ML23020A101

ROI-0704 (MD 8.3) Evaluation - Uusa EN56302

ML23020A101
Person / Time
Site:	07003103
Issue date:	01/09/2023
From:	Robert Williams NRC/RGN-II/DFFI
To:	Louisiana Energy Services, URENCO USA
References
EN56302, IR 2023001, ROI-0704
Download: ML23020A101 (1)

Text

Enclosure 2 Fuel Facility Event Report License No.

SNM-2020 Docket No.

07003103 Event No.

EN56302 NMED Event No.

NA Licensee: Louisiana Energy Services dba URENCO USA (UUSA)

Event Type: Possible loss of a sole IROFS Event Date:

1/5/23 Report Date:

1/5/23 Inspection Report No.:

2023-001

1. REPORTING REQUIREMENT.

( ) 10 CFR 20.2201 (Theft or Loss)

(X) 10 CFR 70 Appendix A (Reportable Events)

( ) 10 CFR 20.2202 (Notification of Incidents)

( ) 10 CFR 71.95 (Transportation Events)

( ) 10 CFR 20.2203 (Dose Limits)

( ) 10 CFR 73.71 (Safeguards Events)

( ) 10 CFR 40.60 (Source Material)

( ) 10 CFR 74.11 (Material Control & Accounting) (

) 10 CFR 70.50 (Radiological Events)

( ) 10 CFR 95.57 (Information Security)

( ) 10 CFR 70.52 (Criticality)

( ) License Condition

( ) Other

2. REPORT EVALUATION. (X) Preliminary

( ) Follow-up

( ) Closeout (X) Timing of Notification: (X) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ( ) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

( ) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

( ) 30 days (X) Reported in accordance with regulations/license conditions: (X) Yes

( ) No (X) Type/Quantity of RAM Involved None (X) Preliminary Occupational Dose None (X) Preliminary Public Dose None

( ) Calculation:

( ) Excessive Radiation Levels or Concentrations

( ) Part 20 Concentrations

( ) Unrestricted Area Contamination (X) Description of Event On Thursday, January 5, 2023, at 11:05 MST, the control room received a call that a crane operator had operated the UBC pad crane (a bridge type crane that runs along rails located at the sides of the UBC pad) over a strap laying on the crane track. The initial inspection of the crane determined that a component of the crane had been damaged. The component was initially identified as a device to sweep debris from the crane rails and not an item relied on for safety (IROFS) related component. At 14:45 MST, a Shift Manager inspected the crane and determined that the damaged component was part of IROFS27e. The damaged component was one of the restraints that prevent the crane from lifting off the rails during a natural phenomena hazard (e.g., a seismic event). These restrains are credited as a sole IROFS with preventing a high consequence accident sequence (i.e., breach of a cylinder).

( ) Cause of Event (X) Immediate Corrective Actions Adequate Yes, moved crane to a safe area.

( ) Potential Severity Level III, II, I

( ) Other

3. REGION II RESPONSE.

( ) Discuss with Criticality Safety Team Inspector/Date

( ) Immediate Site Inspection Inspector/Date

( ) Special Inspection Inspector/Date (X) Telephone Inquiry (with licensee)

Inspector/Date Sippel/Startz on 1/6/23 (X) Review at Next Routine Inspection Inspector/Date OPS Feb 2023

( ) Preliminary Notification Number

( ) Morning Report Number

( ) Medical Consultant

( ) Other Federal/State agencies requested

( ) Not Required

( ) Not Required

( ) Not Required

( ) Not Required (X) Others Informed: (X) NMSS ( ) NSIR ( ) EDO Staff ( ) State ( ) Region

( ) Other

( ) Report Referred to 2

Y/N Initial Deterministic Screening N

1. Led to an Alert or Site Area Emergency Why:

N

2. Involved an event or condition such that the performance requirements of 10 CFR 70.61 were not met, as documented in the ISA summary Why: Potentially, accident sequences EE-SEISMIC and EE-TORNADO & HIGH WIND-SBM-CRDB SHELL-UBC STORAGE PAD credits an IE probability (-2) and IROFS27e (-3) for preventing an assumed high consequence event. IROFS27e was at a minimum degraded. If it was lost, then these sequences would be NOT UNLIKELY per the licensees ISA summary.

However, their operability determination found that the IROFS would still be able to perform its function.

N

3. Involved operations that either exceeded safety limits or were not included in the licensing bases of the facility, safety analysis report, or the ISA summary Why: (N/A if not applicable)

N

4. Involved a major deficiency in design, construction, operation, or programmatic failures having potential generic safety implications Why: (N/A if not applicable)

N

5. Led to the loss of multiple barriers in systems used to mitigate an actual event (e.g.

Process Building exhaust ventilation system)

Why: (N/A if not applicable)

N

6. Led to a significant loss of the plant protection system involved in generating signals associated with the detection of off-normal conditions and events that could threaten safety (e.g. Criticality Accident Alarm System, fire protection system)

Why: (N/A if not applicable)

N

7. Led to a potential or actual radiological release with the potential for occupational exposure or exposure to members of the public in excess of applicable regulatory limits Why: (N/A if not applicable)

N

8. Led to a potential or actual hazardous chemical release with the potential for occupational exposure or exposure to members of the public in excess of applicable regulatory limits AND the chemical was under NRC jurisdiction Why: Based on initial walkdowns.

