|
|
| (5 intermediate revisions by the same user not shown) |
| Line 2: |
Line 2: |
| | number = ML17170A073 | | | number = ML17170A073 |
| | issue date = 06/15/2017 | | | issue date = 06/15/2017 |
| | title = Browns Ferry, Units 1, 2, and 3 - Report Pursuant to 10 CFR 71.95 (a)(3) and (B) - Failure to Follow Conditions of TN-RAM Packaging Certificate of Compliance No. 9233 | | | title = Report Pursuant to 10 CFR 71.95 (a)(3) and (B) - Failure to Follow Conditions of TN-RAM Packaging Certificate of Compliance No. 9233 |
| | author name = Bono S M | | | author name = Bono S |
| | author affiliation = Tennessee Valley Authority | | | author affiliation = Tennessee Valley Authority |
| | addressee name = | | | addressee name = |
| Line 15: |
Line 15: |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:Tennessee ValleyAuthority, PostOfficeBox2000,Decatur,Alabama35609-2000 June15,201710CFR71.95(c)ATTN:DocumentControlDeskU.S.NuclearRegulatory Commission | | {{#Wiki_filter:Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 June 15, 2017 10 CFR 71.95(c) |
| : Director, DivisionofSpentFuelManagement OfficeofNuclearMaterialSafetyandSafeguards Washington, DC20555-000 1BrownsFerryNuclearPlant,Units1,2,and3RenewedFacilityOperating LicenseNos.DPR-33,DPR-52,andDPR-68NRCDocketNos.50-259,50-260,50-296
| | ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Washington, DC 20555-000 1 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, 50-296 |
|
| |
|
| ==SUBJECT:== | | ==SUBJECT:== |
| ReportPursuantto10CFR71.95(a)(3)and(b)-FailuretoFollowConditions ofTN-RAMPackaging Certificate ofCompliance No.9233
| | Report Pursuant to 10 CFR 71.95 (a)(3) and (b) |
| | - Failure to Follow Conditions of TN-RAM Packaging Certificate of Compliance No. 9233 |
|
| |
|
| ==REFERENCE:== | | ==REFERENCE:== |
| | Certificate of Compliance No. 9233 for the TN-RAM Packaging, Revision 14 The Tennessee Valley Authority (TVA) is submitting this report pursuant to 10 CFR 71.95(a)(3) and (b) with respect to Certificate of Compliance (CoC) No. 9233, Revision 14, for the TN-RAM Packaging, Docket No. 71-9233. WA is an authorized user of the TN-RAM packaging under the provisions of 10 CFR 71.17, General License: NRC-approved package. |
| | Only one TN-RAM packaging has been fabricated and in use since 1989, prior to the discovery that the attachment points not intended for package lifting or tie-down were not rendered inoperable for transport operations as required by 10 CFR 71.87(h) and 49 CFR 173.41(b). The failure to render the impact limiter lifting lugs inoperable was noted during routine operations by a party other than WA. Further review of the design determined that the attachment points intended for lifting the impact limiters will not withstand the static force required for lifting and tie-down in 10 CFR 71.45. |
| | Immediate action was taken to install a cover on each impact limiter lifting lug retained by a bolt installed in the lifting lug through hole, which renders the attachment point inoperable. |
| | In addition to installing the cover, a durable marking, stating "IMPACT LIMITER LIFTING ONLY," |
| | was placed near each impact limiter lifting lug to identify the intended use of the lifting lugs. |
|
| |
|
| Certificate ofCompliance No.9233fortheTN-RAMPackaging, Revision14TheTennessee ValleyAuthority (TVA)issubmitting thisreportpursuantto10CFR71.95(a)(3) and(b)withrespecttoCertificate ofCompliance (CoC)No.9233,Revision14,fortheTN-RAMPackaging, DocketNo.71-9233.WAisanauthorized useroftheTN-RAMpackaging undertheprovisions of10CFR71.17,GeneralLicense:NRC-approved package.OnlyoneTN-RAMpackaging hasbeenfabricated andinusesince1989,priortothediscovery thattheattachment pointsnotintendedforpackageliftingortie-downwerenotrenderedinoperable fortransport operations asrequiredby10CFR71.87(h)and49CFR173.41(b).
| | U.S. Nuclear Regulatory Commission Page 2 June 15, 2017 A written report, as required by 10 CFR 71.95(c), is provided as Enclosure 1. |
| Thefailuretorendertheimpactlimiterliftinglugsinoperable wasnotedduringroutineoperations byapartyotherthanWA.Furtherreviewofthedesigndetermined thattheattachment pointsintendedforliftingtheimpactlimiterswillnotwithstand thestaticforcerequiredforliftingandtie-downin10CFR71.45.Immediate actionwastakentoinstallacoveroneachimpactlimiterliftinglugretainedbyaboltinstalled intheliftinglugthroughhole,whichrenderstheattachment pointinoperable.
| | There are no new regulatory commitments associated with this submittal. If you should have any questions regarding this submittal, please contact Ed Schrull at (423) 751-3850. |
| Inadditiontoinstalling thecover,adurablemarking,stating"IMPACTLIMITERLIFTINGONLY,"wasplacedneareachimpactlimiterliftinglugtoidentifytheintendeduseoftheliftinglugs.
| |
| U.S.NuclearRegulatory Commission Page2June15,2017Awrittenreport,asrequiredby10CFR71.95(c),isprovidedasEnclosure 1.Therearenonewregulatory commitments associated withthissubmittal. | |
| Ifyoushouldhaveanyquestions regarding thissubmittal, pleasecontactEdSchrullat(423)751-3850.
| |
|
| |
|
| ==Enclosure:== | | ==Enclosure:== |
| | 10 CFR 71.95 Report cc (Enclosure): |
| | NRC Regional Administrator |
| | - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Senior Resident Inspector - Sequoyah Nuclear Plant NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRC Project Manager for TN-RAM, SFM Licensing Branch |
|
| |
|
| 10CFR71.95Reportcc(Enclosure):
| | Enclosure 10 CFR 71.95 Written Report Information required by 10 CFR 71.95(c) was prepared by TN Americas LLC and is included as an attachment to this enclosure. Additional licensee-specific information is provided below. |
| NRCRegionalAdministrator
| | (2)(ii) Dates and approximate times of occurrences The TN-RAM cask was used for shipments from the Browns Ferry Nuclear Plant (BFN) on the following dates: |
| -RegionIINRCSeniorResidentInspector
| | 10/11/2012 12/17/2012 1/14/2013 1/23/2013 2/4/2013 2/13/2013 2/18/2013 2/28/2013 3/11/2013 (6) Contact information Please contact WA Corporate Nuclear Licensing Manager Ed Schrull at (423) 751-3850 with any questions regarding this report. |
| -BrownsFerryNuclearPlantNRCSeniorResidentInspector
| | Attachment (6 pages follow): 10 CFR 71.95 Written Report |
| -SequoyahNuclearPlantNRCSeniorResidentInspector
| | |
| -WattsBarNuclearPlantNRCProjectManagerforTN-RAM,SFMLicensing Branch Enclosure 10CFR71.95WrittenReportInformation requiredby10CFR71.95(c)waspreparedbyTNAmericasLLCandisincludedasanattachment tothisenclosure.
| | 10 CFR 71.95 Written Report (1) Abstract The TN-RAM package has trunnions intended as attachment points for lifting and tie-down. The trunnions are a structural part of the package that is designed to meet the requirements of the regulation for lifting and tie-down. Attachment points for lifting the impact limiters during installation and removal are a structural part of the impact limiters that are part of the TN-RAM package. An evaluation of the TN-RAM lifting attachment points demonstrates that the trunnions and impact limiter lifting lugs have been designed only for their intended use. Inadvertent use of the impact limiter lifting tugs to lift or tie-down the TN-RAM would impair the ability of the package to meet requirements for transport. However, operation of the TN-RAM has not included any controls to render the impact limiter lifting tugs inoperable during transport operations as required by transport regulations. An evaluation of the lifting and tie-down operations has been done to determine the extent of the condition and appropriate corrective actions to render the impact limiter tugs inoperable. A review of the NRC 10 CFR Part 71.78(h) regulatory requirements for Operating Controls and Procedures determined that use of the cask without rendering the impact limiter tugs inoperable is a practice that did not follow the conditions of the certificate of compliance. |
| Additional licensee-specific information isprovidedbelow.(2)(ii)Datesandapproximate timesofoccurrences TheTN-RAMcaskwasusedforshipments fromtheBrownsFerryNuclearPlant(BFN)onthefollowing dates:10/11/2012 12/17/2012 1/14/2013 1/23/2013 2/4/20132/13/2013 2/18/2013 2/28/2013 3/11/2013 (6)Contactinformation PleasecontactWACorporate NuclearLicensing ManagerEdSchrullat(423)751-3850withanyquestions regarding thisreport.Attachment (6pagesfollow):10CFR71.95WrittenReport 10CFR71.95WrittenReport(1)AbstractTheTN-RAMpackagehastrunnions intendedasattachment pointsforliftingandtie-down.Thetrunnions areastructural partofthepackagethatisdesignedtomeettherequirements oftheregulation forliftingandtie-down.Attachment pointsforliftingtheimpactlimitersduringinstallation andremovalareastructural partoftheimpactlimitersthatarepartoftheTN-RAMpackage.Anevaluation oftheTN-RAMliftingattachment pointsdemonstrates thatthetrunnions andimpactlimiterliftinglugshavebeendesignedonlyfortheirintendeduse.Inadvertent useoftheimpactlimiterliftingtugstoliftortie-downtheTN-RAMwouldimpairtheabilityofthepackagetomeetrequirements fortransport. | | (2) Description of the event (i) |
| However,operation oftheTN-RAMhasnotincludedanycontrolstorendertheimpactlimiterliftingtugsinoperable duringtransport operations asrequiredbytransport regulations. | | Status of components or systems that were inoperable at the start of the event and that contributed to the event The TN RAM cask system is a Type 8 transportation package design approved by the NRC (71-9233). The package is a steel encased lead shielded cask with wood impact limiters attached at both ends. The impact limiters are a packaging component that is required by the NRC approval of the package design. Impact limiters protect the cask shell and contents by absorbing shocks from impacts incidental to normal and accident transportation conditions. The cask shell is a right circular cylinder with trunnions welded to the outer shell for lifting and tie-down. The overall dimensions of the packaging are approximately 178 inches long and 92 inches diameter with the impact limiters installed. |
| Anevaluation oftheliftingandtie-downoperations hasbeendonetodetermine theextentofthecondition andappropriate corrective actionstorendertheimpactlimitertugsinoperable.
