ML24353A088
| ML24353A088 | |
| Person / Time | |
|---|---|
| Site: | 07109204 |
| Issue date: | 12/18/2024 |
| From: | Gelfond A EnergySolutions |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| ESCD/NRC 24-001 | |
| Download: ML24353A088 (1) | |
Text
740 Osborn Road, Barnwell, SC 29812 www.energysolutions.com December 18, 2024 ESCD/NRC 24-001 ATTN: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
10CFR 71.95 Event Report - Docket 71-9204, Certificate of Compliance USA/9204/B(U)F-96, Model 10-160B Transport Package
Dear Director,
Pursuant to 10CFR71.95(a)(3), EnergySolutions hereby submits the attached report (Attachment 1) for instances that may have been occurred from 2004 until the time of the discovery, in which Condition 5(a)(3) in Certificate of Compliance No. 9204 may not have been complied with in making shipments with the NRC-approved 10-160B Type B transport package. These events based on a potential deficiency were discovered on October 22, 2024.
This potential deficiency is associated with a human performance error related to inadequate verification of critical characteristics for the Model 10-160B impact limiters turnbuckles (ITS-B component). There was no component and/or system failure or any minor and/or major occurrence. An evaluation has determined that this deficiency had no safety significance, there was no reduction in effectiveness of the package, and no exposure of personnel during affected shipments. All other requirements of the Certificate of Compliance and applicable regulations were met. After identification of this potential deficiency, appropriate immediate corrective actions were implemented to prevent recurrence.
For efficiency purposes, this report encompasses all historical events associated with this deficiency and provides reportability on behalf of EnergySolutions and all applicable licensees who are required to fulfill their reporting obligations under 10CFR71.95(c).
Should you have any questions regarding this notice, please contact me at (803)591-9074.
This letter is submitted electronically via the NRC Electronic Information Exchange (EIE) system.
Sincerely, Aleksandr Gelfond Director of Engineering/Licensing, Cask Division
- Failure to Observe Certificate of Compliance Condition for the Model 10-160B Transport Package, December 18, 2024 cc)
Pierre Saverot, US NRC, Division of Fuel Management Amy Hazelhoff, EnergySolutions, VP of Regulatory Affairs
to ESCD/NRC 24-001: Failure to Observe Certificate of Compliance Condition for the Model 10-160B Transport Package, December 18, 2024
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(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:
Each EnergySolutions 10-160B Type B packaging (NRC CoC No.71-9204) uses eight (8) ratchet binders (Turnbuckles) to secure the Impact Limiters to the packaging body.
These are 1-inch shank diameter custom length Type J Turnbuckles which are classified as QL-2 (ITS-B) components and require a minimum breaking strength of 45,000 lbs (as listed in the 10-160B packaging licensing drawing discussed in Section 2 of this report).
The supplier of these Turnbuckles (Patterson Manufacturing) communicated that the Type J Turnbuckles supplied to EnergySolutions (including EnergySolutions predecessor companies) during the period of 2004-2010 may not have a minimum breaking strength of 45,000 lbs.
There was no component and/or system failure, or any major and/or minor occurrences.
This potential deficiency is not considered a design or safety issue since the affected Turnbuckles complied with minimum required design criteria (due to sufficient margin in the SAR calculated safety factor). However, these Turnbuckles may not have been complied with the 10-160B packaging licensing drawing referenced in the NRC CoC No.71-9204, this potential event does qualify for the reporting to Nuclear Regulatory Commission under 10CFR71.95 (a)(3) Instances in which the conditions of approval in the Certificate of Compliance were not observed in making a shipment.
The following immediate corrective/preventive actions were implemented to preclude recurrence (via EnergySolutions Condition Reports CR-2024-0747 and CR-2024-0479)
- 1. Verify that the Turnbuckles installed on 10-160B Packagings and other Type B Packagings for which EnergySolutions is a license holder/licensee are not from the questionable procurement period. This action is applicable to Type B Packagings certified by various regulatory agencies and owned by both EnergySolutions and third parties.
- 2. Provide written notification to the EnergySolutions Cask Operations providing instructions on the limitations of continued 10-160B cask shipments. (i.e.,
Shipments made under Type B NRC/DOE CoCs may not proceed until verification of compliant Turnbuckle installation is achieved).
- 3. Provide notification to customers (owners and users of affected Type B packagings) about this event.
- 4. Establish administrative controls to assure adequate configuration control of affected 10-160B Casks and associated Turnbuckles. (i.e., a method to ensure that compliant Turnbuckles are installed on any planned Type B shipments).
to ESCD/NRC 24-001: Failure to Observe Certificate of Compliance Condition for the Model 10-160B Transport Package, December 18, 2024
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- 5. Perform a surveillance in accordance with EnergySolutions procedures to ensure adequate configuration control of the affected 10-160B Casks and associated Turnbuckles.
- 6. Improve engineering process (verification of critical characteristics) via revision of Impact Limiter Turnbuckles commercial grade upgrade plans for applicable Type B packagings.
- 7. Discuss lessons learned with involved personnel within EnergySolutions Cask Engineering/Licensing Group to minimize the chance for reoccurrence.
(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 include the following specific information as appropriate for the particular event.