N

9. Led to a significant loss of physical security controls 3

Why: (N/A if not applicable)

N

10. Involved significant unexpected system interactions Why: (N/A if not applicable)

N

11. Involved repetitive failures or events with safety related equipment or deficiencies in operations performance Why: (N/A if not applicable)

N

12. Involved a potentially significant failure of the safeguards or security system to prevent, detect, or assess and respond to the theft, loss, or diversion of significant quantities of SNM Why: (N/A if not applicable)

N

13. For INFOSEC issues:

i.

The event involved a failure to control classified or safeguards information with substantial potential for disclosure to unauthorized individuals OR ii.

A damage assessment was required to assess the significance of the event.

If YES to either criterion, continue through the event follow-up process to step (3B) Threat and Uncertainty Criteria. If a damage assessment will be performed, consider if an INFOSEC regional inspection (information gathering) is warranted prior to final recommendation for inspection type in Enclosure 2.

Why: (N/A if not applicable)

If YES to any, complete the Why section remarks and continue to step (3B) Threat and Uncertainty Criteria.

If NO to all, Why section remarks are not required but may be added for clarification. Continue to step (3A) No Reactive Inspection Required.

4 Event Follow Up

=

Background===

On Thursday, January 5, 2023, at 11:05 MST, the control room received a call that a crane operator had operated the UBC pad crane (a bridge type crane that runs along rails located at the North and South sides of the UBC pad) over a strap laying on the crane track.

Google Maps photo of the UBC pad. Showing the UBC pad crane (yellow), and the rails it runs along (darker lines on the top and bottom of the pad).

At 14:45 MST, a Shift Manager inspected the crane and determined that the damaged component was part of IROFS27e. The damaged component was one of the restraints that prevent the crane from lifting off the rails during a natural phenomena hazard (e.g., a seismic event, high winds).

These restrains are credited as a sole IROFS in accident sequence EE-SEISMIC and EE-TORNADO & HIGH WIND-SBM-CRDB SHELL-UBC STORAGE PAD with preventing a high consequence event (breach of a cylinder).

Likewise, for accident sequence EE-TORNADO & HIGH WIND-SBM-CRDB SHELL-UBC STORAGE PAD:

5 Initial Screening As reported, this satisfies question 2 of the Initial Deterministic Screening. (Although, an evaluation is being performed to determine if the IROFS is really failed, or just degraded.)

Section 2.a.i of ROI-0704, states, If YES to any, complete the Why section and continue through the event follow-up process to step (3B) Threat and Uncertainty Criteria.

However, with the completion of the licensees operability determination, question 2 is not satisfied, because the performance requirements would still be met.

Threat and Uncertainty Analysis ROI-0704 Enclosure 4A, OPERATIONAL SAFETY, of the Threat and Uncertainty Matrix, is the applicable portion of the Threat and Uncertainty Matrix.

Because the licensees engineering analysis of the seismic restraints determined that they would be able to perform their safety function, then the event is most similar to the following criteria in the Threat and Uncertainty Matrix.

This is because if the licensees analysis determines that the seismic restraints could still perform their safety function then the IROFS is not failed, but degraded, and the performance requirements of 10 CFR 70.61 were still met.

6 Event Management and Licensee Actions The licensee moved the crane into a safe area where it was not above filled UF6 cylinders. The licensee also performed an engineering analysis/operability determination, and found that the cranes remaining restrains would perform their safety function with the damaged component.

Because this event is being managed, management can consider reducing the NRC response (i.e., from AIT to SIT, or from SIT to Routine), as applicable.

Staff Inspection Recommendation Because the licensees engineering analysis of the restraints determined that they would be able to perform their safety function, the details of the licensees response to this event should be inspected during the next routinely scheduled OPS inspection. (Currently scheduled for the week of February 13th, 2023.)

These recommendations are based on:

The criteria in the Initial Deterministic Screening (as informed by the licensees operability determination) the criteria in Enclosure 4A, OPERATIONAL SAFETY, of the Threat and Uncertainty Matrix (see above) the licensee reporting that they moved the crane to a safe area Management Review and Inspection Determination Completed By: Timothy Sippel Date: 1/9/23 Approved By:

Date:

Branch Chief Robert E.

Williams Digitally signed by Robert E.

Williams Date: 2023.01.18 15:29:46 -05'00' Concur with the recommendation to follow-up on the event during the next available onsite inspection