ML24131A065
| ML24131A065 | |
| Person / Time | |
|---|---|
| Site: | 07109196 |
| Issue date: | 05/10/2024 |
| From: | Shaw D Orano TN Americas |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| E-63538 | |
| Download: ML24131A065 (1) | |
Text
orano May 10, 2024 E-63538 Orano TN 7160 Riverw ood Drive U. S. Nuclear Regulatory Commission Suite 200 Attn: Document Control Desk Columbia, MD 21046 Director, Division of Fuel Management USA Tel: 410-910-6900 Office of Nuclear Material Safety and Safeguards Fa x : 434-260-8480 Washington, D.C. 20555-001
Subject:
10 CFR 71.95 Report for Model UX-30 Transportation Package
Reference:
(1) NRC Certificate of Compliance for the Model No. UX-30, USA/9196/B(U)F-96, Revision 31
(2) Safety Analysis Report for the Model UX-30 Package, Revision 4, June 2018
(3) U.S. NRC Quality Assurance Program Approval for Radioactive Material Packages, Approval Number 0250, Revision Number 24
In accordance with 10 CFR §71.95(a)(3), TN Americas, LLC (TNA) submits two
§71.95 Reports for Certificate of Compliance (CoC) No. 9196 for the UX-30 transportation package [1]. The Model UX-30 package [2] is used for transportation of 30B uranium hexafluoride cylinders within the US and for international shipments by multiple authorized users who are NRC licensees. TN Americas, as the NRC CoC holder, submits this report on behalf of the licensees for two generic issues that may have resulted in instances in which the conditions of approval in the CoC were not observed in making a shipment.
TN Americas Quality Assurance Program [3] implementing procedure for Corrective Action TIP 16.1, determined that the generic issues are conditions of significance that require NRC Part 71, §71.95 Report. The TN Americas Corrective Action process was used to evaluate the extent of condition, perform a root cause analysis, and identity a corrective and preventive action plan for each of the generic issues.
Separate §71.95 reports are provided for each event as Enclosures 1 and 2. An application for revision to the UX-30 CoC to implement corrective actions is planned for submission to NRC by end of May 2024.
E-63538 Document Control Desk Page 2 of 2
Should the NRC staff require additional information to support review of this application, please contact Peter Vescovi at 336-420-8325, or by email at peter.vescovi@orano.group.
Sincerely,
Digitally signed by SHAW Donis ~~:.~2~~2~s,o 09:58:34 -04'00' Don Shaw Licensing Manager
cc:
Pierre Saverot, Senior Project Manager, U.S. Nuclear Regulatory Commission Bernie White, Senior Project Manager, U.S. Nuclear Regulatory Commission Peter Vescovi, Licensing Engineer, TN Americas LLC Prakash Narayanan, Chief Technical Officer, TN Americas LLC James Seals, Director of Transportation Services, TN Americas LLC Brian Ocampos, Quality Assurance Manager, TN Americas LLC
Enclosures:
- 1. NRC 71.95 Report for CAR 2024-020
- 2. NRC 71.95 Report for CAR 2024-018 NRC 71.95 Report for CAR 2024-020 E-63538 Enclosure 1
UX-30 Certificate of Compliance Condition for UF6 cylinder
(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.
Cylinders used for shipment of uranium hexafluoride (UF6) are required to be fabricated, inspected, tested, and maintained in accordance with industry standards. The industry standards specify requirements for packaging of UF6 for transport that are periodically reviewed and revised. The industry standards for UF6 cylinders have been incorporated by reference in transportation regulations.
NRC Certificate of Compliance (CoC) 9196 for the UX-30 package has a condition for approval that makes it mandatory for the 30B cylinder to be fabricated, inspected, tested, and maintained in accordance with American National Standards Institute (ANSI) N14.1-2012 or earlier versions. There have been two versions of ANSI N14.1 (2019 and 2023) issued after 2012. There may be instances in which the conditions of approval in the CoC were not observed in making a shipment of cylinders fabricated in accordance with ANSI N14.1 editions after 2012. Furthermore, DOT regulation 49 CFR 173.420 requires cylinders in compliance with ANSI N14.1 in effect at the time the packaging was manufactured.
