ML23282A008
| ML23282A008 | |
| Person / Time | |
|---|---|
| Site: | 07109372 |
| Issue date: | 10/09/2023 |
| From: | Travis Tate Framatome |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| TJT:23:024 | |
| Download: ML23282A008 (1) | |
Text
framat o me
October 9, 2023 T JT:23:024
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards Washington, D.C. 20555-0001
Subject:
10 CFR 71.95 - 60 Day Report - TN-81 Certificate Not Followed
References:
(1) NRC Certificate of Compliance (CoC) USA/9372/B(U)F-96, Docket Number 71-9372.
Dear Sir or Madam,
Pursuant to 10 CFR 71.95(a)(3), Framatome Inc. (Framatome) submits this report for self-identification of instances where Framatome made multiple shipments of unirradiated fuel assemblies which the conditions of approval in the Certificate of Compliance (CoC) were not observed in making a shipment for the NRC approved Type B package. Framatome is the certificate holder for this packaging.
On September 27 th, 2023, Framatome engineering self-identified an error between the TN-B1 licensing drawing FS1-0042705 Rev. 1 approved in the Certificate of Compliance (CoC) USA/9372/B(U)F-96 Rev. 3 and the previous licensing drawing, 105E37 45 Rev. 8 included since in the original approval. The error increased the number of plug welds required on the inner container to a value greater than the number of plug welds made on all as built TN-B1 packaging's. This error puts the entire fleet of TN-B1 packaging's into a state of non-compliance.
The attachment to this letter provides the required details for the report.
Please feel free to contact me at (509) 375-8550 or Bryan Flanagan of my staff at (509) 375-8537 if you have questions or need additional information.
Frarnatorn e I nc.
2101 Horn Rapid s Road Ric hland, WA 99354 Tel: (509) 375-8100
www.fran1 a ton1 e. com framat o me T JT:23:024 Page 2 of 6
Sincerely,
~:.-~~
Timothy J. Tate, Manager Environmental, Health, Safety and Licensing
T JT/sm
Attachments: 10 CFR 71.95 - Type B Transportation Package Report (USA/9372/B(U)F-96)
cc:
Pierre Saverot, Project Manager, NRC Bernard White, Senior Project Manager, NRC
Framato m e Inc.
2101 Horn Rapids Road Richland, WA 99354 Tel: (509) 375-8100
www.framatome.com framat o me TJT:23:024 Page 3 of 6
Attachment
10 CFR 71.95-Type B Transportation Package Report (USA/9372/B(U)F -96)
- 1. Brief abstract describing the major occurrences 71.95(c)(1)
The TN-B1 package is used to transport unirradiated fresh fuel assemblies, both channeled and unchanneled, with a U-235 mass percentage not to exceed 5 weight percent.
On September 27 th, Frainatome engineering identified an error on a TN-B1 inner container licensing drawing. The drawings identified in the Certificate of Compliance, USA/9372/B(U)F-96, Revision 3, includes in section 5(a)(3), drawing FS1-0042705, Rev. 1. View Kon sheet 3 of this drawing calls out a plug weld with a pitch distance of 200 mm which requires more plug welds than exists on the as built TN-B1 packaging's. The correct pitch distance should be 600 mm.
The 600 mm pitch agrees with the previously approved drawing 105E37 45 Rev. 8 and with the manufacturing drawings.
,--- --;lE------ 7X
_,,---~ '---- 7X
- -----,--c---- 7X P=200 7X--->l*(--~ ----..______ NOMINAL
K (1 : 1)
(SH EET2 )
Current FS1-0042705 Rev. 1 Drawing
Fra m a tome Inc.
2 101 Horn Rap ids Road Ric h la n d, WA 99354 Tel: (509) 375-8100
www.fr a m a tom e.com framat o me T JT:23:024 Page 4 of 6
- 7 PLACES
~ 7 PLACES
1 5 P LACES~ / ~~-- 7 PLACES P=600 NOMINAL
7 PLAC ES
DETAIL K
( S=1 /2)
Original 105E37 45 Rev. 8 Drawing
- 2. Narrative description of the event, 71.95(c)(2)
(i) Status of components or systems that were inoperable at the start of the event and that contributed to the event;
There were no inoperable components or systems.
(ii) Oates and approximate times of occurrences;
FS1-004075 Rev. 1 was approved on August 10, 2022 within the Certificate of Compliance, Docket Number 71-9372, Revision 3. Approximately 61 shipments have been completed without incident since the error was approved.
(iii) The cause of each component or system failure or personnel error, if known;
The drawing error is believed to be a typo in which the weld pitch value was inadvertently changed from 600 to 200 when this new drawing was created within the Framatome drawing system.
(iv) The failure mode, mechanism, and effect of each failed component, if known;
There is no effect to the packaging due to this drawing error. The packaging is in compliance with the correct weld pitch value of 600 mm.
Frarn a to rn e I nc.
210 1 Ho rn Rapid s Road Rich land, WA 99354 Tel: (509 ) 375 -8 100
www.fra m ato m e.co m framat o me T JT :23:024 Page 5 of 6
(v) A list of systems or secondary functions that were also affected for failures of components with multiple functions;
No systems or secondary functions were affected for failures.
(vi) The method of discovery of each component or system failure or procedural error;
The licensing drawing error was identified by Framatome engineering during review of previous changes to the licensing drawings.
(vii) For each human performance-related root cause, a discussion of the cause(s) and circumstances ;
The root cause for the drawing error is attention to detail. There are several other weld call-outs on the same drawing that have a weld pitch of 200. This error was missed by the drafter, reviewer, and approvers.
(viii) The manufacturer and model number (or other identification) of each component that failed during the event;
There 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 TN-B1 packages (USA/9372/B(U)F-96) may be shipped with either one or two unirradiated fuel assemblies or up to 130 loose rods. Solid uranium oxides or uranium carbide fuel rods enriched to no more than 5.0 weight percent U-235.
The proper shipping name typically used is: UN3328, Radioactive Material, Type B (U) Package, Fissile, Class 7, (2.2). The contents include solid uranium dioxide in fuel assemblies, uranium enriched to 20% or less. The non -flammable gas subsidiary hazard is for the pressurized he lium gas within the fuel rods.
Framatome In c.
2101 Horn Rap ids Road Ric hla nd, WA 99354 Tel: (509) 375 - 8100
www.fr a matome.com framat o me T JT:23:024 Page 6 of 6
- 3. Assessment of Safety Consequences and Implications of the Event, 71.95(c)(3)
There is no failure and no safety consequence to the drawing error.
- 4. Corrective actions taken, 71.95(c)(4)
TN - B1 inner container, RB-090, was inspected and the plug weld pitch dimension in question was confirmed to be 600 mm.
Review of all licensing drawings with emphasis on Framatome converted drawings was performed and no other errors were identified. Minor points of clarification were identified for correction in FS1-0042075.
- 5. Reference to any previous similar events, 71.95(c)(5)
There are no previous or similar events identified with this non-conformance.
- 6. Contact, 71.95(c)(6)
Please contact Timothy Tate at (509) 375-8550 for any additional information regarding this report.
- 7. Assessment of Safety Consequences an Implications of the Event, 71.95(c)(7)
No individuals were exposed to radiation or radioactive material due to this event.
There was no leakage of contents due to the non-conformance and no reduction in the performance of the packaging.
Framatorn e Inc.
2101 Ho rn Rap ids Road Ric h la nd, WA 99354 Tel: (509) 375-8100
www.fran1ato1ne.com