ML22101A250
| ML22101A250 | |
| Person / Time | |
|---|---|
| Site: | 07105797 |
| Issue date: | 04/08/2022 |
| From: | Shuler J US Dept of Energy, Office of Packaging and Transportation |
| To: | Yoira Diaz-Sanabria Storage and Transportation Licensing Branch |
| Pierre Saverot NMSS/DFM/STL 301-415-7505 | |
| References | |
| Download: ML22101A250 (8) | |
Text
De p a rt m e n t o f Ene rg y Wa s h in gto n , DC 20585 April 8, 2022 Yoira K. Diaz-Sanabria, Chief Storage and Transportation Licensing Branch U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Two White Flint North - Mail Stop 4 B34 11555 Rockville Pike Rockville, MD 20852-2738
Dear Yoira K. Diaz-Sanabria,
In reference to NRC Certificate of Compliance (CoC) No 5797, Rev. 22 (Docket 71-5797), this letter is the certificate holders notification to NRC of nonconformances of the Tie Down Band (TDB) as-built dimensions with its design shown on CoC drawing (M-20978-EL-008E, Rev. C).
The TDB is also shown on CoC drawings (M-20978-EL-002E, Rev. E, M-20978-EL-003E, Rev.
F), for the High Flux Isotope Reactor (HFIR) Unirradiated Fuel Element Shipping Containers.
The TDB is not an important to safety packaging component for HFIR Shipping Containers to meet 10 CFR Part 71. The as-built configuration of the TDB has been used, without incident, since at least 1989 as shoring of HFIR Shipping Containers in the transport vehicle.
The application (Enclosures 1 & 2) with this request includes a description of the nonconformances, an evaluation of the TDB with respect to the Safety Analysis Report (SAR) for Packaging and CoC, notification to registered users, current and future path forward, and a comparison of the authorized and as-built designs of the TDB.
The Department of Energy (DOE) is hereby requesting NRC to amend CoC 5797, Rev. 22, by a letter of authorization (LoA), so that package users may continue using the as-built configuration of the TDB based on the enclosed application. This LoA is urgently needed for use of the package for shipment of fresh fuel for the DOE High Flux Isotope Reactor.
If you have any questions or need more details, please call at 301-903-5513 or james.shuler@em.doe.gov.
JAMES Digitally signed by JAMES SHULER SHULER Date: 2022.04.08 13:07:38
-04'00' Dr. James M. Shuler Manager, DOE Packaging Certification Program U.S. Department of Energy Office of Packaging and Transportation EM-4.24, 270CC - Rm 3113 Washington, DC 20585
Docket 71-5797 April 5, 2022 CC: ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Mr. Pierre M. Saverot, Project Manager Chad Huffman, SC-ORO Gregory J. Hirtz, ORNL
Enclosures for Docket 71-5797, April 2022 ENCLOSURE 1 EVALUATION OF THE NONCONFORMANCE AND PROPOSED PATH FORWARD 1.0 Description of Nonconformance On March 25, 2022, ORNL Quality Assurance identified nonconformances of the as-built Tie Down Band (TDB) hardware configuration and components relative to its drawing, M-20978-EL-008E, Rev. C, Shipping Container for Unirradiated Out/In HFIR Element Details. The TDB (M-20978-EL-008E, Parts List Find No. 5 and 6) is an optional accessory for blocking and bracing a HFIR Shipping Container in the transport vehicle. The specific non-conformances relative to M-20978-EL-008E, Rev. C, are detailed below:
- Size of the shackles (2 places) in the as-built configuration do not conform to the drawing: In View B-B, the 3/4-inch shackle with welded pin was found to be a 7/16-inch shackle in the field; and the 1-inch shackle in View B-B was found to be a 5/8-inch shackle in the field.
- Orientation of the shackles (2 places) on the drawing is incorrect:
o The orientation of the 3/4-inch shackle in View B-B is shown with its bow through the tab hole on the TDB and its pin connected to the bow of the 1-inch shackle. This orientation is incorrect because the ear or pin of a 3/4-inch shackle would be too large to pass through the tab hole (9/16 inch).
o The orientation of the shackles on the as-built configuration is correct, but does not conform to the drawing. The pin of the 7/16-inch shackle is installed through the tab hole on the TDB and its bow is connected to pin of the 5/8-inch shackle.
- Thickness of the TDB end tabs (4 places) on the as-builts do not conform to the drawing:
The end tab thickness shown in Section A-A is 1/2 inch, whereas the end tab thickness on the as-built TDB is 1/4 inch.