ANSI periodically revises and updates its Standards by issuing new editions; the NRC's practice is to incorporate those new editi ons into the NRC's regulations. The NRC regulations do not incorporate by reference ANSI Standards for 10 CFR Part 71, Packaging and Transportation of Radioactive Materials as is done for other NRC regulations and DOT 49 CFR Ch. I. NRC does recommend the use of industry standards and codes in generic guidance documents and may include a reference to a standard or code as a condition of approval in a Part 71 CoC for radioactive material package designs.
Previous editions of ANSI N14.1 are superseded by revisions but continued use of UF6 cylinders fabricated using previous versions is allowed. Although UF6 cylinders may be fabricated to an edition of ANSI N14.1 in effect at time of fabrication, periodic inspections and maintenance requirements specified in the version of ANSI N14.1 in effect at time of use are required for cylinders to remain in service. The NRC issues Part 71 package design approvals for a duration of 5 years with rules for renewal or revision of the CoC. ANSI N14.1 may have been revised while NRC CoC 9196 was in effect or the version of ANSI N14.1 was not updated in the application for the next revision or renewal. Not changing the effective date for ANSI N14.1 in the NRC CoC 9196 condition of approval may have been intended to allow time for NRC review of the changes to the standard or possibly an unintentional omission during application for renewal or revision of the CoC.
Significant corrective actions include submission of an application by the CoC holder to request the condition of approval be revised to reference the latest ANSI N14.1 edition and TN Quality Assurance Program implementing procedure for Control of Licensing
Pa ge1of7 NRC 71.95 Report for CAR 2024-020 E-63538 Enclosure 1
Documents, TIP 5.4, will be revised to include checking the effective date of standards and codes incorporated by reference in the NRC CoC.
The Model UX-30 package is used for transportation of 30B uranium hexafluoride cylinders within the US and for international shipments by multiple authorized users who are NRC licensees. TN Americas as the NRC CoC holder submits this report on behalf of the licensees for instances in which the conditions of approval in the CoC were not observed in making a shipment.
(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;
ANSI N14.1, Nuclear Materials-Uranium Hexafluoride-Packagings Transport (1971, 1982, 1987, 1990, 1995, 2001, 2012, 2019 and 2023 Editions) was developed under the procedures of the American National Standards Institute by Subcommittee N14-8 (later changed to N14-1) of Accredited Standards Committee N14 on Transportation of Fissile and Radioactive Materials.
The packaging and transport of UF6 is subject to regulation by government agencies having jurisdiction over packaging and transport. This standard does not take precedence over applicable U.S. Nuclear Regulatory Commission (NRC), U.S. Department of Energy (DOE), U.S. Department of Transportation (DOT), or other governmental regulations.
This standard covers only those standard cylinders that meet all of the acceptance criteria for UF6 handling and is recommended for all new cylinder construction. Cylinders currently in service and not in accordance with this standard are acceptable for continued use, provided that they are inspected, tested, and maintained so as to comply with the intent of this standard and are used within their original design limitations.
In all instances of shipping 30B cylinders in the UX-30 using NRC CoC 9196 complied with the intent of ANSI N14.1 even though there may have been instances where the 30B cylinder was fabricated to an edition of ANSI N14.1 issued after 2012.
(ii) Dates and approximate times of occurrences;
DOT 49 CFR Chapter I Part 173 specifies requirements for UF6 packagings in section 173.420 -Uranium hexafluoride. Section 173.420 authorizes the use of packagings designed, fabricated, and marked in accordance with ANSI N14.1 or Section VIII of the ASME Code provided the packaging was manufactured on or before June 30, 1987. Since
Pa ge2of7 NRC 71.95 Report for CAR 2024-020 E-63538 Enclosure 1
the October 1, 2004 edition of 49 CFR Ch. I Part 173, ANSI N14.1 is incorporated by reference to Section 171.7 within 173.420. Both the ASME Code edition year and editions of ANSI N14.1 are incorporated by reference into 173.420 in Section 171.1 as summarized in the table below. The amendments of 49 CFR Ch. I Part 173 shown in the table are years when there was a change to either ASME Code or ANSI standards references.