| | The cask body is approximately 129 inches long with an outer diameter of 51 inches. The maximum gross weight of the package is approximately 80,000 lbs. The structural evaluation for tie-down and lifting devices in the TN-RAM SAR states that there are no other structural parts of the package which can be used for tie down attachments. |
| AreviewoftheNRC10CFRPart71.78(h)regulatory requirements forOperating ControlsandProcedures determined thatuseofthecaskwithoutrendering theimpactlimitertugsinoperable isapracticethatdidnotfollowtheconditions ofthecertificate ofcompliance.
| | (ii) |
| (2)Description oftheevent(i)Statusofcomponents orsystemsthatwereinoperable atthestartoftheeventandthatcontributed totheeventTheTNRAMcasksystemisaType8transportation packagedesignapprovedbytheNRC(71-9233). | | Dates and approximate times of occurrences The TN-RAM package first use was on or about 1989. The lifting lugs were not rendered inoperable during the period of operation since first use. |
| Thepackageisasteelencasedleadshieldedcaskwithwoodimpactlimitersattachedatbothends.Theimpactlimitersareapackaging component thatisrequiredbytheNRCapprovalofthepackagedesign.Impactlimitersprotectthecaskshellandcontentsbyabsorbing shocksfromimpactsincidental tonormalandaccidenttransportation conditions.
| | (iii) |
| Thecaskshellisarightcircularcylinderwithtrunnions weldedtotheoutershellforliftingandtie-down.Theoveralldimensions ofthepackaging areapproximately 178incheslongand92inchesdiameterwiththeimpactlimitersinstalled.
| | The cause of each component or system failure or personnel error The TN-RAM SAR contains loading and handling guidelines that include general instructions for removal of the impact limiters using a "suitable crane and two legged sling", rotating and lifting the cask using a "suitable crane hook" to "engage the lift beam to the two front trunnions", and removal and installation of "front and rear trunnion tie-downs." |
| Thecaskbodyisapproximately 129incheslongwithanouterdiameterof51inches.Themaximumgrossweightofthepackageisapproximately 80,000lbs.Thestructural evaluation fortie-downandliftingdevicesintheTN-RAMSARstatesthattherearenootherstructural partsofthepackagewhichcanbeusedfortiedownattachments.
| | The Operations and Maintenance Manual for the TN-RAM (OM-7) expands on the handling guideline and describes the trunnions intended purpose for lifting and tie-down of the cask. |
| (ii)Datesandapproximate timesofoccurrences TheTN-RAMpackagefirstusewasonorabout1989.Theliftinglugswerenotrenderedinoperable duringtheperiodofoperation sincefirstuse.(iii)Thecauseofeachcomponent orsystemfailureorpersonnel errorTheTN-RAMSARcontainsloadingandhandlingguidelines thatincludegeneralinstructions forremovaloftheimpactlimitersusinga"suitable craneandtwoleggedsling",rotatingandliftingthecaskusinga"suitable cranehook"to"engagetheliftbeamtothetwofronttrunnions", | | OM-7 also describes the impact limiter lifting lugs as "located such that the limiter is |
| andremovalandinstallation of"frontandreartrunniontie-downs."TheOperations andMaintenance ManualfortheTN-RAM(OM-7)expandsonthehandlingguideline anddescribes thetrunnions intendedpurposeforliftingandtie-downofthecask.OM-7alsodescribes theimpactlimiterliftinglugsas"locatedsuchthatthelimiteris 10CFR71.95WrittenReportbalancedwhenitislifted."TheglossaryoftermsinOM-7definesliftinglugsas"attachments providedontheimpactlimitersforhandlingoperations,"
| | |
| liftbeamsas"devicesforcaskliftingandhandlingoperations,"
| | 10 CFR 71.95 Written Report balanced when it is lifted." The glossary of terms in OM -7 defines lifting lugs as "attachments provided on the impact limiters for handling operations," lift beams as "devices for cask lifting and handling operations," and trunnions as "handling attachments provided for cask primary lifting, support and tie-down." These definitions describe the intended purpose of attachment points. The design of the impact limiter rigging equipment is sized for attachment to the lifting lugs, and lift beams are specialized lifting devices that are designed for attachment to the trunnions. A dynamometer is installed between the crane hook and sling that is attached to the lifting lugs. The dynamometer is used to support the weight to allow removal of impact limiter bolts, and the procedure requires "lift up on the sling until a reading of 3700, +0, -100 pounds is indicated on the dynamometer." |
| andtrunnions as"handling attachments providedforcaskprimarylifting,supportandtie-down."Thesedefinitions describetheintendedpurposeofattachment points.Thedesignoftheimpactlimiterriggingequipment issizedforattachment totheliftinglugs,andliftbeamsarespecialized liftingdevicesthataredesignedforattachment tothetrunnions.
| | Any attempt to lift the weight of the TN-RAM package would exceed 3700 pound reading on the dynamometer. Tie-down members for the TN-RAM are trailer support pedestals specially designed for attachment to the trunnions. |
| Adynamometer isinstalled betweenthecranehookandslingthatisattachedtotheliftinglugs.Thedynamometer isusedtosupporttheweighttoallowremovalofimpactlimiterbolts,andtheprocedure requires"liftupontheslinguntilareadingof3700,+0,-100poundsisindicated onthedynamometer."
| | The tarp installed over the support frame during transport has been considered a control to render the impact limiter lugs inoperable. The tarp when installed blocks access to the impact limiter lugs, but the lifting tugs are accessible when the tarp and support frame are removed for handling operations. Transport operations include the preparation of the package for transport (installing impact limiters), securing the package to the trailer for transit (tie-down), and receiving the package (removing impact limiters). During preparation for transport and receipt of the TN-RAM, the impact limiters are installed without the tarp in place. Prior to removal of the impact limiters and after installation the lift lugs are accessible. |
| AnyattempttolifttheweightoftheTN-RAMpackagewouldexceed3700poundreadingonthedynamometer.
| | Rigging equipment or tie-down members could inadvertently be attached to the lift tugs. |
| Tie-downmembersfortheTN-RAMaretrailersupportpedestals specially designedforattachment tothetrunnions. | | However, lifting or tie-down of the TN-RAM using the lifting lugs would require intentional misuse of the rigging equipment and tie-down members, and violate operational controls and procedures for handling the cask. A method for rendering the lift lugs inoperable is required to prevent attachment to these points during preparation and receipt phases of transport operations. The tarp does not meet the intent of the requirement in the regulation to render the attachment point inoperable during all phases of transport operations. |
| Thetarpinstalled overthesupportframeduringtransport hasbeenconsidered acontroltorendertheimpactlimiterlugsinoperable.
| | (iv) |
| Thetarpwheninstalled blocksaccesstotheimpactlimiterlugs,buttheliftingtugsareaccessible whenthetarpandsupportframeareremovedforhandlingoperations.
| | The failure mode, mechanism, and effect of each failed component The impact limiter attachment points are intended only for lifting the impact limiter during removal and installation white the TN-RAM package is attached to the transportation trailer. Each impact limiter weighs approximately 3700 lbs. The impact limiter shell is a structural part of the packaging that retains the wood shock absorber. The shell is sealed to protect the wood material from environmental conditions incident to routine use. |
| Transport operations includethepreparation ofthepackagefortransport (installing impactlimiters), | | The impact limiter lifting lugs are designed for a safety factor against yield that is consistent with accepted industry standards for material handling using standard rigging equipment. |
| securingthepackagetothetrailerfortransit(tie-down),andreceiving thepackage(removing impactlimiters).
| | |
| Duringpreparation fortransport andreceiptoftheTN-RAM,theimpactlimitersareinstalled withoutthetarpinplace.Priortoremovaloftheimpactlimitersandafterinstallation theliftlugsareaccessible.
