ML24227B012
| ML24227B012 | |
| Person / Time | |
|---|---|
| Site: | 07109196 |
| Issue date: | 08/17/2024 |
| From: | Storage and Transportation Licensing Branch |
| To: | TN Americas LLC |
| Shared Package | |
| ML24227B011 | List: |
| References | |
| Download: ML24227B012 (1) | |
Text
10 CFR 71.95 REPORT EVALUATION FORM Docket No.: 71-9196 Package Model No.: UX-30 Report Submitted By: TN Americas LLC Report Date: May 10, 2024 Report ADAMS Accession No.:
ML24131A065 Review the incoming report to determine if additional Commission or staff action is warranted. The review should consider whether the report identifies a generic defect or problem with the package design and the safety significance of the issue.
Note that a high safety significance represents a potential for significant radiation exposure, medium safety significance represents a potential for some moderate radiation exposure, and low safety significance represents little or no potential for radiation exposure.
- 1. The report identifies:
Significant reduction in the effectiveness of a package during use.
Defect with a safety significance.
Shipment in which conditions of the approval were not observed.
- 2. What is the safety significance? ___ High
__ Medium Low
- 3. Summary of the report:
Attached to this letter, TN Americas LLC (TN) submitted two reports pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 71.95, Reports. One report states that 30-inch cylinders fabricated, inspected, tested, and maintained after issuance of the 2019 and 2024 revisions to American Nationals Standards Institute (ANSI) 14.1, Uranium Hexafluoride Packagings Transport, may have been shipped that were in compliance with one of the newer version of the standards instead of the 2012 revision that is called out in revisions of Certificate of Compliance No. (CoC) 9196 for the Model No. UX-30. TN noted that this requirement conflicts with regulations issued by the U.S. Department of Transportation (DOT) in 49 CFR 173.420, Uranium hexafluoride (fissile, fissile excepted and non-fissile). DOTs regulations require that Packagings must be designed, fabricated, inspected, tested and marked in accordance with American National Standard N14.1 in effect at the time the packaging was manufactured. DOTs regulations incorporate-by-reference versions of ANSI N14.1 up to the 2001 revision, not the 2012 version of ANSI N14.1.
The second report states that there are packages in service for which the shear lug shown on UX-30 Drawing No. C-110-B-57922-001, Rev. 4, which is referenced in the CoC for the UX-30, was fabricated using a different material. The drawing shows that the material for sheet, bar, and plate components, which includes the shear lug since it is fabricated from plate material, must be Type 304 ASTM International material A240, however the fabrication drawing shows that the sheet, bar, and plate components can be fabricated from either ASTM A240 or ASTM A479. TN determined the cause to be that the ASTM material requirements were not adequately transferred from the approved licensing drawing to the associated fabrication drawing.
2 10 CFR 71.95 REPORT EVALUATION FORM Docket No.: 71-9196 Package Model No.: UX-30 Report Submitted By: TN Americas LLC Report Date: May 10, 2024 Report ADAMS Accession No.:
- 4. Corrective actions taken by the licensee:
For the non-compliance for use of 2019 or 2024 versions of the ANSI Standard, in its report, TN stated that it will submit an application to request the condition of approval be revised to reference the latest ANSI N14.1 edition (see application dated June 5, 2024 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML24157A369)) and it will revise its Quality Assurance Program implementing procedure for Control of Licensing Documents, to include checking the effective date of codes and standards incorporated by reference in the U.S.
Nuclear Regulatory Commission (NRC) CoC.
For the non-compliance report on use of the unapproved material specification, TN stated that it will submit an application to add ASTM A479 as an alternate material for fabrication (see application dated June 5, 2024 [ML24157A369]). In addition to prevent recurrence, TN stated that it will revise its Quality Assurance Program Implementing Procedure for Fabrication Drawing Control, TIP 5.8, and Drawing Control, TIP 5.1, to require reconciling material specifications on fabrication and design drawings with the licensing drawings.
Both changes were approved on July 9, 2024 (ML24169A215).
- 5. Staff comments:
The NRC determined that the consequences of both non-compliances were low. Both changes were approved on July 9, 2024 (ML24169A215). There are not significant differences between the 2012 and the 2019 versions of the ANSI Standard such that following a later version would cause the package to fail. In addition, the staff noted in its safety evaluation report that the yield and tensile material properties are identical for both materials.
- 6. Staff conclusion:
The report does NOT identify generic design or license/certificate issues that warrant additional Commission or staff action. This report is considered closed.
There is a need to take additional action. Provide a summary of the bases and recommended actions:
ML24227B011(pkg), ML24227B012(Report),
ML24131A065(ltr)
OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NAME BWhite SFigueroa YDiaz-Sanabria DATE 8/15/24 8/15/24 8/17/24