49 CFR Ch. I Part ASME BPVC Section ANSI N14.1 173 Amendments VIII Div I (173.420 (2)(i))
(173.420 (2)(ii))
October 1, 1987 Not referenced 1982 Edition October 1, 1995 1992 Edition and 1971, 1982, 1987, and Addenda through 1990 Editions December 31, 1993 October 1, 2003 1998 Edition 1971, 1982, 1987, 1990 and 2001 Editions October 1, 2004 1998 Edition 1971, 1982, 1987, 1990, 1995 and 2001 Editions November 23, 2015 Edition 1971, 1982, 1987, 2015 1990, 1995 and 2001 Editions December 28, 2017 Edition 1971, 1982, 1987, 2020 to April 10, 1990, 1995 and 2001 2924 Editions
Code of Federal Regulations (Annual Edition) l GovInfo
There is an NRC Certificate of Compliance (CoC) 9196 that authorizes the Model UX-30 package design for protection of 30B UF6 cylinders during transportation. The NRC CoC number 9196 was initially issued in 1984 for Type AF package design and evolved to the present Type B(U)F package design approval. A CoC condition of approval requires cylinders to be compliant with industry standards for UF6 packaging. The requirement is for UF6 cylinders to be fabricated, inspected, tested, and maintained in accordance with the industry standards.
NRC CoC 9196 Package design Industry standard referenced in NRC approval type CoC 9196 Revision Issued 0 - 3 1984 -1991 Type AF ORO-651 Rev 3 4 - 6 1991 - 1992 Type AF ANSI N14.1-1990 7 - 14 1996 - 1998 Type AF ANSI N14.1-1990 15 1999 Type AF ANSI N14.1-1995 18 2001 Type AF ANSI N14.1-1995 19 - 26 2004-2011 Type AF-85 ANSI N14.1-2001 an ISO 7195:1993(F) 27 - 31 2013-2023 Type B(U)F-96 ANSI N14.1-2012 and
Pa ge3of7 NRC 71.95 Report for CAR 2024-020 E-63538 Enclosure 1
ISO 7195:2005
Initially ORO-651 and ASME BPVC Section VIII Div I were referenced in the NRC CoC.
The condition was revised to replace ORO-651 with ANSI N14.1 in Revision 4, and later ISO 7195 was added in Revision 19 to the re quirement. Prior to 1990, there were two editions of ANSI N14.1 that were in effect in 1982 and 1987 that could have been referenced in CoC 9191 Revision 0, 1, 2, and 3. ORO 651 Revision 3 was the industry standard referenced in the initial issue of CoC 9196 and was not changed until NRC condition of approval referenced ANSI N14.1-1990 in CoC 9196 Revision 4 that was issued in 1991.
The CoC condition of approval continued to reference ANSI N14.1-1990 through CoC 9196 Revision 14 that was issued in 1998. ASNI N14.1-1995 was in effect when CoC 9196 Revisions 1 through 14 were issued between 1996 and 1998.
The CoC 9196 Revisions 15, 16, and 17 issued in 1999 did reference ANSI N14.1-1995 that was the latest ANSI N14.1 edition in effect. There was a single CoC 9196 revision in 2001 that continued to reference ANSI N14.1-1995 although there had been a new version of ANSI N14.1 issued in 2001.
In 2004, the CoC 9196 was revised with approval to 1985 requirements as Type AF-85.
The CoC condition of approval referenced ANSI N14.1-2001 and added the initial ISO 7195:1993. For the time from 2004 to 2011 when CoC 9196 Revisions 19-26 were issued, ANSI N14.1-2001 was the version in effect but ISO 7195:2005 had been issued.
CoC 9196 Revision 27 was issued in 2013 with a change to the approval type as B(U)F-96 and condition of approval changed to reference ANSI N14.1-2012 and ISO 7195:2005 that were in effect in 2013. The condition of approval continued to reference ANSI N14.1-2012 and ISO 7195:2005 for the next ten years while ANSI N14.1 was revised in 2019 and 2023, and ISO 7195 was revised in 2020.
(iii) The cause of each component or system failure or personnel error, if known;
NRC CoC condition was not changed to incorporate the latest edition of ANSI N14.1 that was in effect at the time of CoC revision due to failure of CoC holder to request the change when ANSI N14.1 was amended or issued as a new edition.
(iv) The failure mode, mechanism, and eff ect of each failed component, if known;
The 30B cylinder is a single packaging component of the UX-30 package that consists of a shell meeting ASME BPVC Section VIII, Div. I requirements for an unfired vessel with an ASME-U stamp certification, valve for filling and withdrawal of UF6, and plug for cleaning and periodic inspection.