| | 10 CFR 71.95 Written Report The nominal design weight of the impact limiter is 3695 lbs. The most likely failure mechanism or "weak link" in the attachment point on the impact limiter would be a tensile breakage of the lifting lug. Attempting to lift the package using the impact limiter lifting lugs would not result in damage to the structural inipact limiter shell that would impair the ability to meet transport requirements. |
| Riggingequipment ortie-downmemberscouldinadvertently beattachedtothelifttugs.However,liftingortie-downoftheTN-RAMusingtheliftinglugswouldrequireintentional misuseoftheriggingequipment andtie-downmembers,andviolateoperational controlsandprocedures forhandlingthecask.Amethodforrendering theliftlugsinoperable isrequiredtopreventattachment tothesepointsduringpreparation andreceiptphasesoftransport operations.
| | The lifting lugs were not intended to tie-down of the TN-RAM during for transport. The stress applied to the lifting lugs used at attachment points for tie-down would be different than for the intended use to lift the impact limiters. A review of the impact limiter lifting design basis indicates that the lifting lugs would not withstand the stress applied by static forces required for tie-down in 71.45(a) or static force required by DOT for Protection Against Shifting and Falling Cargo (49 CFR 393). |
| Thetarpdoesnotmeettheintentoftherequirement intheregulation torendertheattachment pointinoperable duringallphasesoftransport operations.
| | (v) |
| (iv)Thefailuremode,mechanism, andeffectofeachfailedcomponent Theimpactlimiterattachment pointsareintendedonlyforliftingtheimpactlimiterduringremovalandinstallation whitetheTN-RAMpackageisattachedtothetransportation trailer.Eachimpactlimiterweighsapproximately 3700lbs.Theimpactlimitershellisastructural partofthepackaging thatretainsthewoodshockabsorber. | | A list of systems or secondary functions that were also affected for failures of components with multiple functions Lifting lugs are designed for the single purpose of lifting the impact limiter. |
| Theshellissealedtoprotectthewoodmaterialfromenvironmental conditions incidenttoroutineuse.Theimpactlimiterliftinglugsaredesignedforasafetyfactoragainstyieldthatisconsistent withacceptedindustrystandards formaterialhandlingusingstandardriggingequipment.
| | (vi) |
| 10CFR71.95WrittenReportThenominaldesignweightoftheimpactlimiteris3695lbs.Themostlikelyfailuremechanism or"weaklink"intheattachment pointontheimpactlimiterwouldbeatensilebreakageoftheliftinglug.Attempting toliftthepackageusingtheimpactlimiterliftinglugswouldnotresultindamagetothestructural inipactlimitershellthatwouldimpairtheabilitytomeettransport requirements.
| | The method of discovery of each component or system failure or procedural error Failure to render the impact limiter lugs inoperable was noted during routine operation of the TN-RAM. |
| Theliftinglugswerenotintendedtotie-downoftheTN-RAMduringfortransport.
| | (vii) |
| Thestressappliedtotheliftinglugsusedatattachment pointsfortie-downwouldbedifferent thanfortheintendedusetolifttheimpactlimiters.
| | For each human performance-related root cause, a discussion of the cause(s) and circumstances Approved operational procedures and controls in place were followed since first use of the cask. There is no known instance of lifting or tie-down of the TN-RAM using the lifting lugs during nearly 30 years operating experience. |
| Areviewoftheimpactlimiterliftingdesignbasisindicates thattheliftinglugswouldnotwithstand thestressappliedbystaticforcesrequiredfortie-downin71.45(a)orstaticforcerequiredbyDOTforProtection AgainstShiftingandFallingCargo(49CFR393).(v)Alistofsystemsorsecondary functions thatwerealsoaffectedforfailuresofcomponents withmultiplefunctions Liftinglugsaredesignedforthesinglepurposeofliftingtheimpactlimiter.(vi)Themethodofdiscovery ofeachcomponent orsystemfailureorprocedural errorFailuretorendertheimpactlimiterlugsinoperable wasnotedduringroutineoperation oftheTN-RAM.(vii)Foreachhumanperformance
| | (viii) |
| -relatedrootcause,adiscussion ofthecause(s)andcircumstances Approvedoperational procedures andcontrolsinplacewerefollowedsincefirstuseofthecask.Thereisnoknowninstanceofliftingortie-downoftheTN-RAMusingtheliftinglugsduringnearly30yearsoperating experience. | | The manufacturer and model number (or other identification) of each component that failed during the event No failure of the impact limiter lifting lugs occurred on the TN-RAM No. 001. |
| (viii)Themanufacturer andmodelnumber(orotheridentification) ofeachcomponent thatfailedduringtheeventNofailureoftheimpactlimiterliftinglugsoccurredontheTN-RAMNo.001.(ix)Foreventsoccurring duringuseofapackaging, thequantities andchemicalandphysicalform(s)ofthepackagecontentsQuantities ofradioactive materialinformofactivated metalsshippedduringuseofthepackagevariedduringuse.Duringthisperiodofusethepackagecontentswaslimitedtoabout14,000CiCo-60equivalent activitythatwasrecentlyincreased in2015toaallowupto30,000CiCo-60equivalent activity. | | (ix) |
| (3)SafetySignificance Theliftinglugswhenusedasintendedhavebeenevaluated tomeetindustrystandards forriggingandmaterialhandling. | | For events occurring during use of a packaging, the quantities and chemical and physical form(s) of the package contents Quantities of radioactive material in form of activated metals shipped during use of the package varied during use. During this period of use the package contents was limited to about 14,000 Ci Co-60 equivalent activity that was recently increased in 2015 to a allow up to 30,000 Ci Co-60 equivalent activity. |
| Attempting tolifttheTN-RAMusingtheliftinglugswouldresultinayieldingandtensilefailureoftheliftinglug.Thestructural shelloftheimpactlimiterwouldnotlikelybedamagedduetoattempting toliftthepackageusingtheliftinglugs.Stressesgenerated intheimpactlimitershellwhenusedasatie-downattachment pointforsecurement ofloadduring 10CFR71.95WrittenReporttransport havenotbeenanalyzed. | | (3) Safety Significance The lifting lugs when used as intended have been evaluated to meet industry standards for rigging and material handling. Attempting to lift the TN-RAM using the lifting lugs would result in a yielding and tensile failure of the lifting lug. The structural shell of the impact limiter would not likely be damaged due to attempting to lift the package using the lifting lugs. Stresses generated in the impact limiter shell when used as a tie-down attachment point for securement of load during |
| Usingtheimpactlimiterliftinglugsastie-downattachment pointscouldgeneratestressesintheimpactlimitershellthatcouldresultintearsorcracks.Undetected duringthenormaluseorperiodicinspections, thesedefectswouldallowmoistureingressandeventualdegradation ofthewoodimpactabsorbing materialthatwouldimpairtheperformance ofthepackageduringnormalandaccidenttransport conditions.
| | |
| (4)Corrective ActionsBothengineering andadministrative controlshavebeenimplemented topreventinadvertent useoftheimpactlimiterlugsforliftingortie-downofthepackage.Theengineering controlisacoverforeachimpactlimiterliftinglugthatisretainedbyaboltinstalled intheliftinglugthroughholetorendertheattachment pointinoperable. | | 10 CFR 71.95 Written Report transport have not been analyzed. Using the impact limiter lifting lugs as tie-down attachment points could generate stresses in the impact limiter shell that could result in tears or cracks. |
| Theliftinglugcoverspreventattachment ofriggingequipment ortiedownmemberstotheimpactlimitersliftlugsduringtransport (Figure1).Figure1-LiftingLugCoverAnadministrative controlidentifies theintendeduseoftheimpactlimiterliftinglugsbyadurablemarkingneareachimpactlimiterliftinglugstating"IMPACTLIMITERLIFTINGONLY"(Figure2).Additionally astatement shouldbeaddedintheSARChapter7-Operations andOperations andMaintenance Manual,OM-07"TNRAMOperations Manual"subsection 8.5thatwouldrequirerendering theimpactlimiterliftinglugsinoperable andstatingtheallowedattachment pointsforliftingandtie-downoftheTN-RAM.TheSARChapter7isacondition ofthe§71.17,Generallicense:NRC-approved package,andOM-7isprovidedtothecaskusersasaguidewithmoredetailedinstructions onimplementing theoperations requirements intheSAR.4 10CFR71.95WrittenReportNeitherTN-RAMSARCh.7-Operations orpreviousversionsofOperations andMaintenance manualOM-7includearequirement torenderinoperable attachment pointsthatarestructural partofthepackageandnotdesignedforintendedpackageliftingortie-down.ThemostrecentversionofOM-7however,didaddarequirement torendertheliftinglugsinoperable byinstalling aboltthroughthelug,orothersimilarmethod.Figure2-LiftingLugMarking(5)ExtentoftheCondition Operating procedures anddesignoftheliftbeamthatareintendedforliftingthecaskandtheliftinglugsmakeitimprobable thattheliftbeamwouldbeattachedtotheliftinglugs.Furthermore, thetrailertrunnionpedestals aretie-downmembersspecifically designedforattachment tothetrunriions makingitimprobable thatgenerictie-downmembersattachedtotheliftinglugswouldbeusedtosecuretheTN-RAMtothetrailer.Thedesignandoperation oftheTN-RAMlimitsthepossibility ofinadvertent useoftheimpactlimiterliftinglugsaspackageliftingortie-downattachment points.Allliftingandtie-downoperations arecontrolled bydetailedoperating procedures andperformed bytrainedandqualified personnel.
