEAR REGULATORY COMMISSION Signed by Diaz-Sanabria, Yoira on 04/15/22 Yoira K. Diaz-Sanabria, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-5797 EPID L-2022-LLA-0054
Enclosure:
Safety Evaluation Report cc w/encl: R. Boyle, Department of Transportation
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION REPORT U.S. Department of Energy Docket No. 71-5797 Model No. Inner HFIR Unirradiated Fuel Element Shipping Container, and Outer HFIR Unirradiated Fuel Element Shipping Container
SUMMARY
The High Flux Isotope Reactor (HFIR) Unirradiated Fuel Element Shipping Container is a Type B(U)F package, with contents described as U3O8 -Al cermet, enriched up to 95% in U235, and clad in aluminum.
After identifying nonconformances of the as-built Tie Down Band (TDB) hardware configuration and components with respect to the licensing drawings referenced in the Certificate of Compliance (CoC) No. 5797, Rev. 22 (Docket 71-5797), the Department of Energy (DOE), by letter dated April 8, 2022, requested the authorization to continue shipments to the HFIR reactor in order to avoid significant impacts to reactor operations.
The package loading procedure refers to the Tie-Down Band as an optional accessory, i.e., a shoring ring, provided with the HFIR Shipping Container, to either shore or tie down the package on the transport vehicle. The TDB is not a packaging component, i.e., it is not a structural part of the package and, as such, is not credited for safety.
The applicant is issuing a nonconformance report on the as-built TDB, is revising Drawing M-20978-EL-008E, Rev. C, is drafting a 71.95 report, and is preparing an amendment request that will be submitted within the next few months along with a CoC renewal request.
The as-built configuration of the TDB, although not compliant with the SAR drawings, has no adverse impact on the safety of the package: therefore, it does not affect the packages ability to meet all requirements in the regulations. Thus, the staff agrees on the continued use of the package for shipments to the HFIR reactor.
Based on the statements and representations in the application, the staff finds that the applicants request for continued shipments with the as built configuration of the TDBs does not affect the ability of the Model No. Inner HFIR Unirradiated Fuel Element Shipping Container, and Outer HFIR Unirradiated Fuel Element Shipping Container package to meet the requirements of 10 CFR Part 71.
EVALUATION On March 25, 2022, the applicant identified nonconformances of the as-built Tie Down Band (TDB) hardware configuration and components with respect to the licensing drawing, M-20978-EL-008E, Rev. C, Shipping Container for Unirradiated Out/In HFIR Element Details:
Enclosure
2
- A 3/4 -inch shackle with a welded pin was found to be an as built 7/16 -inch shackle; a 1-inch shackle had an as built size of 5/8- inch.
- The orientation of the shackles is incorrect on the drawing while it is correct on the as-built configuration but does not conform to the drawing.
- The thickness of the TDB end tabs is 1/2 inch, whereas it is 1/4 inch on the as-built TDB.
The applicant stated that the TDB is not a structural part of the package and is not a credited safety component: as such, the HFIR package design meets the requirements of 10 CFR Part 71 without the TDB.
However, the applicant recognized that, because the TDB is shown on three drawings referenced in the CoC (M-20978-EL-002E, Rev E; M-20978-EL-003E, Rev F, and M-20978-EL-008E, Rev. C), it can be construed that the conditions of approval in the CoC were not observed in making the shipments.
The applicant also noted that the as-built configuration of the TDB, although not compliant with the drawings, has a 32-year history of safe shipments with the HFIR Shipping Containers and that the working load limits of the as built shackle is still appropriate for the transportation of the containers. As such, failure of the as-built TDB will not affect the packages ability to meet all the requirements in the regulations.
The staff finds that this request to use the as-built TBD for shipments of the HFIR Shipping Containers has no adverse impact on public health and safety.
Based on the discussion above, the staff found the applicants request for continued shipments using the as built TBDs does not affect the ability of the Model No. HFIR Unirradiated Fuel Element Shipping Container, and Outer HFIR Unirradiated Fuel Element Shipping Container package to meet 10 CFR Part 71 requirements.
CONDITIONS (1) Authorization is for an unlimited number of shipments of fresh fuel to the High Flux Isotope Reactor to support continued operations.
(2) The package may be used with the as-built configuration of the Tie Down Band with its design shown on licensing drawings (M-20978-EL-008E, Rev. C, M-20978-EL-002E, Rev. E, M-20978-EL-003E, Rev. F, as referenced in Condition Nos. 5(a)(3)(i) and 5(a)(3)(ii) of the CoC.
(3) All other conditions of CoC No. 5797 shall remain the same.
(4) This authorization shall expire on January 31, 2023.
CONCLUSIONS Based on the statements and representations in the letter dated April 8, 2022, the staff agrees that the use by DOE of the Model No. Unirradiated Fuel Element Shipping Container, and Outer HFIR Unirradiated Fuel Element Shipping Container package meets the requirements of 10 CFR Part 71, subject to the conditions listed above.
Issued on April 15, 2022.