There have been no failures of 30B cylinders fabricated after the N14.1 date referenced in the NRC CoC. The 30B cylinder function is to contain UF6 and prevent ingress of water
Pa ge4of7 NRC 71.95 Report for CAR 2024-020 E-63538 Enclosure 1
during routine, normal, and accident transp ort conditions. A 30B cylinder designed or fabricated to specification N14.1-2012 or earlier editions or later editions may be used for transportation. The performance criteria for transportation of UF6 are defined in NRC 10 CFR 71.55(g) and DOT 49 CFR 173.420. Failure of a cylinder to meet these performance criteria may result in radiological, toxicity, and chemical hazards associated with exposure to UF6. Water ingress may result in a criticality event with associated radiation exposure hazards.
(v) A list of systems or secondary function s that were also affected for failures of components with multiple functions;
There are no systems or secondary functions affected by a failure of a 30B cylinder to contain UF6 or prevent water ingress.
(vi) The method of discovery of each component or system failure or procedural error;
The date referenced for the ANSI N14.1 edition was discovered during review of the NRC CoC endorsed by DOT for issuance of a Competent Authority Certification (CAC). The DOT CAC is used for validation in other countries for international shipments of UX-30.
(vii) For each human performance-related root cause, a discussion of the cause(s) and circumstances;
The NRC actively participates with other industry standards and code committee members with full involvement in discussions and technical debates in the development of new and revised standards and codes. This includes a technical justific ation of each new or revised standard or code. The NRC's committee representatives discuss the Codes and technical justifications with other cognizant staff to ensure an adequate technical review. The NRC position on industry standards and codes is reviewed and approved by NRC management as part of proposed generic guidance including NUREG-Series Publications, Regulatory Guides, Information Notices, and Regulatory Issue Summaries.
ANSI periodically revises and updates its Standards by issuing new editions; the NRC's practice is to incorporate those new editi ons into the NRC's regulations. The NRC regulations do not incorporate by reference ANSI Standards for 10 CFR Part 71, Packaging and Transportation of Radioactive Materials as is done for other NRC regulations and DOT 49 CFR Ch. I, Part 173. NRC does recommend the use of industry standards and codes in generic guidance documents and may include a reference to a standard or code as a condition of approval in a Part 71 CoC for radioactive material package designs.
Previous versions of ANSI N14.1 are superseded by revisions but continued use of UF6 cylinders fabricated using previous versions is allowed. Although UF6 cylinders may be fabricated to an edition of ANSI N14.1 in effect at time of fabrication, periodic inspections and maintenance requirements specified in the version of ANSI N14.1 in effect at time of use are required for cylinders to remain in service. The NRC issues Part 71 package design
Pa ge5of7 NRC 71.95 Report for CAR 2024-020 E-63538 Enclosure 1
approvals for a duration of 5 years with rules for renewal or revision of the CoC. ANSI N14.1 may have been revised while NRC CoC 9196 was in effect or the version of ANSI N14.1 was not updated in the application for the next revision or renewal. Not changing the effective date for ANSI N14.1 in the NRC CoC 9196 condition of approval may have been intended to allow time for NRC review of the changes to the standard or possibly an unintentional omission during application for renewal or revision of the CoC.
(viii) The manufacturer and model number (or other identification) of each component that failed during the event; and
There have been no failures of 30B cylinders transported in the Model UX-30 package that could be attributed to the ANSI N14.1 edition referenced in the NRC CoC.
(ix) For events occurring during use of a packaging, the quantities and chemical and physical form(s) of the package contents.
A 30B cylinder may contain up to 5,020 lbs of uranium hexafluoride (UF6) in solid form.
The enrichment is limited to 5 wt.% enrichment in U-235.
(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.
The use of the standards although voluntary becomes mandatory when incorporated by reference in the regulations or approval certificate. There are no safety consequences or implications for referencing a superseded version of ANSI N14.1 in the NRC CoC 9196.
Notwithstanding the edition referenced in the NRC CoC 9196, ANSI N14.1 requires cylinder designs shall be in accordance with Section VIII, Division 1 of the ASME Boiler and Pressure Vessel Code (the Code) and the requirements of this standard. The Code requires fabrication and certification of the 30B cylinder using edition in effect at the time of fabrication.