| | Undetected during the normal use or periodic inspections, these defects would allow moisture ingress and eventual degradation of the wood impact absorbing material that would impair the performance of the package during normal and accident transport conditions. |
| TheTN-RAMcaskshellisliftedwithouttheimpactlimitersinstalled.
| | (4) Corrective Actions Both engineering and administrative controls have been implemented to prevent inadvertent use of the impact limiter lugs for lifting or tie-down of the package. The engineering control is a cover for each impact limiter lifting lug that is retained by a bolt installed in the lifting lug through hole to render the attachment point inoperable. The lifting lug covers prevent attachment of rigging equipment or tie down members to the impact limiters lift lugs during transport (Figure 1). |
| Impactlimitersareremovedfromthecaskshellpriortoliftingoperations toremovethecaskshellfromthetrailer,andlikewisetheimpactlimitersareinstalled afterliftingoperations toplacecaskshellonthetraileriscomplete.
| | Figure 1 - Lifting Lug Cover An administrative control identifies the intended use of the impact limiter lifting lugs by a durable marking near each impact limiter lifting lug stating "IMPACT LIMITER LIFTING ONLY" (Figure 2). |
| Handlingisdoneexclusively bypersonstrainedinoperation oftheTN-RAMattheloadingfacilityandunloading facilities, andtransport isbyexclusive useonaspecialized trailer.(6)Contactinformation
| | Additionally a statement should be added in the SAR Chapter 7-Operations and Operations and Maintenance Manual, OM-07 "TN RAM Operations Manual" subsection 8.5 that would require rendering the impact limiter lifting lugs inoperable and stating the allowed attachment points for lifting and tie-down of the TN-RAM. The SAR Chapter 7 is a condition of the § 71.17, General license: NRC-approved package, and OM-7 is provided to the cask users as a guide with more detailed instructions on implementing the operations requirements in the SAR. |
| [Thenameandtelephone numberofapersonwithinthelicensee's organization whoisknowledgeable abouttheeventandcanprovideadditional information] | | 4 |
| 10CFR71.95WrittenReport(7)Extentofexposureofindividuals toradiation ortoradioactive materials Noindividuals wereexposedtoradiation ortoradioactive materials asaconsequence ofnotrendering theimpactlimiterliftinglugsinoperable duringtransport operations.}}
| | |
| | 10 CFR 71.95 Written Report Neither TN-RAM SAR Ch. 7-Operations or previous versions of Operations and Maintenance manual OM -7 include a requirement to render inoperable attachment points that are structural part of the package and not designed for intended package lifting or tie-down. The most recent version of OM-7 however, did add a requirement to render the lifting lugs inoperable by installing a bolt through the lug, or other similar method. |
| | Figure 2-Lifting Lug Marking (5) Extent of the Condition Operating procedures and design of the lift beam that are intended for lifting the cask and the lifting lugs make it improbable that the lift beam would be attached to the lifting lugs. |
| | Furthermore, the trailer trunnion pedestals are tie-down members specifically designed for attachment to the trunriions making it improbable that generic tie-down members attached to the lifting lugs would be used to secure the TN-RAM to the trailer. |
| | The design and operation of the TN -RAM limits the possibility of inadvertent use of the impact limiter lifting lugs as package lifting or tie-down attachment points. |
| | All lifting and tie-down operations are controlled by detailed operating procedures and performed by trained and qualified personnel. The TN-RAM cask shell is lifted without the impact limiters installed. Impact limiters are removed from the cask shell prior to lifting operations to remove the cask shell from the trailer, and likewise the impact limiters are installed after lifting operations to place cask shell on the trailer is complete. |
| | Handling is done exclusively by persons trained in operation of the TN-RAM at the loading facility and unloading facilities, and transport is by exclusive use on a specialized trailer. |
| | (6) Contact information |
| | [The name and telephone number of a person within the licensee's organization who is knowledgeable about the event and can provide additional information] |
| | |
| | 10 CFR 71.95 Written Report (7) Extent of exposure of individuals to radiation or to radioactive materials No individuals were exposed to radiation or to radioactive materials as a consequence of not rendering the impact limiter lifting lugs inoperable during transport operations.}} |
|
|---|
Category:Letter
MONTHYEARIR 05000259/20240112024-12-26026 December 2024
Biennial Problem Identification and Resolution Inspection Report 05000259/2024011, 05000260/2024011, and 05000296/2024011
ML24354A2092024-12-19019 December 2024
American Society of Mechanical Engineers, Section XI, Third 10 Year Inspection Interval, Inspection Service, System Procedure Test, Containment Inspection, and Repair and Replacement Programs, Owners Activity Report for Browns Ferry Nuclear
CNL-24-082, Central Emergency Control Center Emergency Plan Implementing Procedure Revision2024-12-17017 December 2024
Central Emergency Control Center Emergency Plan Implementing Procedure Revision
CNL-24-009, Brown Ferry Nuclear Plant, Units 1, 2 & 3; Sequoyah Nuclear Plant, Units 1 & 2 and Watts Bar Plant, Units 1 & 2 - Triennial Decommission Funding Plans for Independent Spent Fuel Storage Installations2024-12-17017 December 2024
Brown Ferry Nuclear Plant, Units 1, 2 & 3; Sequoyah Nuclear Plant, Units 1 & 2 and Watts Bar Plant, Units 1 & 2 - Triennial Decommission Funding Plans for Independent Spent Fuel Storage Installations
CNL-24-081, Application for Subsequent Renewed Operating Licenses, Third Safety Supplement2024-12-17017 December 2024
Application for Subsequent Renewed Operating Licenses, Third Safety Supplement
CNL-24-083, Alabama Department of Environmental Management Letter2024-12-10010 December 2024
Alabama Department of Environmental Management Letter
CNL-24-049, Brows Ferry Nuclear Plant, Units 1, 2 and 3 - License Amendment Request for Adoption of TSTF-576 to Revise Safety/Relief Valve Requirements2024-12-0909 December 2024
Brows Ferry Nuclear Plant, Units 1, 2 and 3 - License Amendment Request for Adoption of TSTF-576 to Revise Safety/Relief Valve Requirements
05000296/LER-2024-004, Reactor Coolant System Pressure Boundary Leakage Identified from Recirculation System Small Bore Piping2024-12-0404 December 2024
Reactor Coolant System Pressure Boundary Leakage Identified from Recirculation System Small Bore Piping
05000260/LER-2024-002-01, High Pressure Coolant Injection Inoperable Due to Rupture Disc Failure and Resulting System Isolation2024-11-25025 November 2024
High Pressure Coolant Injection Inoperable Due to Rupture Disc Failure and Resulting System Isolation
IR 05000260/20240912024-11-21021 November 2024
Final Significance Determination of a White Finding and Notice of Violation and Assessment Followup Letter NRC Inspection Report 05000260/2024091
ML24324A3332024-11-20020 November 2024
Notification of Licensed Operator Initial Examination 05000259/2025301, 05000260/2025301, 05000296/2025301
IR 05000259/20240102024-11-12012 November 2024
Design Basis Assurance Inspection Program Inspection Report 05000259/2024010 and 05000260/2024010 and 05000296/2024010
IR 05000259/20240032024-11-0404 November 2024
Integrated Inspection Report 05000259/2024003 and 05000260/2024003 and 05000296/2024003
CNL-24-043, Application for Subsequent Renewed Operating Licenses, Second Safety Supplement2024-11-0101 November 2024
Application for Subsequent Renewed Operating Licenses, Second Safety Supplement
ML24305A1692024-10-31031 October 2024
Site Emergency Plan Implementing Procedure Revision
05000259/LER-2024-003, Valid Specified System Actuation Caused the Automatic Start of Emergency Diesel Generators2024-10-29029 October 2024
Valid Specified System Actuation Caused the Automatic Start of Emergency Diesel Generators
05000259/LER-2024-001-02, Secondary Containment Isolation Valve Inoperable Due to Mechanical Failure2024-10-28028 October 2024
Secondary Containment Isolation Valve Inoperable Due to Mechanical Failure
ML24299A2632024-10-25025 October 2024
Response to Apparent Violation in NRC Inspection Report 05000260/2024090, EA-24-075
ML24289A1232024-10-24024 October 2024
Letter to James Barstow Re Environmental Scoping Summary Report for Browns Ferry
CNL-24-074, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2024-10-23023 October 2024
Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revisions
ML24308A0042024-10-16016 October 2024
