ML24005A241
| ML24005A241 | |
| Person / Time | |
|---|---|
| Site: | 07109309 |
| Issue date: | 01/05/2024 |
| From: | Murray S Global Nuclear Fuel |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| M240003 | |
| Download: ML24005A241 (1) | |
Text
GNi=
Global Nuclear Fuel M240003 January 5, 2024 Attn: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards US Nuclear Regulatory Commission Washington, DC 20555-0001 Global Nuclear Fuel Scott P. Murray Manager, Facility Licensing 3901 Castle Hayne Road P.O. Box 780 Wilmington, NC 28402 USA T (910) 819-5950 scott.murray@ge.com
Subject:
10 CFR 71.95 - 60 Day Report - RAJ-II 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 RAJ-II package in which a condition of approval in USN RC Certificate of Compliance (CoC) (Reference 1) was not observed. Specifically, a GNF-A owned RAJ-II package was shipped with a condition that failed to meet the requirements for a packaging component (inner container lid bolts) as required in the package safety analysis report and internal procedures.
An evaluation has determined that this event was of very low safety significance and there was no release of material while using the RAJ-II package with this condition. All other requirements of the CoC 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. Inhere are any questions regarding this report, please contact me at (910) 819-5950.
Sincerely, sd~ M&ge(f)~
Facility Licensing Attachment Cc: NRC Region II Administrator, Atlanta, GA J. Rivera, USNRC, RII J. Rowley, USNRC, NMSS SPM 24-003
US NRC M240003 January 5, 2024 Page2 Attachment 10 CFR 71.95-Type B Transportation Package Report USA/9309/B(U)F-96 (1) Brief abstract describing the major occurrences - {71.95(c)(1)
The RAJ-I I package is a rectangular metal box used to transport a maximum of two unirradiated boiling water reactor (BWR) finished fuel assemblies. It is comprised of one inner container (IC) and one outer container (OC), both made of stainless steel. The IC is composed of a double wall stainless steel structure with an alumina silicate thermal insulator filling the gap between the two walls. Both the IC and OC have a removable top lid to allow loading of the contents that are reinstalled and secured with bolts prior to shipment. Internal procedures require these bolts to be securely tightened to a specified torque.
NRC CoC USN9309/B(U)F-96, Revision 14 (and previous revisions), specifies in condition 6(a) that:
6 (a) The package shall be prepared for shipment and operated in accordance with the Package Operations of Chapter 7 of the application.
GNF-A internal procedure OP 1050.70.202, Rev 16 "Fuel Bundle Packing - Packing Channeled Fuel Bundles" requires the IC top lid bolts to be installed and tightened.
On November 5, 2023, GNF-A shipped RAJ-II inner container serial number RB-2180 containing unirradiated fuel assemblies to a domestic customer reactor site without the required 10 IC top lid bolts being installed and tightened. There were no incidents or accident conditions during the use of the affected package and no components or systems of the package failed.
(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; Except for the IC top lid bolts, the affected RAJ-II packaging was properly prepared by GNF-A in accordance with applicable procedures and regulations before being shipped.
There were no inoperable components or systems.
ii)
Dates and approximate times of occurrences; On November 7, 2023, the customer reactor site notified GNF-A that it discovered the IC top lid bolts on RB-2180 were not installed as required. There were no other RAJ-II packages in the shipment that had this nonconformance.
iii)
The cause of each component or system failure or personnel error, if known; There were no known system or component failures.
US NRC M240003 January 5, 2024 Page 3 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; No systems or secondary functions were affected by the improperly installed IC top lid bolts..
vi)
The method of discovery of each component or system failure or procedural error; The improperly installed IC top lid bolts were discovered and reported by a customer reactor site.
vii)
For each human performance-related root cause, a discussion of the cause(s) and circumstances; An investigation of the GNF-A loading procedural requirements determined the issue was likely caused by a human performance related issue. A second verification associated with visually confirming the IC top lid bolts were installed also failed.
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 affected RAJ-II package contained two unirradiated boiling water reactor (BWR) finished fuel assemblies. The radioactive material is in the form of solid ceramic pellets with limited solubility and minimal propensity to suspend in air. The proper shipping name was RQ, UN3328, Radioactive Material, Type B(U) Package, Fissile, Class 7, Solid, Uranium Dioxide (Enriched to 20% or less).
(3) Assessment of Safety Consequences and Implications of the Event -
(71.95(c}(3}
Per the RAJ-I I safety analysis report, the primary containment of the uranium dioxide fuel inside the package is the fuel rod cladding. The cladding is verified as leak tight prior to any shipment. The RAJ-II is constructed of two non-containment structures, the OC and IC. Both the OC and IC are designed to protect the fuel assemblies and fuel rod cladding to maintain containment during accident conditions. The OC consists of a metal wall with shock absorbing devices and vibration isolation mounts for the IC with a primary function of mechanical protection. The IC's main function is to provide thermal support but also does provide some mechanical protection.
Both the IC and OC top lid bolts are safety category B per NUREG/CR-6407 meaning another component must also fail to create an unsafe condition. There are a total of 24 OC top lid bolts, and all were installed and securely tightened in this case. A technical
US NRC M240003 January 5, 2024 Page4 evaluation of the impacts of this condition to general package requirements and accident testing conditions concluded that the effectiveness of the package was not significantly reduced due to the missing IC top lid bolts. This conclusion was based on the following:
No other package deviations with the fact that this is a Level B safety item (2 or more items must fail).
The redundant structure of the IC and OC containers, along with the integrity of the remaining structure (bolts, vibro-isolation bars, and shock absorbers).
A 10 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 24 outer top lid bolts are sufficient to meet the intended function of the mechanical interface, no substantial safety hazard or technical specification violation exists as a result of the condition. As a result, no additional 10 CFR 21 reporting is required.
(4) Corrective actions taken or planned - {71.95{c){4)
- 1) An internal condition report (CR 44166) was opened to track and remedy the cause of the event.
Complete:
November 8, 2023
- 2) Perform a non-conformance assessment to identify causal factors and recommend preventive actions.
Complete:
December 19, 2023
- 3) RAJ-I I packages prepared for shipment prior to November 8, 2023, and still onsite were released for shipment by the responsible quality function based on visual inspection verifications of the IC top lid bolts.
Complete:
December 21, 2023
- 4) Revise fuel bundle packing internal procedures (OP 1050.70.202 and OP 1050. 70.205) to clarify verification instructions and control requirements.
Scheduled completion:
February 15, 2024 (5) Reference to any previous similar events - {71.95{c){5)
None (6) Contact - {71.95{c){6}
Please contact Scott Murray at (910) 819-5950 for any additional information about this report.
(7) Extent of Exposure to Radiation - {71.95{c){7}
No individuals were exposed to radiation or radioactive material due to this issue. There was no leakage of contents due to the nonconformance.