ML23146A041
| ML23146A041 | |
| Person / Time | |
|---|---|
| Site: | Erwin, 07100249 |
| Issue date: | 05/22/2023 |
| From: | Knowles T BWXT Nuclear Fuel Services, Nuclear Fuel Services |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| 38G-23-0012, GOV-01-55-04, ACF-23-0140 | |
| Download: ML23146A041 (1) | |
Text
38G-23-0012 GOV-01-55-04 ACF-23-0140 Nucl e ar Fuel Services, Inc.
CERTIFIED MAIL RETURN RECEIPT REQUESTED May 22, 2023 Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 Attention : Document Control Desk
Reference:
1.) NRC Docket No. 71-0249 2.) NRC Docket No. 70-0143 / SNM-124
Subject:
10 CFR 71.95 60 Day Report, Corrosion on LR-230 (Liquid-Rad Transport Unit)
Dear Sir or Madam,
On March 28, 2023, NRC Inspection personnel identified corrosion on a Liquid Rad Transport Unit (LR-230) (USA/9291/B(U)F-96). The Safety Ana lysis Report for Packaging (SARP), Chapter 7, Operating Procedures, states the unit should not be used if corrosion is discovered on the exterior surface. The NFS operating procedure did not specifically include corrosion on the preload inspection checklist. As a result, LR-230 units were shipped with corrosion present. NFS has determined that this event is reportable per 10 CFR.71.95(b). In accordance with 10 CFR 71.95(c), NFS is providing a written report within sixty days of the discovery of this event (Enclosure 1).
If you have questions concerning this submittal, please contact Thomas Holly, Licensing Unit Manager, at 423.743.2595.
Respectfully, NUCLEAR FUEL SERVICES, INC.
- J4_4,,1"'~
Mr. Timothy A. Knowles, Safety and Safeguards Director TAK/STM/psp
Enclosure:
1.) 10 CFR 71 .95 Report Regarding Corrosion on Liquid-Rad Transport Unit People Strong 1205 Banner Hill Rd, Erwin, TN 37650 t +1.423.743.9141 f* +1.423.743.0140 www.nucle.:1rtuelservices.com INNOVATION DRIVEN >
Enclosure 1 10 CFR 71.95 Report As required by 10 CFR 71.95(c), NFS provides response to the following items:
(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.
No component or system failures are associated with this event report; however, the NFS implementing procedure for package operation did not specifically include "corrosion" as an inspection point on the pre-load checklist. As a result, LR-230 packages were shipped with corrosion present on the exterior surface, which did not demonstrate compliance with the SARP as written. SARP Chapter 7 states, in part: "If the exterior surface is tom or substantially crushed, or if cracks .or corrosion are discovered, the unit should not be used".
On March 28, 2023, during an NRG Transportation Quality Assurance Inspection, the.
NRC Inspector identified corrosion on exterior surfaces of a LR-230 container that was being prepared for loading. Subsequent inspection of a loaded LR-230 trailer indicated similar corrosion on multiple containers. Contrary to the Liquid-Rad Transport Unit Safety Analysis Report for Packaging, Revision 11, Section 7.1.1, pre-loading inspections conducted by NFS personnel were not sufficiently adequate to identify the corrosion. Additionally, NFS operating procedures did not identify the requirement to discontinue use of the container if corrosion was identified during pre-loading inspections. As a result, NFS immediately stopped shipments of the loaded LR-230 trailers pending resolution with the package owner (Westinghouse Electric Corporation) and Certificate Holder (Orano).
(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 incl&de 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; No components or systemsI were inoperable and contributed to the event.
(ii) Dates and approximate times of occurrences; NFS has shipped LR--230 trailers for many years. Initially, NFS shipped three trailers (4906, 4907, and 4908). In 2020, the package owner put three additional trailers into service (4910, 4911, and 4912). NFS makes approximately 2-3 shipments per week to Westinghouse Electric Corporation.
(iii) The cause of each component or system failure or personnel error, if known; This event oQCurred, due to a lack of rigorous adherence to the equipment SARP during development of local operating procedures applicable to the container.
(iv) The failure :mode, mechanism, and effect of each failed component, if known; No failed components contributed to this event.
(v) A list of sys(ems or secondary functions that were also affected for failures of components with multiple functions; No failed components contributed to this event.
. (vi) The method of discovery of each component or system failure or procedural error; Corrosion was identified by NRC Inspection personnel on a container being prepared for loading. Subsequent inspections of other LR-230 trailers by NFS personnel identified additional corrosion.
(vii) For each human performance-related root cause, a discussion of the cause(s) and circumstances; NFS implementing procedures need improvement to capture all SARP inspection criteria, specifically corrosion. Additionally, clarification is required from the certificate holder that will provide registered users information needed to determine operability for continued use until the corrosion can be repaired/refurbished.
(viii) The manufacturer and model number (or other identification) of each component that failed during the event; and No failed components contributed to this event.
(ix) For events occurring during use of a packaging, the quantities and chemical and physical form(s) of the package contents.
Each Liquid-Rad Transport Unit contains up to 230 gallons of a Low Enriched Uranyl Nitrate Solution.
(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 tfJe same function as the components and systems that failed during the event.
Corrosion identified ~n the LR-230 containers was most significant on the carbon steel bracing for the containers and on exterior surfaces surrounding the equipment data
plates. Along the carbon steel bracing plates, corrosion could be described as pitting and blistering. NFS immediately notified the owner of the containers, Westinghouse Electric Corporation and the Certificate Holder, Orano. NFS evaluated the safety significance of historical shipments as low.
(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.
The certificate holder (Orano) is requesting a Special Letter Authorization for continued use. NFS, as a registered user, will use the NRC approved letter as a basis to restart shipments. Additionally, NFS operating procedures will be modified to ensure all SARP requirements are satisfied. Long term corrective actions will be taken by the owner (Westinghouse) to refurbish the units.
(~) Reference to any previous similar events involving the same packaging that are known to the licensee or certificate holder.
NFS does not know of any similar events.
(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.
Thomas Holly, Licensing Unit Manager - 423.743.2595.
(7) The extent of ~xposure of individuals to radiation or to radioactive materials without identification of individuals by name.
No individuals were exposed to radiation or radioactive materials as a result of this event.