2.0 Evaluation of the Nonconformances Safety Analysis Report (SAR) for Packaging and Nuclear Regulatory Commission (NRC) Certificate of Compliance (CoC) Number 5797 The TBD is not a structural part of the package and is not a credited safety component in the SAR (Safety Analysis Report for Packaging the ORNL HFIR Unirradiated Fuel Element Shipping Container, ORNL/TM-11656, Rev. 11) or NRC CoC No. 5797 (Rev 22).
The HFIR package design meets the requirements of 10 CFR Part 71, Subpart E, Package Approval Standards, without the TBD.
SAR - The TDB is not credited or evaluated in the SAR as an important-to-safety packaging component for HFIR Shipping Containers. In other words, the package does not rely on the TDB to meet Subpart E. However, the TBD is shown and referenced on three SAR/CoC drawings:
Page 1 of 6
Enclosures for Docket 71-5797, April 2022
- M-20978-EL-002E, Rev E - Parts List Find No. 17 and Section A,
- M-20978-EL-003E, Rev F - Parts List Find No. 16 and Section A, with a note For Shipping Purposes Only, and
- M-20978-EL-008E, Rev. C - Parts List Find Nos. 5 & 6 (for the HFIR Inner and Outer Shipping Containers) and Tie Down Band with Section A-A and View B-B.
Use of the TBD is optional per the SAR, Chapter 7, Section 7.1 Step 11 (see below) and the TBD is referred to as the removable shoring ring:
- 11. HFIR unirradiated fuel element container when loaded with fuel, are shipped off-site in a "sole-use" vehicle. The HFIR fuel element container is provided with a removal shoring ring which may be used to shore or tiedown the container during shipments. Appropriate shoring shall be used in the transportation of those containers.
The as-built configuration of the TDB, although not compliant with the SAR drawing, is appropriate shoring (i.e., blocking and bracing) based on the safe shipping history of HFIR Shipping Containers since at least c.1989. The maximum gross weight of the HFIR Shipping Container is 1,050 lb. The working load limit of a 7/16-inch shackle is approximately 1-1/2 metric tons (3,300 lb.), so with two 7/16-inch shackles per TDB, the shoring is appropriate for transportation of the containers.
CoC 5797 - The design detail of the TBD is shown on Drawing M-20978-EL-008E, Rev.
C and this drawing is explicitly referenced in CoC Section 5(a)(3)(i) and 5(a)(3)(ii) with the HFIR Inner and Outer Shipping Containers drawings.
Despite the non-conformance of the as-built TDB with its drawing, the as-built configuration meets the requirements of CoC Condition 7(b):
(b) Each package shall be operated and prepared for shipment in accordance with the Operating Procedures in Chapter 7 of the application.
That is, the as-built configuration of the TDB is appropriate shoring (i.e., blocking and bracing) therefore meets the Operating Procedures in Chapter 7 (Step 11), based on the safe shipping history of HFIR Shipping Containers since at least c.1989.
3.0 Notification to Registered Users Following the discovery of the nonconformances with the TBD, registered users of the package were notified by ORNL to suspend use of the packaging pending further evaluation. ORNL confirmed that there were no packages in transit when the error was identified.
Page 2 of 6
Enclosures for Docket 71-5797, April 2022 4.0 Path Forward
- a. ORNL has issued a nonconformance report on the as-built TDB in according with it Quality Assurance Program and is revising Drawing M-20978-EL-008E, Rev. C, to correct the drawing as needed (See Enclosure 2).
- b. ORNL is drafting a §71.95 report of the nonconformance if NRC believes it violates
§71.95(a)(3): Instances in which the conditions of approval in the Certificate of Compliance were not observed in making a shipment.
- c. DOE Packaging Certification Manager will request NRC to amend CoC 5797 by letter of authorization to authorize use of the as-built TBD for shipments of the HFIR Shipping Containers.
- d. ORNL will prepare a subsequent SAR amendment to correct, clarify, or remove the TDB from the SAR since it is not a credited packaging component Page 3 of 6
Enclosures for Docket 71-5797, April 2022 ENCLOSURE 2 COMPARISON BETWEEN TIE DOWN BAND CONFIGURATION ON CERTIFICATION DRAWING AND AS BUILT CONFIGURATION Page 4 of 6
Enclosures for Docket 71-5797, April 2022 FIGURE 1: Tie Down Band detail on HFIR Drawing M-20978-EL-008E, Rev. C Page 5 of 6
Enclosures for Docket 71-5797, April 2022 FIGURE 2: As-built configuration of Tie Down Band Page 6 of 6