Ahc 24-1578 Environmental Review of the Browns Ferry Nuclear Plant, Units 1, 2 and 3 Subsequent License Renewal Application Limestone County
CNL-24-077, Application for Subsequent Renewed Operating Licenses, Response to Request for Additional Information, Set 12024-10-0909 October 2024
Application for Subsequent Renewed Operating Licenses, Response to Request for Additional Information, Set 1
ML24270A2162024-09-27027 September 2024
Notice of Intentions Regarding Preliminary Finding from NRC Inspection Report 05000260/2024090, EA-24-075
ML24262A1502024-09-24024 September 2024
Requalification Program Inspection - Browns Ferry Nuclear Plant
CNL-24-060, Supplement to Request for Approval of the Tennessee Valley Authority Nuclear Quality Assurance Program Description2024-09-24024 September 2024
Supplement to Request for Approval of the Tennessee Valley Authority Nuclear Quality Assurance Program Description
ML24262A0602024-09-23023 September 2024
Summary of August 19, 2024, Meeting with Tennessee Valley Authority Regarding a Proposed Supplement to the Tennessee Valley Authority Nuclear Quality Assurance Plan
ML24263A2952024-09-19019 September 2024
Site Emergency Plan Implementing Procedure Revision
CNL-24-065, Tennessee Valley Authority – Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2024-09-18018 September 2024
Tennessee Valley Authority – Central Emergency Control Center Emergency Plan Implementing Procedure Revisions
IR 05000260/20240902024-09-17017 September 2024
NRC Inspection Report 05000260/2024090 and Preliminary White Finding and Apparent Violation - 1
CNL-24-062, Cycle 16 Reload Analysis Report2024-09-16016 September 2024
Cycle 16 Reload Analysis Report
ML24255A8862024-09-10010 September 2024
Core Operating Limits Report for Cycle 16 Operation, Revision 0
ML24239A3332024-09-0303 September 2024
Full Audit Plan
IR 05000259/20244042024-09-0303 September 2024
Cyber Security Inspection Report 05000259/2024404 and 05000260-2024404 and 05000296/2024404-Cover Letter
IR 05000259/20240052024-08-26026 August 2024
Updated Inspection Plan for Browns Ferry Nuclear Plant, Units 1, 2 and 3 - Report 05000259/2024005, 05000260/2024005 and 05000296/2024005
ML24225A1682024-08-16016 August 2024
– Notification of Inspection and Request
ML24219A0272024-08-0606 August 2024
Response to NRC Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Examinations
IR 05000259/20244022024-08-0606 August 2024
Security Baseline Inspection Report 05000259/2024402 and 05000260/2024402 and 05000296/2024402
IR 05000259/20240022024-08-0202 August 2024
Brown Ferry Nuclear Plant – Integrated Inspection Report05000259/2024002 and 05000260/2024002 and 05000296/2024002
ML24199A0012024-07-22022 July 2024
Clarification and Correction to Exemption from Requirement of 10 CFR 37.11(c)(2)
ML24172A1342024-07-15015 July 2024
Exemptions from 10 CFR 37.11(C)(2) (EPID L-2023-LLE-0024) - Letter
ML24183A4142024-07-10010 July 2024
– License Renewal Regulatory Limited Scope Audit Regarding the Environmental Review of the License Renewal Application (EPID Number: L-2024-SLE-0000) (Docket Numbers: 50-259, 50-260, and 50-296)
05000296/LER-2024-003, Main Steam Relief Valves Lift Settings Outside of Technical Specifications Required Setpoints2024-07-0808 July 2024
Main Steam Relief Valves Lift Settings Outside of Technical Specifications Required Setpoints
05000259/LER-2024-001-01, Inoperability of Unit 3 Diesel Generator Due to Relay Failure2024-07-0303 July 2024
Inoperability of Unit 3 Diesel Generator Due to Relay Failure
ML24184A1142024-07-0202 July 2024
Site Emergency Plan Implementing Procedure Revision
ML24183A3842024-07-0101 July 2024
Registration of Use of Cask to Store Spent Fuel (MPC-364, -365)
ML24179A0282024-06-26026 June 2024
Evaluation of Effects of Out-of-Limits Condition as Described in IWB-3720(a)
05000259/LER-2024-002, Reactor Scram Due to Generator Step-Up Transformer Failure2024-06-24024 June 2024
Reactor Scram Due to Generator Step-Up Transformer Failure
ML24176A1132024-06-23023 June 2024
American Society of Mechanical Engineers, Section XI, Fourth 10 Year Inspection Interval, Inservice Inspection, System Pressure Test, Containment Inspection, and Repair and Replacement Programs, Owner’S Activity Report Cycle 21 Oper
ML24175A0042024-06-23023 June 2024
Interim Report of a Deviation or Failure to Comply Associated with a Valve in the Unit 3 High Pressure Coolant Injection System
ML24089A1152024-06-21021 June 2024
Transmittal Letter, Environmental Assessments and Findings of No Significant Impact Related to Exemption Requests from 10 CFR 37.11(c)(2)
2024-09-03
[Table view]
Category:Report
MONTHYEARML24179A0282024-06-26026 June 2024
Evaluation of Effects of Out-of-Limits Condition as Described in IWB-3720(a)
ML24047A2092024-02-22022 February 2024
Calendar Year 2023 Baseline Inspection Completion
ML23192A4472023-07-31031 July 2023
Staff Assessment of Updated Seismic Hazards at TVA Sites Following the NRC Process for the Ongoing Assessment of Natural Hazards Information
ML23025A0752023-01-25025 January 2023
American Society of Mechanical Engineers, Section XI, Third 10 Year Inspection Interval, Inservice Inspection, System Pressure Test, Containment Inspection, and Repair and Replacement Programs, Owner’S Activity Report Cycle .
ML22363A3922022-12-28028 December 2022
Cycle 14 Mellla+ Eigenvalue Tracking Data
CNL-22-090, Request to Use a Later Edition of the American Society of Mechanical Engineers Operation and Maintenance Code and Alternative Requests for the Fifth Inservice Testing Interval2022-12-12012 December 2022
Request to Use a Later Edition of the American Society of Mechanical Engineers Operation and Maintenance Code and Alternative Requests for the Fifth Inservice Testing Interval
CNL-22-100, To Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3,in Support of Atrium 11 Fuel Use at Browns Ferry (TS-535)2022-12-0909 December 2022
To Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3,in Support of Atrium 11 Fuel Use at Browns Ferry (TS-535)
CNL-22-066, Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for in Support of Atrium 11 Fuel Use Supplement 3, Response to Request for Additional Information2022-07-18018 July 2022
Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for in Support of Atrium 11 Fuel Use Supplement 3, Response to Request for Additional Information
ML22154A4042022-06-0303 June 2022
Unit 3 Cycle 20 Mellla+ Eigenvalue Tracking Data
CNL-22-057, To Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 in Support of Atrium 11 Fuel Use2022-05-27027 May 2022
To Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 in Support of Atrium 11 Fuel Use
ML21277A1232021-10-0404 October 2021
Submittal of Browns Ferry Unit 2 Reactor Pressure Vessel Vertical Weld Flaw Evaluation
ML21246A2942021-09-29029 September 2021
Enclosufinal Ea/Fonsi for TVAs Initial and Updated Triennial Decommissioning Funding Plans for Browns Ferry Nuclear Plant ISFSIs
ML21246A2952021-09-29029 September 2021
Memo to File
CNL-20-102, 10 CFR 71.95 Report for 3-60B Casks User2020-12-16016 December 2020
10 CFR 71.95 Report for 3-60B Casks User
ML20255A0002020-09-24024 September 2020
Staff Review of Seismic Probabilistic Risk Assessment Associated with Reevaluated Seismic Hazard Implementation of the Near Term Task Force Recommendation 2.1: Seismic
ML20112F4852020-05-0606 May 2020
Staff Assessment of Flooding Focused Evaluation
CNL-19-074, Extended Power Uprate - Flow Induced Vibration Summary Report2019-09-0404 September 2019
Extended Power Uprate - Flow Induced Vibration Summary Report
CNL-19-004, Tennessee Valley Authority, Browns Ferry Nuclear Plant, Unit 2, Completion of Required Action for NRC Order EA-13-109, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions2019-06-0707 June 2019
Tennessee Valley Authority, Browns Ferry Nuclear Plant, Unit 2, Completion of Required Action for NRC Order EA-13-109, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions
CNL-19-041, Extended Power Uprate - Unit 1 Flow Induced Vibration Summary Report2019-04-16016 April 2019
Extended Power Uprate - Unit 1 Flow Induced Vibration Summary Report
CNL-19-032, Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 8, Additional Operator Training Information2019-03-13013 March 2019
Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 8, Additional Operator Training Information
ML19024A1722019-01-23023 January 2019
Enclosure 2 - TN-RAM SAR Revision 18 Changed Pages
ML18341A1292018-12-0404 December 2018
Enclosure 2 to E-53202; TN-RAM SAR Revision 18 Changed Pages (Public Version)
CNL-18-134, Extended Power Uprate - Replacement Steam Dryer Revised Analysis and Limit Curves Report2018-11-29029 November 2018
Extended Power Uprate - Replacement Steam Dryer Revised Analysis and Limit Curves Report
