ML22342A380
| ML22342A380 | |
| Person / Time | |
|---|---|
| Site: | 07109294 |
| Issue date: | 12/08/2022 |
| From: | Murray S Global Nuclear Fuel |
| To: | Division of Fuel Management, Document Control Desk |
| References | |
| M220160 | |
| Download: ML22342A380 (1) | |
Text
_Global Nuclear Fuel M220160 December 8, 2022 -
Attn: Document Control Desk.
Director, Division of Fuel Management O_ffice of Nuclear Material Safe~ and Safegu*~q_s US Nuclea,r Regulatory Cemmission Washington, DC 20~55-:00~0f -
Global Nuclear Fuel Scott P. Murray Manager, Facility Licensing 3901 CasUe Hayne Road P.O. Box780
- Wilmington, NC 28492 USA
"( (910) 819~5~50 _
scott.murray@ge.com
Subject:
1 O CFR 71.95 - 60 Day. Report - NPC Certificate Condition of Approval Not Observed
Reference:
Dear Sir or Madam:
Global Nuclear Fuel - Americas, L.L.C. (GNF-A) in Wilmington, NC hereby submits this report for a discovery involving use.of the NPC package in which a condition of approval in USN RC Certificate of Compliance (CoC) (~~ference 1) was not observed. Sp~9ifically, a GNF-A owned NPC pack~ge was s_hipped with a 9ondition that failed to meet the loading requirements as specified in the package safety analysis report and internal procedures.
An evaluation has determined that this event was_of v_ery low _safety significance and there was no release of material while using t_t}_e NPC package yvith this con_dition. All other requiremen_ts of the Coe were met. An internal condition report was opened to track and remedy the cause of the event.
I am the individual knowledgeable about this event and can provide -additional information as needed. If there are any questions regarding this report, please contact me at (910) 819-5950.
Sincerely,
£. Plfi.*
Scott ~Y, Manager ~
Facility Licensing
(/
Attachment Cc: NRG Region II Administrator, Atlanta, GA J. Rivera, USNRC/RII/DPFI J. Rowley, USNRC/NMSS/DFM/FFLB SPM 22-040
USNRC M220160 Dec_ember 8, 2022 Page2 Attachment 10 CFR 71.95-Type A Transportation l>ac~age R~port USA/92~4/AF-~6
-(1 )-Brief abstract describing the maior occurrences -Jfl.95fc}U > - * - - --- -- - --
The NPC package is a cubic metal box used to transport type -A quantities of low-
- enriched uranium oxide powder, pellets, and uranium compQ1,1_nds. It is comprised of _a stainless-steel outer_shell with a three-by-::three *array of cylindrical.cQntainment vessels.
The outer packaging is equipped with atop cover that is secured to-the outer packaging bo9y using closure cap screws arid bolts prior to shipment. lntemat R!:.C!Cedures require
- a visual inspection that the cover"channe[recepfacle ceramfo-lioer braidec:t rope gasket is-in-place and undamaged.
NRC Coe USA/9294AF-96, Revision 9 (and previous revisions), specifies in condition 6(a) that:
6 (a) The pack~ge shall be prepared for shipment and operatecl in accordance with the Operating Procedures in Qhapter 7 of the application.
GNF-A shipped NPC package serial number N-0033 containing low enriched uranium oxide powder to a customer site with a wrench th_at was improperly placed on th~ gasket of the outer packaging body. There were no incidems or accident conditions during the use of the affected package ahd no components* or sy§terris of the package failed.
. (2) Narrative descrjptiqn of the event-__ (Zl,ss,cua>.
i)
Status of component§ or ~ystem§ that were* inoperable at th~ start of the event and that contributed to the event:
Except for the improperly placed wrench, tt,e affected NP packaging was properly prepared by GNF-A in accordance with applicable procedures-and regulations before being shipped. There were no inoperable comJ?onents or systems.
ii)
Dates and approximate times of occurrences.
On October 17, 2022, a foreign customer site notified GNF-A that it discovered a ratcheting wrench improperly placed Q-'1 the Outer Cm1tainment Assembly (OGA) gasket of NPC N-0033. There were no other NPC packages in the shipment with this nonconformance.
iii)
The cause of each component or system failure or per~o!!nef error, if known.
There were no known system or component failures.
iv)
The failure mode, mechanism, and effect of each failed component, if known.