(4) A description of any corrective actions planned 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.
TN Americas Quality Assurance Program imp lementing procedure for Corrective Action TIP 16.1, determined that the event is a condition of significance that required an NRC Part 71.95 Report and Root Cause Analysis.
Submission of an application by the CoC holder will be made to NRC to request the condition of approval be revised to reference the latest ANSI N14.1 edition.
Pa ge6of7 NRC 71.95 Report for CAR 2024-020 E-63538 Enclosure 1
TN Americas Quality Assurance Program implementing procedure for Control of Licensing Documents, TIP 5.4, will be revised to include checking the effective date of standards and codes incorporated by reference in the NRC CoC.
The Corrective Action TIP 16.1 process will detail the a Corrective and Preventative Action Plan and determine the completion schedule.
(5) Reference to any previous similar events involving the same packaging that are known to the licensee or certificate holder.
DOT 49 CFR Ch. I, Part 173 incorporates by reference industry standards and codes.
ANSI N14.1 is incorporated by reference into §173.420 Uranium hexafluoride (fissile, fissile excepted and non-fissile) and §173.417 Authorized fissile materials packages.
§171.7 Reference material includes ANSI N14.1 1971, 1982, 1987, 1990, 1995, and 2001 Editions but does not include the ANSI N14.1-2019 and 2023 Editions.
(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.
Should the NRC staff require additional information to support review of this event, please contact Peter Vescovi at 336-420-8325 or by email at peter.vescovi@orano.group.
(7) The extent of exposure of individuals to radiation or to radioactive materials without identification of individuals by name.
This event resulted in no exposure of individuals to radiation or radioactive material beyond that expected for routine use of the UX-30 package for transportation.
Pa ge7of7 NRC 71.95 Report for CAR 2024-018 E-63538 Enclosure 2
UX-30 Engineering Drawing for Package Approval, Material Specification
(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.
UX-30 license drawing C-110-B-57922-001 Rev 4, as incorporated by reference in NRC CoC 71-9196 Rev 31, requires the shear lug material to be Type 304 ASTM A240 as shown in Section D-D on Sheet 3. However, contrary to this requirement, note 12 on fabrication drawing X-20-238E Rev 12 allowed for either ASTM A240 or ASTM A479 to be used for sheet, bar, and plate components which applies to Item 8 (Shear Lug) as it is fabricated from plate material. This discre pancy in drawing material requirements dates back to the 1990s and there are UX-30 units in service that were fabricated from these drawings.
The event and causal analysis process identified the root cause of this issue to be human error with contributing casual factors of an attention to detail failure and ineffective procedural requirements for licensing to fabrication drawing reconciliation reviews. The ASTM material requirements were not adequately transferred from the approved Licensing Drawing C-110-B-57922-001 Rev 4 to the associated Fabrication Drawing X-20-238E Rev 12. Per the identified condition, the licensing drawing requiring only Type 304 ASTM A240 material for the shear lug (Item 8), which was made of plate, versus the Fabrication drawing indicating the allowance for sheet, bar, and plate components to be ASTM A240 or ASTM A479 indicates the awareness of the ASTM requirements was present. However, the specific requirement for an item to be only one type of material was not captured because of an attention to detail failure in this instance as this discrepancy was readily noted upon investigation.
Corrective action includes revising Licensing Drawing C-110-B-57922-001 to allow use of ASTM Type A240 or ASTM A479 material to assure all units currently in service would be compliant with conditions for package design approval. In addition, actions to prevent recurrence include revision of TN Quality Assurance Program Implementing Procedure for Fabrication Drawing Control, TIP 5.8, and Drawing Control, TIP 5.1, to require reconciling material specifications on fabrication and design drawings with the licensing drawings.
The Model UX-30 package is used for transportation of 30B uranium hexafluoride cylinders within the US and for international shipments by authorized users who are NRC licensees. TN Americas as the NRC CoC holder submits this report on behalf of the licensees for these instances in which the conditions of approval in the CoC may not have been observed in making a shipment.
Pa ge1of6 NRC 71.95 Report for CAR 2024-018 E-63538 Enclosure 2
(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;
A comparison was performed between the current licensing drawing (C-110-B-57922-0001 Rev 4) and the current fabrication drawing (X-20-238E Rev 12). The material of every component listed on the licensing drawing was compared with what is specified on the fabrication drawing for the equivalent component and there were seven instances of where the licensing drawing required ASTM A240 Type 304 material and one instance were the licensing drawing required ASTM A479 Type 304. The fabrication drawing however included note 12 (shown as follows), which allowed either A240 or A479 to be used in those instances.