Consolidated Safety Analysis Report (SAR) for Model 10-160B Type B RadWaste Shipping Cask, Revision 7, dated November 2013, Appendix 1.3, (SAR Drawing) identifies Drawing No. C-110-D-29003-010, Cask Assembly General Notes / Parts List.
The subject drawing, Revision 16, Sheet 2 of 5, Item 54 requires (8) Turnbuckles with eye bolts per Specification BB. Specification BB requires an Ultimate Strength of 45,000 lbs (i.e., a minimum breaking strength of 45,000 lbs).
These components were supplied by Patterson Manufacturing (the Supplier) as commercial items which were upgraded to QL-2 (ITS-B) classification using EnergySolutions approved commercial grade upgrade process. EnergySolutions requested clarification from the supplier regarding the basis for the minimum breaking strength of 45,000 lbs stated on the Supplier provided data sheets. After internal evaluations, the Supplier concluded that there is insufficient documentation from the period of 2004 thru 2010 to verify that the Type J Turnbuckles met the minimum breaking strength of 45,000 lbs due to a change in material suppliers.
Without sufficient evidence from this period, the Supplier is unable to reasonably assure that Turnbuckles shank material met the minimum breaking strength of 45,000 lbs and can only confirm this as a potential deficiency. For this period, a material with a reduced strength could have been used for the Turnbuckle threaded shank making its minimum calculated breaking strength capacity to be 42,800 lbs. The Supplier has confirmed that the Type J Turnbuckles supplied to EnergySolutions outside of this period do have a minimum breaking strength of 45,000 lbs.
Even with a reduced breaking strength of 42,800 lbs, it can be concluded that the affected Turnbuckles complied with the packaging design criteria since the maximum load
to ESCD/NRC 24-001: Failure to Observe Certificate of Compliance Condition for the Model 10-160B Transport Package, December 18, 2024
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applied to the Turnbuckles is 34,245 lbs (based on the analysis in Section of 2.7.1.5 of the 10-160B packaging SAR), resulting in a safety factor of 1.25. Therefore, it can be concluded that this condition was not a design or safety issue.
(2)(i) Status of components or systems that were inoperable at the start of the event and that contributed to the event:
This criterion is not applicable to the event because there were no components or systems that were inoperable at the start of the event and/or contributed to the event.
(2)(ii) Dates and approximate times of occurrences:
Shipments made in the model 10-160B packaging under NRC CoC No.71-9204 in the period of 2004 until the time of discovery. The time of discovery is October 22, 2024.
(2)(iii) The cause of each component or system failure or personnel error, if known; The cause of the event is a human performance deficiency associated with inadequate verification of critical characteristics by EnergySolutions during implementation of 10-160B Impact Limiter Turnbuckles commercial grade upgrade plan.
(2)(iv) The failure mode, mechanism, and effect of each failed component, if known:
This criterion is not applicable to the event because no components failed.
(2)(v) A list of systems or secondary functions that were also affected for failures of components with multiple functions:
This criterion is not applicable to the event because no components failed.
(2)(vi) The method of discovery of each component or system failure or procedural error:
There was no component or system failure. Based on EnergySolutions Condition Report CR-2024-0747, EnergySolutions requested clarification regarding the basis of the minimum breaking strength of 45,000 lbs stated in the Supplier literature (Datasheet#
7004-Q). The Supplier has concluded that there is insufficient documentation from the period of 2004 thru 2010 to verify that the Type J Turnbuckles met the minimum breaking strength of 45,000 lbs due to a change in material suppliers.
to ESCD/NRC 24-001: Failure to Observe Certificate of Compliance Condition for the Model 10-160B Transport Package, December 18, 2024
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(2)(vii) For each human performance-related root cause, a discussion of the cause(s) and circumstances:
The cause of the non-compliance was related to human performance. The verification methods described in EnergySolutions Commercial Item Upgrade Plan for Cask Impact Limiter Turnbuckles were found to be less than adequate for the established critical characteristic (45,000 lbs breaking strength capacity).
(2)(viii) The manufacturer and model number (or other identification) of each component that failed during the event.
Manufacturer and model numbers associated with component failure are not applicable because no components failed, however potential affected part is Patterson Manufacturing Type J Turnbuckle Part # 7004-Q.
(2)(ix) For events occurring during use of a packaging, the quantities and chemical and physical form(s) of the package contents This criterion is not applicable to the event because no components failed.
(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 the same function as the components and systems that failed during the event.
There were no systems and/or components that failed during the event. There were no safety consequences or implications of the event.
(4) A description of any corrective actions planned because 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.
This event has been entered in EnergySolutions Condition Report (Condition Report CR-2024-0747). In addition to immediate actions identified in (1) above, EnergySolutions will implement appropriate corrective actions to strengthen the training program and improve the current system of controls to prevent reoccurrence of this event based on the outcome of the applicable Root Cause Analysis.
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(5) Reference to any previous similar events involving the same packaging that are known to the licensee or certificate holder.
No previous similar events were identified.
(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.
Aleksandr Gelfond EnergySolutions Director of Engineering/Licensing, Cask Division (803)591-9074 axgelfond@energysolutions.com (7) The extent of exposure of individuals to radiation or to radioactive materials without identification of individuals by name.
There were no exposures to individuals as a result of this event(s).