ML18283B5472018-10-10010 October 2018
Responding to Letter of 11/18/1977 from E. G. Case to G. Williams, Providing Environmental Qualification Information for Electrical Connectors in Reference of IE Bulletins 77-05 & 77-05A
CNL-18-112, Extended Power Uprate - Flow Induced Vibration Summary Report2018-09-13013 September 2018
Extended Power Uprate - Flow Induced Vibration Summary Report
CNL-18-060, Completion of Required Action for NRC Order EA-13-109, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions2018-05-31031 May 2018
Completion of Required Action for NRC Order EA-13-109, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions
ML18079B1402018-02-23023 February 2018
Browns Ferry Nuclear Plant, Units 1, 2, and 3: Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus
ML18053A0232018-02-22022 February 2018
Compilation of Industry Provided Information on Anchor Darling Double Disc Gate Valve Population Affected by Flowserve, Part 21 Issue of Wedge Pin Failure on an Anchor Darling Double Disc Gate Valve in Report Format with Valve Count
ML17222A3282017-09-0505 September 2017
Flood Hazard Mitigation Strategies Assessment
ML17170A0732017-06-15015 June 2017
Report Pursuant to 10 CFR 71.95 (a)(3) and (B) - Failure to Follow Conditions of TN-RAM Packaging Certificate of Compliance No. 9233
ML17114A3712017-04-20020 April 2017
Errata for BWRVIP-271NP: BWR Vessel and Internals Project, Testing and Evaluation of the Browns Ferry, Unit 2, 120 Degree Capsule
ML17033B1642017-02-0202 February 2017
American Society of Mechanical Engineers Section XI, Inservice Inspection, System Pressure Test, Containment Inservice Inspection, and Repair and Replacement - Cycle 11 Operation Programs
ML17024A0362016-12-31031 December 2016
Operating Data Report for 2016
CNL-16-169, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 35, Consolidated Power Uprate Safety Analysis Report Revision2016-10-28028 October 2016
Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 35, Consolidated Power Uprate Safety Analysis Report Revision
ML16196A0882016-08-0505 August 2016
Staff Assessment of Response to 10 CFR 50.54(f) Information Request - Flood Causing Mechanism Reevaluation
ML16146A0182016-05-25025 May 2016
Special Report 296/2016-001 for Inoperable Post Accident Monitoring (PAM) Instrumentation
ML16028A2952016-01-29029 January 2016
10 CFR 71.95 Notification Associated with the Failure to Observe Certificate of Compliance Condition of the 8-120B Secondary Lid Test Port Configuration
ML16027A0592016-01-27027 January 2016
Snubbers Added to Inservice Testing Program
ML15356A6542015-12-22022 December 2015
Submittal of 10 CFR 50.46 30-Day Report
CNL-15-056, Application to Modify Technical Specification 2.1.1.2, Reactor Core Minimum Critical Power Ratio Safety Limits (TS-506)2015-09-25025 September 2015
Application to Modify Technical Specification 2.1.1.2, Reactor Core Minimum Critical Power Ratio Safety Limits (TS-506)
NL-15-169, Browns Ferry, Units 1, 2, and 3, Startup Test Plan2015-09-21021 September 2015
Browns Ferry, Units 1, 2, and 3, Startup Test Plan
NL-15-169, Browns Ferry Units 1, 2 and 3, Flow Induced Vibration Analysis and Monitoring Program2015-09-21021 September 2015
Browns Ferry Units 1, 2 and 3, Flow Induced Vibration Analysis and Monitoring Program
NL-15-169, Non-Proprietary - Safety Analysis Report for Browns Ferry, Units 1, 2 and 3, Extended Power Uprate, Attachment 72015-09-21021 September 2015
Non-Proprietary - Safety Analysis Report for Browns Ferry, Units 1, 2 and 3, Extended Power Uprate, Attachment 7
ML15282A1812015-09-21021 September 2015
Non-Proprietary - Safety Analysis Report for Browns Ferry, Units 1, 2 and 3, Extended Power Uprate, Attachment 7
ML15282A2402015-09-21021 September 2015
Startup Test Plan
ML15282A2392015-09-21021 September 2015
Flow Induced Vibration Analysis and Monitoring Program
ML15254A5432015-09-11011 September 2015
Submittal of 10 CFR 72.48 Changes, Tests, and Experiments, Biennial Summary Report Associated with the Independent Spent Fuel Storage Installation
ML15282A1842015-08-31031 August 2015
ANP-3377NP, Browns Ferry Units 1, 2 and 3 LOCA Break Spectrum Analysis Atrium 10XM Fuel (Epu)
ML15282A1822015-08-31031 August 2015
ANP-3403NP, Revision 2, Fuel Uprate Safety Analysis Report for Browns Ferry Units 1, 2, and 3, Attachment 9
ML15282A2362015-08-31031 August 2015
NEDO-33824, Revision 0, Engineering Report, Browns Ferry Replacement Steam Dryer Stress Analysis.
2024-06-26
[Table view]
Category:Miscellaneous
MONTHYEARML24047A2092024-02-22022 February 2024
Calendar Year 2023 Baseline Inspection Completion
ML23025A0752023-01-25025 January 2023
American Society of Mechanical Engineers, Section XI, Third 10 Year Inspection Interval, Inservice Inspection, System Pressure Test, Containment Inspection, and Repair and Replacement Programs, Owner’S Activity Report Cycle .
CNL-22-090, Request to Use a Later Edition of the American Society of Mechanical Engineers Operation and Maintenance Code and Alternative Requests for the Fifth Inservice Testing Interval2022-12-12012 December 2022
Request to Use a Later Edition of the American Society of Mechanical Engineers Operation and Maintenance Code and Alternative Requests for the Fifth Inservice Testing Interval
CNL-18-060, Completion of Required Action for NRC Order EA-13-109, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions2018-05-31031 May 2018
Completion of Required Action for NRC Order EA-13-109, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions
ML18053A0232018-02-22022 February 2018
Compilation of Industry Provided Information on Anchor Darling Double Disc Gate Valve Population Affected by Flowserve, Part 21 Issue of Wedge Pin Failure on an Anchor Darling Double Disc Gate Valve in Report Format with Valve Count
ML17170A0732017-06-15015 June 2017
Report Pursuant to 10 CFR 71.95 (a)(3) and (B) - Failure to Follow Conditions of TN-RAM Packaging Certificate of Compliance No. 9233
ML17033B1642017-02-0202 February 2017
American Society of Mechanical Engineers Section XI, Inservice Inspection, System Pressure Test, Containment Inservice Inspection, and Repair and Replacement - Cycle 11 Operation Programs
ML17024A0362016-12-31031 December 2016
Operating Data Report for 2016
ML16146A0182016-05-25025 May 2016
Special Report 296/2016-001 for Inoperable Post Accident Monitoring (PAM) Instrumentation
ML16028A2952016-01-29029 January 2016
10 CFR 71.95 Notification Associated with the Failure to Observe Certificate of Compliance Condition of the 8-120B Secondary Lid Test Port Configuration
ML15356A6542015-12-22022 December 2015
Submittal of 10 CFR 50.46 30-Day Report
ML15254A5432015-09-11011 September 2015
Submittal of 10 CFR 72.48 Changes, Tests, and Experiments, Biennial Summary Report Associated with the Independent Spent Fuel Storage Installation
CNL-15-106, 3, Sequoyah and Watts Bar, Units 1 & 2 - Provides Service List Update for Routine Information2015-07-0808 July 2015
3, Sequoyah and Watts Bar, Units 1 & 2 - Provides Service List Update for Routine Information
ML14356A3622015-02-11011 February 2015
Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-13-109 (Severe Accident Capable Hardened Vents)
CNL-14-210, Expedited Seismic Evaluation Process Report (CEUS Sites) Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima2014-12-22022 December 2014
Expedited Seismic Evaluation Process Report (CEUS Sites) Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima
CNL-14-129, Third Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Browns Ferry Nuclear Plant2014-08-28028 August 2014
Third Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Browns Ferry Nuclear Plant
L-14-254, 10 CFR 71.95 Report on the TN-RAM Package2014-08-15015 August 2014
10 CFR 71.95 Report on the TN-RAM Package
NRC-14-0058, 10 CFR 71.95 Report - Failure to Observe Certificate of Compliance Conditions for the TN-RAM Cask Due to As-Built Discrepancies Identified by Cask Certificate Holder2014-08-13013 August 2014
10 CFR 71.95 Report - Failure to Observe Certificate of Compliance Conditions for the TN-RAM Cask Due to As-Built Discrepancies Identified by Cask Certificate Holder
LR-N14-0175, CFR 71.95 Report for Packaging and Transporting a Shipping Cask (Model TN-RAM) Without Meeting a Required Condition in Certificate of Compliance 71-92332014-08-11011 August 2014
CFR 71.95 Report for Packaging and Transporting a Shipping Cask (Model TN-RAM) Without Meeting a Required Condition in Certificate of Compliance 71-9233
ML14066A3012014-03-18018 March 2014
Staff Assessment of the Seismic Walkdown Report Supporting Implementation of Near-Term Task Force Recommendation 2.3 Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident
ML13177A3522013-07-16016 July 2013