A review of standard product offerings from various suppliers was performed to identify if the raw material used in the previously identi fied eight instances was available in either A240 or A479. This review concluded that of the one instance where A479 was specified on the licensing drawing, the material geometry is not available in A240, therefore there is no possible issue for that instance. For the seven instances where A240 was specified on the licensing drawing, the raw material for two instances was found to be available in either A240 or A479.
Item 8 (shear lug) is specified on the licensing drawing as 0.38 Plate, Stainless Steel, Type 304 ASTM A240, although the fabrication drawing specified this item as 0.38 thick plate and allowed it to be either A240 or A479 per note 12.
Item 23 (lift lug) is specified on the licensing drawing as 3/16 thick ASTM A240 Type 304, although the fabrication drawing specified this item as 3/16 thick (7 GA) plate and allowed it to be either A240 or A479 per note 12. This issue was not identified previously.
In summary, there are two components of the UX-30 that could have been fabricated from material not compliant with the licensing drawing. These components are Item 8 (shear lug) and Item 23 (lift lug), as identified on the fabrication drawing.
(ii) Dates and approximate times of occurrences;
A review of historical versions of the licensing and fabrication drawings revealed that the discrepancy on material requirements for the two components existed as far back as 1992.
The SAR drawing in effect in 1992 required the two components to be ASTM A240, whereas the fabrication drawing in effect in 1992 allowed them to be ASTM A240 or A479. It is important to note that the structural analyses in the SAR associated with these two components include properties for A240 and not A479. As such, there is reasonable
Pa ge2of6 NRC 71.95 Report for CAR 2024-018 E-63538 Enclosure 2
assurance that the licensing basis for these two components always required them to be ASTM A240 Type 304 material and the fabrication drawing always allowed them to be either ASTM A240 or A479 material.
A review of fabrication document packages for serial numbers SP-UX-0521 through SP-UX-0540 (fabricated by CHT in 2007) and serial number SP-30-649 (fabricated by CHT in 2013) showed that the material used for the shear lug (Item 8) was ASTM A479, Type 304L material. Note that while the CMTR identified the material as 304L, the chemical and mechanical testing results showed compliance to both 304 and 304L requirements.
A review of fabrication document packages for serial numbers SP-30-601 through SP 648 (fabricated by Vectra in 1995) showed that the material used for the shear lug (Item 8) was certified to ASTM A240, ASTM A276, and ASTM A479, Type 304 material.
As identified in a nonconformance report (NCR 2024-007), the material ordered by TNF between 2020 and 2021 to use in fabricating Item 8 was specified to meet ASTM A479, with no mention of ASTM A240.
Examples of units being fabricated with the optional lift lugs (Item 23) could not be located.
Considering the vast number of UX-30s fabricated over the last three decades (estimated to be over 2,000 units) and the above findings, it is likely that an indeterminate number of UX-30 packagings have been fabricated with material that was not compliant to the licensing drawing.
(iii) The cause of each component or system failure or personnel error, if known;
The event and causal analysis process identified the root cause of this issue to be human error with contributing casual factors of attention to detail and ineffective procedural requirements for licensing to fabrication drawing reconciliation reviews.
(iv) The failure mode, mechanism, and eff ect of each failed component, if known;
In both instances, the components shown on the fabrication drawing as Item 8 (Shear lug) or optional Item 23 (Lift lug), the failure mechanism is shear of the component during routine transportation or handling conditions. Item 8 (shear lug) is a tie-down feature that interfaces with a cradle that is used to secure the package to the conveyance (ISO flat rack, vehicle, or rail car). Item 23 (lift lug) is an alternate attachment point for lifting the UX-30 upper overpack during loading or unloading the 30B cylinders. Material with insufficient tensile strength may result in failure to k eep the UX-30 package secured to the conveyance or a loss of load control while lifting the UX-30 upper overpack. ASTM A240, Type 304 and ASTM A479, both have the same mechanical properties.
