ML24358A156
| ML24358A156 | |
| Person / Time | |
|---|---|
| Site: | Erwin, 07100249 |
| Issue date: | 10/14/2024 |
| From: | Rogers D BWXT Nuclear Fuel Services, Nuclear Fuel Services |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| 21G-24-0191, GOV-01-55-04, ACF-24-0218 | |
| Download: ML24358A156 (1) | |
Text
Nuclear Fuel Services, Inc.
CERTIFIED MAIL RETURN RECEIPT REQUESTED
- i Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards ATTENTION: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Reference:
1.) NRC Docket No. 71-0249 2.) NRC Docket No. 70-0143 / SNM-124 21 G-24-0191 GOV-01-55-04 ACF-24-0218 October 14, 2024
Subject:
10 CFR 71.95-60 Day Report, Presence of Water In ES-3100 Shipping Package
Dear Sir or Madam,
On August 14, 2024, an NRC licensee identified the presence of water upon receipt in two (2) ES-3100 shipping packages (USA/9315/B(U)F-96) shipped from Nuclear Fuel Services (NFS). The Safety Analysis Report for Packaging (SARP), Chapter 7, Operating Procedures, states incidents requiring notification include adverse conditions, such as entrapped moisture. The subsequent investigation identified an overhead leak in the storage area resulted in water intrusion into the ES-3100 packages via the openings for the tamper indicating devices. NFS 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 (Attachment 1).
If you or your staff have any questions, require additional information, or wish to discuss this matter further, please contact Ashley Morris, Licensing Unit Manager, at 423-743-1758. Please reference our unique document identification number (21G-24-0191) in any correspondence concerning this letter.
Sincerely, NUCLEAR FUE~VICES, INC.
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..u t fl) N 6 7 Danielle Rogers, ~
S CTG/las Safety and Safeguards Director jl/ I{ 5
Attachment:
1.) 10 CFR 71.95 Report 1205 Banner Hill Rd, Erwin, TN 37650 t: +1.423.743.9141 f: +1.423.743.0140 www.nuclearfuelservices.com People Strong INNOVATION DRIVEN >
.' I Copies:
Mr. James Downs Senior Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards US Nuclear Regulatory Commission Two White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Nicholas Peterka Senior Fuel Facility Inspector U.S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Larry Harris NRC Senior Resident Inspector 21 G-24-0191 GOV-01-55-04 ACF-24-0218 10 CFR 71.95 Report (4 pages to follow) 21 G-24-0191 GOV-01-55-04 ACF-24-0218
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- I 21 G-24-0191 GOV-01-55-04 ACF-24-0218 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. The ES-3100 package performed as designed and intended.
On August 14, 2024, an NRC licensee identified the presence of water upon receipt in two (2) ES-3100 packages (USA/9315/B(U)F-96) shipped from Nuclear Fuel Services, Inc. (NFS). The licensee notified NFS in accordance with the Safety Analysis Report for Packaging (SARP), Chapter 7, Operating Procedures, Section 7.2.1, Example 5, Adverse Condition (entrapped moisture). The licensee identified water within the ES-3100 drum body, NOT the internal containment vessel. The licensee unpackaged the contents without issue. The presence of water did not impact the shipment nor challenge the safety basis. The presence of water was only identified in two (2) containers, with no water found present in the balance of the shipment.
Upon notification, NFS promptly investigated the event, including an immediate extent of condition which revealed no other signs of water in containers nor the loading area.
The investigation and extent of condition found no signs of physical damage to the subject packages nor any other containers on-site. The investigation verified that trained and qualified personnel completed the required pre-load inspection checklist for each ES-3100 on the shipment. This documented inspection verified no moisture was present at that time. After verifying all procedure requirements identified in Chapter 7 of the SARP were followed per NFS standard operating procedure, no apparent cause for water exposure nor intrusion could be identified.
It is important to note, prior to and after loading, ES-3100 containers are held in a staging area prior to shipment. Subsequent to the original shipping event on August 14, 2024, NFS experienced a second, on-site event where water was discovered inside an ES-3100. On September 5, 2024, water was identified in two (2) different ES-3100 containers on site at NFS. These specific containers were EMPTY. The investigation determined the two containers were inspected on August 30, 2024, per the normal process and procedures and no moisture was identified prior to relocating in the staging area.
On September 4, 2024, these specific ES-3100 containers were pre-load inspected per the SOP and water was identified in the bottom of the drum body and underneath the lid in each container.
Given all the ES-3100 containers were physically intact with no signs of damage, the original on-going investigation continued to search for a root cause that led to water exposure. As a result, the overhead area in the storage location was inspected for any potential leaks. Although not actively dripping, obvious signs of saturated insulation were discovered on the overhead chilled water lines.
Immediate action was taken to place this specific storage location out of service. Also of note, it was confirmed the two ES-3100 packages involved in the initiating event on
21 G-24-0191 GOV-01-55-04 ACF-24-0218 August 14, 2024, were staged for shipping in this same location which explains the origin for water exposure.
The overhead leak from the cooling water line was believed to be intermittent, given the lack of consistent dripping or water accumulation on the floor in the storage area. As water dripped onto the ES-3100, an intrusion path exists to the inner drum body (not the inner CV) through the lid openings that permit the tamper indicating devices to be applied.
As a result of the overhead water leak in the storage area, the original ES-3100 packages were shipped with water present on the interior of the drum body, which did not demonstrate compliance with the SARP as written.
The final extent of condition reported no deficiencies after all impacted ES-3100 packages were opened and inspected.
(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.
(i) Status of components or systems that were inoperable at the start of the event and that contributed to the event; No ES-3100 components or systems were inoperable nor contributed to the event.
(ii) Dates and approximate times of occurrences; The initiating event occurred on August 14, 2024 at approximately 0800 EST and the subsequent event on September 5, 2024 at approximately 0815 EST.
(iii) The cause of each component or system failure or personnel error, if known; No components or systems failed, nor did any human performance errors contribute to this event. The adverse condition resulted from building/infrastructure system failure.
(iv) The failure mode, mechanism, and effect of each failed component, if known; No failed mechanisms or components contributed to this event.
21 G-24-0191 GOV-01-55-04 ACF-24-0218 (v) A list of systems or secondary functions that were also affected for failures of components with multiple functions; No failure of systems or components contributed to this event.
(vi) The method of discovery of each component or system failure or procedural error; Each instance of the adverse condition (entrapped moisture) was identified by trained and qualified personnel in accordance with relevant procedure(s) both at NFS and the receiving facility.
(vii) For each human performance-related root cause, a discussion of the cause(s) and circumstances; No human performance errors were a contributing factor for this event.
(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.
The quantities and physical form of the package contents were in full compliance with the Certificate of Conformance. Detailed content description omitted for classification purposes. This event did not impact the inner containment vessel nor contents.
(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.
No safety consequences were identified for this event. The ES-3100 performed as designed and intended. The event did not challenge the package safety basis.
(4) A description of any corrective actions pl1;1nned 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.
Immediate corrective actions were taken to inspect all ES-3100 containers stored in the affected area (areas where the water lines were overhead) for water intrusion. No additional adverse conditions were identified.
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21 G-24-0191 GOV-01-55-04 ACF-24-0218 Pending completion of repairs/relocation of the overhead water lines, all ES-3100 containers stored in the affected area must be covered to protect against any potential overhead leaks. Additionally, ES-3100 containers impacted by the presence of water were tagged out of service and handled in accordance with procedure NFS-Q-185, Control of Nonconforming Items.
(5) 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.
Ashley Morris, Licensing Manager-42*3-743-1758 (7) The extent of exposure 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.