Review of Commitment Submittal for License Renewal Regarding the One-Time Inspection Procedure
ML13144A5762013-05-22022 May 2013
Watt Bar, Units 1 & 2, Report of Drug Testing Error in Accordance with 10 CFR 26.719(c)(1)
ML13115A9552013-05-16016 May 2013
Final ASP Analysis-Browns Ferry Nuclear Plant, Unit 3, Reactor Trip and Subsequent Loss of Offsite Power Due Failure of Unit Station System Transformer Differential Relay (LER 296/12-004)
ML13092A3922013-03-27027 March 2013
Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition - Transition Report
ML12356A1762012-11-30030 November 2012
Kld TR-505, Rev. 1, Development of Evacuation Time Estimates, Part 6 of 8
ML12335A3402012-11-27027 November 2012
Tennessee Valley Authority - Fleet Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding the Flooding Walkdown Results of Recommendation 2.3 of the Near-Term Task Force Review of
ML1127000692011-09-26026 September 2011
Enclosure 2, Mfn 10-245 R4, Description of the Evaluation and Surveillance Recommendations for BWR/2-5 Plants
ML1108712502011-03-24024 March 2011
BWR Vessel and Internals Inspection Summaries for Spring 2010 Outages
ML1100502872010-06-22022 June 2010
Investigation of Tritium Releases to Groundwater
ML1019304172010-05-0606 May 2010
Tritium Database Report
ML12171A1892010-03-31031 March 2010
Integrated Resource Plan, TVAs Environmental & Energy Future
ML1008800282010-03-24024 March 2010
Day Report of Emergency Core Cooling System Evaluation Model Changes
ML1002010142010-01-15015 January 2010
Attachment 2, Browns Ferry, Unit 1 Response to NRC Request for Supplemental Information Regarding Technical Specification Change TS-467 - Utilization of Areva Fuel and Associated Analysis Methodologies
ML1002010152010-01-15015 January 2010
NEDO-32484, Rev. 7, Browns Ferry Nuclear Plant Units 1, 2, and 3 SAFER/GESTR-LOCA Loss-of-Coolant Accident Analysis
ML1002010162010-01-15015 January 2010
Gnf 0000-0111-8036-R0-NP, GE14 Fuel Thermal-Mechanical Information
ML1011602102009-10-0606 October 2009
51-9121503-002, Engineering Information Record, Responses to NRC Comments Regarding Browns Ferry Unit 1 Proposed Fuel Transition Amendment
ML0924605002009-08-31031 August 2009
CDI Report No. 09-25NP, Rev. 0, Stress Assessment of Browns Ferry Nuclear, Unit 1 Steam Dryer to 120% OLTP Power Level, Enclosure 5
ML0834600222008-11-30030 November 2008
Enclosure 2 - Browns Ferry, Units 1, 2, & 3 - Technical Specifications Changes TS-418 and TS-431 - Extended Power Uprate - CDI Report 07-11NP, Revision 1, Dynamics of BWR Steam Dryer Components, Non-Proprietary Version
ML0711503692007-04-23023 April 2007
Units 1, 2, & 3 - Submittal of Unit 1 Periodic Inspection Program for License Renewal Procedure in Fulfillment of License Renewal Commitment
ML0710303972007-04-13013 April 2007
Status of Unit 1 Restart Issues, Revision 12
ML0635300372006-12-14014 December 2006
Core Operating Limits Report for Cycle 7 Operation
ML0631004422006-11-0101 November 2006
Supplemental Information - Changes to Instrumentation Surveillance Test Intervals and Allowed Out-of-Service Times
ML0622002772006-07-26026 July 2006
Technical Specifications (TS) Changes TS-431 & TS-418 - Extended Power Uprate (EPU) - Response to Round 7 Requests for Additional Information
ML0616701512006-06-12012 June 2006
Extended Power Uprate (EPU) - Reload Analysis Report
ML0625103852006-05-31031 May 2006
Enclosure 3, Browns Ferry, Units 1, 2 & 3 - CDI Report No. 05-28P, Rev 1, Bounding Methodology to Predict Full Scale Steam Dryer Loads from In-Plant Measurements.
ML0614503952006-05-15015 May 2006
0043-8325-SRLR, Revision 1, Supplemental Reload Licensing Report for Brown Ferry 1, Reload 6 Cycle 7, Cover Through Page 122
ML0614503972006-05-15015 May 2006
0043-8325-SRLR, Revision 1, Supplemental Reload Licensing Report for Brown Ferry 1, Reload 6 Cycle 7, Pages 123 Through End
ML0608804132006-03-21021 March 2006
EPU Containment Overpressure Credit Risk Assessment, Rev. 1
ML0607204302006-03-0101 March 2006
March 1, 2006 Public Meeting Slides for Proposed Generic Letter Post-Fire Safe-Shutdown Circuit Analysis Spurious Actuations.
ML0513004622005-04-27027 April 2005
Technical Specifications Change 438- Response to Request for Additional Information Regarding Excess Flow Check Valve Surveillance Test Frequency
2024-02-22
[Table view] |
Text
Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 June 15, 2017 10 CFR 71.95(c)
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Washington, DC 20555-000 1 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, 50-296
SUBJECT:
Report Pursuant to 10 CFR 71.95 (a)(3) and (b)
- Failure to Follow Conditions of TN-RAM Packaging Certificate of Compliance No. 9233
REFERENCE:
Certificate of Compliance No. 9233 for the TN-RAM Packaging, Revision 14 The Tennessee Valley Authority (TVA) is submitting this report pursuant to 10 CFR 71.95(a)(3) and (b) with respect to Certificate of Compliance (CoC) No. 9233, Revision 14, for the TN-RAM Packaging, Docket No. 71-9233. WA is an authorized user of the TN-RAM packaging under the provisions of 10 CFR 71.17, General License: NRC-approved package.
Only one TN-RAM packaging has been fabricated and in use since 1989, prior to the discovery that the attachment points not intended for package lifting or tie-down were not rendered inoperable for transport operations as required by 10 CFR 71.87(h) and 49 CFR 173.41(b). The failure to render the impact limiter lifting lugs inoperable was noted during routine operations by a party other than WA. Further review of the design determined that the attachment points intended for lifting the impact limiters will not withstand the static force required for lifting and tie-down in 10 CFR 71.45.
Immediate action was taken to install a cover on each impact limiter lifting lug retained by a bolt installed in the lifting lug through hole, which renders the attachment point inoperable.
In addition to installing the cover, a durable marking, stating "IMPACT LIMITER LIFTING ONLY,"
was placed near each impact limiter lifting lug to identify the intended use of the lifting lugs.
U.S. Nuclear Regulatory Commission Page 2 June 15, 2017 A written report, as required by 10 CFR 71.95(c), is provided as Enclosure 1.
There are no new regulatory commitments associated with this submittal. If you should have any questions regarding this submittal, please contact Ed Schrull at (423) 751-3850.
Enclosure:
10 CFR 71.95 Report cc (Enclosure):
NRC Regional Administrator
- Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Senior Resident Inspector - Sequoyah Nuclear Plant NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRC Project Manager for TN-RAM, SFM Licensing Branch
Enclosure 10 CFR 71.95 Written Report Information required by 10 CFR 71.95(c) was prepared by TN Americas LLC and is included as an attachment to this enclosure. Additional licensee-specific information is provided below.
(2)(ii) Dates and approximate times of occurrences The TN-RAM cask was used for shipments from the Browns Ferry Nuclear Plant (BFN) on the following dates:
10/11/2012 12/17/2012 1/14/2013 1/23/2013 2/4/2013 2/13/2013 2/18/2013 2/28/2013 3/11/2013 (6) Contact information Please contact WA Corporate Nuclear Licensing Manager Ed Schrull at (423) 751-3850 with any questions regarding this report.
Attachment (6 pages follow): 10 CFR 71.95 Written Report
10 CFR 71.95 Written Report (1) Abstract The TN-RAM package has trunnions intended as attachment points for lifting and tie-down. The trunnions are a structural part of the package that is designed to meet the requirements of the regulation for lifting and tie-down. Attachment points for lifting the impact limiters during installation and removal are a structural part of the impact limiters that are part of the TN-RAM package. An evaluation of the TN-RAM lifting attachment points demonstrates that the trunnions and impact limiter lifting lugs have been designed only for their intended use. Inadvertent use of the impact limiter lifting tugs to lift or tie-down the TN-RAM would impair the ability of the package to meet requirements for transport. However, operation of the TN-RAM has not included any controls to render the impact limiter lifting tugs inoperable during transport operations as required by transport regulations. An evaluation of the lifting and tie-down operations has been done to determine the extent of the condition and appropriate corrective actions to render the impact limiter tugs inoperable. A review of the NRC 10 CFR Part 71.78(h) regulatory requirements for Operating Controls and Procedures determined that use of the cask without rendering the impact limiter tugs inoperable is a practice that did not follow the conditions of the certificate of compliance.