Pa ge3of6 NRC 71.95 Report for CAR 2024-018 E-63538 Enclosure 2
(v) A list of systems or secondary function s that were also affected for failures of components with multiple functions;
There are no systems or secondary functions affected by a failure of Item 8 (Shear lug) or optional Item 23 (Lift lug).
(vi) The method of discovery of each component or system failure or procedural error;
The allowance of ASTM 479, Type 304 material for Item 8 (Shear lug) or optional Item 23 (Lift lug) on the fabrication drawing was discovered during a fabrication review for the UX-30.
(vii) For each human performance-related root cause, a discussion of the cause(s) and circumstances;
The ASTM material requirements were not adequately transferred from the approved Licensing Drawing (C-110-B-57922-001 Rev 4) to the associated Fabrication Drawing (X-20-238E Rev 12). Per the identified condition the licensing drawing requiring only Type 304 ASTM A240 material for the shear lug (Item 8), which was made of plate, versus the Fabrication drawing indicating the allowance for sheet, bar, and plate components to be ASTM A240 or ASTM A479 indicates the awareness of the ASTM requirements was present. However, the specific requirement for it em to be only one type of material was not captured because of an attention to detail failure in this instance as this discrepancy was readily noted upon investigation.
This situation was further exacerbated by the ineffective procedural requirements for reconciliation review as TIP 5.8 Rev 2 section 4.1 indicates Licensing review is not required for Fabrication Drawing, and TIP 5.1 Rev 14 section 5.13 indicates the PE is to perform Licensing Reviews for drawing approval when applicable. These requirements resulted in an error prone situation where pers onnel could arrive at a determination that a licensing review is not required. To address this issue the requirement for review of licensed component drawings will be incorpor ated into TIP 5.8 with an incorporated checklist to assure all material, code, etc. requirements are reviewed and reconciled. This will ensure fabrication drawings for license d components are reviewed and reconciled to licensed drawing requirements.
(viii) The manufacturer and model number (or other identification) of each component that failed during the event; and
TN Americas Model UX-30 manufactured by TN Fabrication (f.k.a. Columbiana HiTech).
SAR Drawing C-110-B-57922-001 Rev 4, Item 8, Shear lug. There have been no failures of Model UX-30 to provide impact or thermal protection for 30B cylinders that could be attributed to use of an ASTM material specification that was not included in the licensing drawing.
Pa ge4of6 NRC 71.95 Report for CAR 2024-018 E-63538 Enclosure 2
(ix) For events occurring during use of a packaging, the quantities and chemical and physical form(s) of the package contents.
A 30B cylinder may contain up to 5,020 lb of uranium hexafluoride (UF6) in solid form.
The enrichment is limited to 5 wt.% enrichment in U-235.
(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.
Failure to keep the UX-30 package secured to the conveyance or a loss of load control while lifting the UX-30 upper overpack could result in serious injury or fatality due to loss of load control during routine transportation or handling. There is no known fabrication of UX-30 with the optional Item 23 (Lift lug) attachment point on the sides of the upper overpack for rigging equipment. Lift lugs on the top of the upper overpack are used to attach rigging equipment. There are no instances of loss of load during transportation due to failure of Item 8 (Shear lug) to secure the UX-30 package.
(4) A description of any corrective actions planned 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.
TN Americas Quality Assurance Program Implementing Procedure for Corrective Action TIP 16.1, determined that the event is a condition of significance that required an NRC Part 71.95 Report and Root Cause Analysis.
Submission of an application by the CoC holder will be made to NRC to request reference to a revised engineering drawing for package approval.
The Corrective Action TIP 16.1 process will detail the Corrective and Preventive Action Plan and determine the completion schedule.
(5) Reference to any previous similar events involving the same packaging that are known to the licensee or certificate holder.
There are no previous instances of material specifications used for fabrication of UX-30 that were not specified by the package CoC. Another instance was discovered during the evaluation of extent of condition,
(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.
Should the NRC staff require additional information to support review of this event, please contact Peter Vescovi at 336-420-8325 or by email at peter.vescovi@orano.group.
Pa ge5of6 NRC 71.95 Report for CAR 2024-018 E-63538 Enclosure 2
(7) The extent of exposure of individuals to radiation or to radioactive materials without identification of individuals by name.
This event resulted in no exposure of individuals to radiation or radioactive material beyond that expected for routine use of the UX-30 package for transportation.
Pa ge6of6