There were no known system or component failures.
v)
A list of systems or secondary functions that were also affected for failures of components with multiple functions.
USNRC M220160-December 8, 2022 Page3 No systems or secondary functions were affected by the improperly placed IJl-'.~ench.:
vi)
The method of discovery of each comporie'!_t or systef1! failf.!re or pro~dural_ e!tot::_
T~e improperly placed wrench was discovered and reported by a foreign customer site.
vii)
For each human performance-related root cause, a discussion of the cause(s) and circumstancfJS.
An inyestigation of the GNF-A package loading procepural requirements determined _
the issu~ was likely caused by a human performance *relat~-~ i~s_ye. rtiere ~~s !10 requirement for a final visual inspection of the top of the OCA for foreign materials prior to lowering the top cover lid into place.
viii)
The manufacturer and model number (or other. identification) of each component that failed during the event.
T-here were no component failures.
ix)
For events occurring during use of a packaging, *the quantities and chemical and physical form(s) of the package contents.
The affected NPC package contained low enriched uranium oxide powder. The radioactive material is in the form of a solld inside an Inner Container Canister Assembly (ICCA). The proper shipping name was RQ, UN3328, Radioactive Material,
- Type A Package, Fissile, Class 7, Solid, Uranium Dioxide (Enrich~d to 20% or less).
(3) Assessment of Safety consequences and lmpljcations of tbe Event -
<Zl,95(c1(3)
The stainless-steel channel receptacle for the braided rope gasket was undamaged; however, the channel was obstructed by the wrench whicfrhad the potential to negatively affect the effectiveness of the seal. Prior to shipment, GNF--A did inspect the channel prior to packing the ICCA with powd_er. A wrench is used in the process as each of the ICCAs is packed with powder and the ICCA lids are installed and band clamps applied. The wrench is used to start the nut on the band clamp. It remained on top of the OCA during the packing process for the ICCAs. Prior to putting the OCA lid in place, all too!s are to be removed and relocated for use at th~ nexfNPC to be packed at.an adjacent station.
An evaluation determined that a box wrench in the seal may allow water penetration thrqugty the seal if subjected to a water spray or immersion. Howe_ver, this wa~ not the case for this shipment and the Criticality Safety analysis considers water intrusion into tt)e NP9 foam area. $0 had any water leaked into the NPC fo_ar:n area d~e to tbe box
- wrench, the condition is bounded by the Criticality Safety Analysis of Record. The primary uranium powder containment boundary is the ICCA with its lid and band clamp.
The presence of the box wrench had no effect on the ICCA containment boundary. The SAR thermal analysis modeled the ceramic rope as missing completely and a 1/8" gap between the lid and the container. This was not the case. Further, the safety class for ttie c9mponent is B, indicating that it needs a secondary failure, and the safety quality assessment of record shows that a failure of the braided rope gasket still needs a
USNRC M220160 December 8, 2022 Page4 secondary failure of the OCA before it would create a safety concern. Since the secondary failure was presumably not present, there was not a safety concern, even if a Hypothetical Accident Condition had occurred.
A 1 O CFR 21 evaluation was also performed to determine if the condition could have created a substantial safety hazard or contribute to exceeding a technical specification safety limit. Since the NPC safety analysis report modelled the OCA gasket as missing completely and the primary containment boundary is the ICCA, the yvrench had no effect on the containment boundary. As a result, no substantial safety hazard or technical specification violation exists as a result of the condition and no additional 1 O CFR 21 reporting is required.
(4) correctjye actjons taken - (71,95(c)(4)
- 1) An _internal condition report (CR 40767) was opened to tra(?l< and remedy the cause of th~. event.
Complete:
October 17, 2022
- 2) GNF-A will revise the NPC package operating procedure to perform a final visual inspe.ction of the OCA top for any foreign materials prior to lowering the OCA lid assembly into place.
Scheduled Completion:
January 31, 2023 (5) Reference to any preyjoys sjmnar events - (71.9S(c)(s) * *-
None (6) contact - CZl,9s(c)(§)
Please contact Scott Murray at (910) 819-5950 for any additional information about this report.
(7) Extent of Exposure to Radjatjon - CZl,95(c)(Z).
No individuals were exposed to radiation or radioactive material due to this issue.
There was no leakage of contents due to the nonconformance.