(2) Description of the event (i)
Status of components or systems that were inoperable at the start of the event and that contributed to the event The TN RAM cask system is a Type 8 transportation package design approved by the NRC (71-9233). The package is a steel encased lead shielded cask with wood impact limiters attached at both ends. The impact limiters are a packaging component that is required by the NRC approval of the package design. Impact limiters protect the cask shell and contents by absorbing shocks from impacts incidental to normal and accident transportation conditions. The cask shell is a right circular cylinder with trunnions welded to the outer shell for lifting and tie-down. The overall dimensions of the packaging are approximately 178 inches long and 92 inches diameter with the impact limiters installed.
The cask body is approximately 129 inches long with an outer diameter of 51 inches. The maximum gross weight of the package is approximately 80,000 lbs. The structural evaluation for tie-down and lifting devices in the TN-RAM SAR states that there are no other structural parts of the package which can be used for tie down attachments.
(ii)
Dates and approximate times of occurrences The TN-RAM package first use was on or about 1989. The lifting lugs were not rendered inoperable during the period of operation since first use.
(iii)
The cause of each component or system failure or personnel error The TN-RAM SAR contains loading and handling guidelines that include general instructions for removal of the impact limiters using a "suitable crane and two legged sling", rotating and lifting the cask using a "suitable crane hook" to "engage the lift beam to the two front trunnions", and removal and installation of "front and rear trunnion tie-downs."
The Operations and Maintenance Manual for the TN-RAM (OM-7) expands on the handling guideline and describes the trunnions intended purpose for lifting and tie-down of the cask.
OM-7 also describes the impact limiter lifting lugs as "located such that the limiter is
10 CFR 71.95 Written Report balanced when it is lifted." The glossary of terms in OM -7 defines lifting lugs as "attachments provided on the impact limiters for handling operations," lift beams as "devices for cask lifting and handling operations," and trunnions as "handling attachments provided for cask primary lifting, support and tie-down." These definitions describe the intended purpose of attachment points. The design of the impact limiter rigging equipment is sized for attachment to the lifting lugs, and lift beams are specialized lifting devices that are designed for attachment to the trunnions. A dynamometer is installed between the crane hook and sling that is attached to the lifting lugs. The dynamometer is used to support the weight to allow removal of impact limiter bolts, and the procedure requires "lift up on the sling until a reading of 3700, +0, -100 pounds is indicated on the dynamometer."
Any attempt to lift the weight of the TN-RAM package would exceed 3700 pound reading on the dynamometer. Tie-down members for the TN-RAM are trailer support pedestals specially designed for attachment to the trunnions.
The tarp installed over the support frame during transport has been considered a control to render the impact limiter lugs inoperable. The tarp when installed blocks access to the impact limiter lugs, but the lifting tugs are accessible when the tarp and support frame are removed for handling operations. Transport operations include the preparation of the package for transport (installing impact limiters), securing the package to the trailer for transit (tie-down), and receiving the package (removing impact limiters). During preparation for transport and receipt of the TN-RAM, the impact limiters are installed without the tarp in place. Prior to removal of the impact limiters and after installation the lift lugs are accessible.
Rigging equipment or tie-down members could inadvertently be attached to the lift tugs.
However, lifting or tie-down of the TN-RAM using the lifting lugs would require intentional misuse of the rigging equipment and tie-down members, and violate operational controls and procedures for handling the cask. A method for rendering the lift lugs inoperable is required to prevent attachment to these points during preparation and receipt phases of transport operations. The tarp does not meet the intent of the requirement in the regulation to render the attachment point inoperable during all phases of transport operations.
(iv)
The failure mode, mechanism, and effect of each failed component The impact limiter attachment points are intended only for lifting the impact limiter during removal and installation white the TN-RAM package is attached to the transportation trailer. Each impact limiter weighs approximately 3700 lbs. The impact limiter shell is a structural part of the packaging that retains the wood shock absorber. The shell is sealed to protect the wood material from environmental conditions incident to routine use.
The impact limiter lifting lugs are designed for a safety factor against yield that is consistent with accepted industry standards for material handling using standard rigging equipment.
10 CFR 71.95 Written Report The nominal design weight of the impact limiter is 3695 lbs. The most likely failure mechanism or "weak link" in the attachment point on the impact limiter would be a tensile breakage of the lifting lug. Attempting to lift the package using the impact limiter lifting lugs would not result in damage to the structural inipact limiter shell that would impair the ability to meet transport requirements.
The lifting lugs were not intended to tie-down of the TN-RAM during for transport. The stress applied to the lifting lugs used at attachment points for tie-down would be different than for the intended use to lift the impact limiters. A review of the impact limiter lifting design basis indicates that the lifting lugs would not withstand the stress applied by static forces required for tie-down in 71.45(a) or static force required by DOT for Protection Against Shifting and Falling Cargo (49 CFR 393).
(v)
A list of systems or secondary functions that were also affected for failures of components with multiple functions Lifting lugs are designed for the single purpose of lifting the impact limiter.
(vi)
The method of discovery of each component or system failure or procedural error Failure to render the impact limiter lugs inoperable was noted during routine operation of the TN-RAM.
(vii)
For each human performance-related root cause, a discussion of the cause(s) and circumstances Approved operational procedures and controls in place were followed since first use of the cask. There is no known instance of lifting or tie-down of the TN-RAM using the lifting lugs during nearly 30 years operating experience.
(viii)
The manufacturer and model number (or other identification) of each component that failed during the event No failure of the impact limiter lifting lugs occurred on the TN-RAM No. 001.
(ix)
For events occurring during use of a packaging, the quantities and chemical and physical form(s) of the package contents Quantities of radioactive material in form of activated metals shipped during use of the package varied during use. During this period of use the package contents was limited to about 14,000 Ci Co-60 equivalent activity that was recently increased in 2015 to a allow up to 30,000 Ci Co-60 equivalent activity.
(3) Safety Significance The lifting lugs when used as intended have been evaluated to meet industry standards for rigging and material handling. Attempting to lift the TN-RAM using the lifting lugs would result in a yielding and tensile failure of the lifting lug. The structural shell of the impact limiter would not likely be damaged due to attempting to lift the package using the lifting lugs. Stresses generated in the impact limiter shell when used as a tie-down attachment point for securement of load during
10 CFR 71.95 Written Report transport have not been analyzed. Using the impact limiter lifting lugs as tie-down attachment points could generate stresses in the impact limiter shell that could result in tears or cracks.
Undetected during the normal use or periodic inspections, these defects would allow moisture ingress and eventual degradation of the wood impact absorbing material that would impair the performance of the package during normal and accident transport conditions.
(4) Corrective Actions Both engineering and administrative controls have been implemented to prevent inadvertent use of the impact limiter lugs for lifting or tie-down of the package. The engineering control is a cover for each impact limiter lifting lug that is retained by a bolt installed in the lifting lug through hole to render the attachment point inoperable. The lifting lug covers prevent attachment of rigging equipment or tie down members to the impact limiters lift lugs during transport (Figure 1).
Figure 1 - Lifting Lug Cover An administrative control identifies the intended use of the impact limiter lifting lugs by a durable marking near each impact limiter lifting lug stating "IMPACT LIMITER LIFTING ONLY" (Figure 2).
Additionally a statement should be added in the SAR Chapter 7-Operations and Operations and Maintenance Manual, OM-07 "TN RAM Operations Manual" subsection 8.5 that would require rendering the impact limiter lifting lugs inoperable and stating the allowed attachment points for lifting and tie-down of the TN-RAM. The SAR Chapter 7 is a condition of the § 71.17, General license: NRC-approved package, and OM-7 is provided to the cask users as a guide with more detailed instructions on implementing the operations requirements in the SAR.
4
10 CFR 71.95 Written Report Neither TN-RAM SAR Ch. 7-Operations or previous versions of Operations and Maintenance manual OM -7 include a requirement to render inoperable attachment points that are structural part of the package and not designed for intended package lifting or tie-down. The most recent version of OM-7 however, did add a requirement to render the lifting lugs inoperable by installing a bolt through the lug, or other similar method.
Figure 2-Lifting Lug Marking (5) Extent of the Condition Operating procedures and design of the lift beam that are intended for lifting the cask and the lifting lugs make it improbable that the lift beam would be attached to the lifting lugs.
Furthermore, the trailer trunnion pedestals are tie-down members specifically designed for attachment to the trunriions making it improbable that generic tie-down members attached to the lifting lugs would be used to secure the TN-RAM to the trailer.
The design and operation of the TN -RAM limits the possibility of inadvertent use of the impact limiter lifting lugs as package lifting or tie-down attachment points.
All lifting and tie-down operations are controlled by detailed operating procedures and performed by trained and qualified personnel. The TN-RAM cask shell is lifted without the impact limiters installed. Impact limiters are removed from the cask shell prior to lifting operations to remove the cask shell from the trailer, and likewise the impact limiters are installed after lifting operations to place cask shell on the trailer is complete.
Handling is done exclusively by persons trained in operation of the TN-RAM at the loading facility and unloading facilities, and transport is by exclusive use on a specialized trailer.
(6) Contact information
[The name and telephone number of a person within the licensee's organization who is knowledgeable about the event and can provide additional information]
10 CFR 71.95 Written Report (7) Extent of exposure of individuals to radiation or to radioactive materials No individuals were exposed to radiation or to radioactive materials as a consequence of not rendering the impact limiter lifting lugs inoperable during transport operations.
