ML030570208
| ML030570208 | |
| Person / Time | |
|---|---|
| Site: | 07109150 |
| Issue date: | 07/13/1981 |
| From: | Lake W Office of Nuclear Material Safety and Safeguards |
| To: | Macdonald C Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML030570208 (6) | |
Text
FCTC:WHL 71-9150 u
JUL 13 1981 MEMORANDtf.1 FOR:. Charles E. MacDonald, Chief Transportatfon Certiffcatfon Branch FROM:
Wf llfam ff. !Ake
-~ Transportation Certification Branch
SUBJECT:
DOE REQUEST FOR APPROVAL OF ALTERNATE u
.. OPERATIONAL CONTROL FOR PU-AIR TRANSPORT In order to evaluate DOE's request for approval of the Model PAT-2, t have consfdered:the DOE application of April 3, 1981. the Sandia Report, SAND 81-0001, as amended May 27, 1981. and f11e data for the PAT-1.
I have concluded that the DOE has not demonstrated that a sfgnfftcant.
problem arises *1n requtr*tng aft-UK>st. mafn deck stowage for PAT packages.
nor have they shown how the altematfve proposal satisfies the intent of the stowage requirement.
I have conducted telephone fnqufrfes to verify DOE's statements regarding shipper problems associated with the aft-most mfn deck stowage requirement (see enclosure)~* I have found the DOE statements to be unsupported and find that it fs questionable to assume that changing the stowage requirement
- as proposed by OOE would sfgniffcantly change Pu--afr transport problems.
In revfewfng PAT-1 hf story* *1.ffnd that the aft-roost main deck stowage requirement was., subjective requirement recommended by an ad hoc contn1ttee of aircraft experts set up by RAS; they apparently felt that the proposed location presented no sfgnfffcant operational difficulty and represented the safest location for thfs relatively small package. Sfnce they suggested no evident quantifiable cnterfa. I can see only two possible reasons for change:
- 1.
Signfffcant operational dffficu1t1es are 1dentff1ed and NAS 1s reconsulted or the Conmfssfon decides independently that the RAS reccmmendatfon 1s fnvalfdated by the existence of sfgnfffcant operational difficulty; or
- 2.
It ts shcnm that e.n alternate location or control will result fn f!D?roved or equivalent ~ckage protection.
OFFICE * * * * *. * * * *, * *. * * *. * * * *. *.................. *........ *.... * *.. *.. *..... *,. *.... *..... *...........,. *........... *...........,......
SURNAME...............................................................................................................................
DATE NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY
u Charles£. MacDonald 2
JUL 13 1981 Since neither of the reasons above appear to be met. I rec01llllend that we qfve no further *consideration to. DOE's request as presented in thefr April 3 and Nay 27, 1981 submfttals.
Enclosure:
As stated Distribution w/encl:
\\tJljJ,ake
.JiM5'cket Fi 1 es NMSS R/F FCTC R/F HWLee JEJackson CRChappell Original Signed bl.*
1-1111 f am ff. Lake Transportation Certfficatfon Branch D1vfs1on of Fuel Cycle and Material Safety, NMSS
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SURNAME.. l!.J},~~f~:.Y~.................................. *...............................................................................................
. ** DATE:.-~.~.~t~?.{~~***..... ;*............... *****"********.......... :................................................,................... *.:~***.. *
. NRC l"ORM 318 ( 10*80) NRCM 0240 OFFICIAL RECORD COPY
V INVESTIGATION OF THE STOWAGE LOCATION OPERATIONAL CONTROL FOR PU-AIR TRANSPORT Sul'llllary and Conclusion The Department of Energy {DOE) requested NRC approval for shipment of safeguard samples of plutonium by air. They also requested an alternate to the operational control that requires aft-most main deck stowage of plutonium air transport packages. The DOE c1aims'1' that the present operational control has made the use of the PAT-1 package impractical
- and will have a similar effect on the PAT-2 package.
I have investigated this claim concluding *that the aft-most main deck stowage requirement was in conflict with a Department of Transportation (DOT) requirement for crew accessibility for hazardous materials. The DOT requirement has been *revised and the stowage requirement no longer significantly effects the practicality of using plutonium air transport packages.
Background
In order to satisfy PL 94-79 enacted August 9, 1975, the NRC began a program to: (1) develop criteria and (2) design and develop a container capable of withstanding crash and blast-testing equivalent to the crash and explosion of a high flying aircraft. The NRC sought the advice of the Conmission's Advisory Conrnittee on Reactor Safeguards (ACRS) and the National Academy of Sciences (NAS). A specific recomnendation of the NAS was to require such a package be stowed in the aft-most position on the main deck.'2' The staff incorporated this operational control requirement into its criterfaf3), and the PAT-1 Certificate of Compliance'4'. Although NAS had considered and found acceptable the evaluation for under-belly stowagers,, they strongly recorrmended the operational control.
The expert opinion of -NAS was that an extra margin of safety would be afforded by main deck stowage, and if stowed on the main deck, the package(s) should be stowed in the aft-most position to avoid possible crushing from heavier packages if a crash should occur.
The NAS and the NRC'staff assumed that such a requirement would not be difficult to comply with.
rllSANDIA Draft Report, SAND 81-0001, paragraph 2.8.12, pp 2-57 to 2-60.
' 2' NAS Report, NUREG/CR-0428, 1978, pg 14.
' 3'Qualification Criteria, NUREG-0360, Jan. 1978, pp 9, 10.
' 4'NRC Certificate of Compliance No. 0361, Sept. 5, 1978.
(SlNUREG-0360, Jan. 1978, pp 29, 30, 31.
V Neither the NRC staff nor NAS was aware of an existing DOT requirement that hazardous materials be accessible to the aircraft crew.
The only apparent way of satisfying both the DOT and NRC requirements would be to stow a package on the main cargo deck.in the rear of the aircraft with-no cargo between the package and crew, making it crew accessible. The DOT revised its requirement tn 1980 to eliminate radioactive materials from the hazardous materials that have to be accessible to the crew. rs, Discussion The DOE claims that the aft-most main deck stowage requirement makes use of the PAT packages impractical; they identify the problem of loading/
unloading at intennediate stop*s, claiming a direct connection with the reported Flying Tigers, Inc. offer to carry a PAT-1 from JFK Airport in NYC to Europe in a sole use aircraft."'
I investigated DOE's claim by conducting telephone inquiries of people involved in air cargo operations, an individual involved in arranging plutonium sample shipmentsfB'l, and J. A. Andersen, Sandia Laboratories.
The important points of my investigation are listed below:
- 1.
The reported offer by Flying Tigers, Inc. to ship a single package in one plane occurred someti~e in 1979; ft was probably due to the conflicting DOT/NRC requirements that existed prior to March 1980, and had nothing to do with loading/unloading at intermediate stops.
2.. The shipper would not incur additional costs due to aft-most main deck stowage vs. under-belly stowage.
- 3.
A number of cargo only flights are available which originate
-from major U.S. airports and tenninate at major European airports. Specific European locations can be reached by connecting airlines, ground transport or both within Europe.
Someone who had to get a PAT package from the U.S. to Europe could develop appropriate routing; prior planning would minimize if not eliminate delays, and result in essentially the same transit time for under-belly stowage.
- 4.
Other problems significantly effecting PAT shipments would not be reduced by allowing under-belly stowage including:
(1) airline captains can and often do, refuse any cargo, and (2) local laws and agencies (i.e., NY Port Authority} may impose restrictions.
161DOT HM-152, FR 20097, Puhl. March 27, 1980.
f ~SANDIA Draft Report, SAND 81-0001, par *. 2.8.12,. pp 2-57 to 2-60.
Those.people contacted between June 29 1981 and July 6 1981 are listed in Appendix A.
- 5.
The DOE Safety Evaluation Report (SAR)'9', prepared by SANDIA, points to difficulties in using PAT-1 but no details are reported.
I have contacted a SANDIA representative to find that no inquiries were made of airlines to detennine the actual cause or to verify the extent of the problemflO);
however, they did an extensive study of shipper problems through a shipper surveyf11'. This investigation identified the problems, looked for causes of problems, and extent of problems.
r9tsANDIA Draft Report, SAND 81-0001.
fl0)J. A. Anderson, telecon, July 2, 1981.
r11,SANDIA memo, J. A. Anderson to 'Distribution, Subj:
Problems With Plutonium Air Shipments, May 21, 1979.
V Appendix A List of Contacts for Study Encl to memo dtd JUL 1 S 1981 Namenttle Aff111atfon Phone No.
Mary K. Lambert Flying Tigers, Inc.
Person/Airfreight lWA, Dulles Brady Williamson/Mgr.
cargo Svc. Programs lWA, NYC Wayne Ferrar Pan-Am, Dulles Cargo Mgr!
Kenneth Snow/Mgr:
Flying Tigers. Inc.
Hazardous Ma t1 's David Kuettler/Mgr Northwest Orient Al Cargo Tariffs John Andersen Sandia Laboratory Dave Lund/fonnerly NBL. IL Mgr. Sale Pgm.
(now DOE, ALOO)