ML110050335
| ML110050335 | |
| Person / Time | |
|---|---|
| Site: | 07100170, 07105939 |
| Issue date: | 12/22/2010 |
| From: | Don Krause GE-Hitachi Nuclear Energy Americas |
| To: | Michele Sampson NRC/NMSS/SFST/LID/LB, Document Control Desk |
| References | |
| LTR: DRK-2010-30 | |
| Download: ML110050335 (19) | |
Text
0 HITACHI GE Hitachi Nuclear Energy Donald R. Krause Manager, Regulatory Compliance and EHS Vallecitos Nuclear Center 6705 Vallecitos Rd Sunol, CA 94586 USA 22 December 2010 T 925 862 4360 F 925 304-7435 Donald.Krause@ge.com Ms. Michele M. Sampson, Sr. Project Manager Licensing Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-001 ATTN: Document Control Desk Copy to:
Associate Administrator for Hazardous Material Safety Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation 1200 New Jersey Avenue, S.E.
Washington, D.C. 20590-0001 Attn: Special Permits, PHH-31 LTR: DRK-2010-30
Subject:
APPLICATION FOR LIMITED CONTINUED USE OF THE MODEL NO. 1500 TYPE B PACKAGE, CERTIFICATE OF COMPLIANCE No. 5939
- 1)
NRC Letter to D.R. Krause, GEH, "Authorization for Limited Shipments in the Model No. 1500 Package, Certificate of Compliance No. 5939", Dated January 16, 2009.
References:
Dear Ms. Sampson:
GE - Hitachi Nuclear Energy Americas, LLC ("GEH"), with operations at the Vallecitos Nuclear Center (VNCI, Sunol, California respectfully request an extension to the Authorization for limited continued use of the GEH Model No. 1500 Type B Package, Certificate of Compliance No. 5939, from December 31, 2010 to December 30, 2011 and for the authorization to make use of the Model 1500 to accomplish a maximum of seven (7) Cobalt-60 shipment in calendar year 2011, as detailed herein. i 11 Please note that GEH does not request any changes to the Model 1500 design nor currently authorized contents, and that GEH will continue to maintain the Model 1500, Serial Number 1507, in accordance with the maintenance and operating procedures on file with the NRC through the requested time period. Further, GEH understands that this request will not be considered a form of certificate renewal, either under 10 CFR 71.38 or any other NRC regulation.
GE Hitachi Nuclear Energy DRK 2010-30 Renewal GEH Model 1500 R1.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 2 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 GEH shall continue to operate the Model 1500 Type B Package in accordance with the Quality Assurance Program Approval for Radioactive Material Packages, No. 0170, approved by the NRC under Docket No. 71-0170.
If there are any questions on this request, or additional information is required, please contact me or our Technical
Contact:
Mr. Carlos Martinez at (925) 862-4481.
Sincerely, Donald R. Krause cn=Donald R. Krause, o=GE Hitachi Nuclear Energy, ou=Vallecitos Nuclear Center, email=donald.krause@ge.com, c=US 2010.12.22 15:38:30 -08'00' Donald R. Krause Mgr., Regulatory Compliance & EHS
Attachment:
Model 5939 Supplemental Information Docket No. 71-5939 TAC No. L24282 cc:
Gaby Francis (GEH)
Andrew Langston (GNF-A)
Carlos Martinez (GEH)
Louis Quintana (GEH)
Michael Schrag (GEH)
David Turner (GEH)
GE Hitachi Nuclear Energy DERK 2010-30 Renewal GEH Model 1500 Ri.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 3 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 NRC RIS 2008-18, Information on Requests for Extending Use of Expiring Transportation Packages GEH Model No. 1500 Type B Package, Certificate of Compliance No. 5939 Docket No. 71-5939; TAC No. L24282 GEH currently operates one (1) Model No. 1500 Package, Serial Number 1507. The primary use of this Package is for the transport of Cobalt-60 sealed sources, in Special form, for medical and commercial applications. The Package is operated and maintained under GEH's Quality Assurance'Program, Approval No. 0170, approved by the NRC under Docket No. 71-0170.
(1)
Package Information.
NRC Certificate of Compliance Number. 5939 (2)
Identification of Shipments.
(a) Number of shipments; (bV number of packages per shipment; (c) packaging serial numbers; (d) package contents; (e) end use of the radioactive material; (fl shipment origin and destination; (g) mode; (h) general timeframe; and (i) date last shipment will be completed.
(a) Seven (7) Cobalt-60 shipments, using the Model 1500 Package, in calendar year 2011.
(b) Each shipment shall be accomplished using one (1) Model 1500 Package.
(c) Each shipment shall make use of Model 1500 Package, Serial Number 1507.
(d) Each shipment shall be comprised of Cobalt-60 (Co-60) as sealed sources that meet the requirements of Special form radioactive material. The number of Co-60 sources, and corresponding activity, will depend on the Customer's order; however, the maximum quantity of material shall comply with the approved content limits specified in Certificate of Compliance No. 5939.
(e) The end-use of the Co-60 sealed sources is predominantly for industrial, sterilization applications, with some limited research applications.
(f) Four (4) Co-60 shipments would originate at the GE-Hitachi's Vallecitos Nuclear Center (VNC), Sunol, California (location of the Co-60 special form encapsulation facility) and terminate at J. L. Shepherd & Associates ("JLS&A"), San Fernando, California (where the individual sources are installed in commercial process irradiators). In addition, JLSA has expressed interest to lease the GEH Model 1500 Package a maximum of three 13) in calendar year 2011 to delivery/pickup Cobalt-60 sources from as of yet undetermined U.S. locales.
(g) All Co-60 shipments shall be accomplished by truck, as "Exclusive-Use", and are subject to security measures applicable to Radioactive Materials Quantities of Concern (RAMQC) or Highway Route Control Quantity (HRQC) shipments IhN GEH anticipates to makes one Co-60 shipment to JLS&A every quarter in calendar year 2011, and for JLS&A to lease the Model 1500 Package in the 2nd, 3rd and 4th quarter of 2011, for a total of seven (7) Co-60 shipments in 2011.
Wi The last proposed Co-60 shipment, using the Model 1500 Package, would be completed on or before December 30, 2011.
(3)
Reasons for Requesting Extended Use.
GE Hitachi Nuclear Energy DRK 2010-30 Renewal GEH Model 1500 Rl.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 4 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 Justification for Requesting Extended Use. Justification for extending the use of expiring packages must describe why acquiring replacement packages is not practical and why shipments cannot be made before the October 1, 2008, expiration date. The justification must demonstrate that: (a) there are no alternative domestically approved packages available; (b) the contents cannot be reconfigured such that transport can be conducted in accordance with the regulations; and (c) the transport schedule cannot be adjusted so as to be conducted in accordance with the regulations. The justification must also describe any good-faith efforts to acquire replacement packages that meet the current package performance requirements, including a detailed description of past activities and the current status of acquiring replacement packages. In addition, any adverse impacts that will result if the shipment is not conducted should be fully described.
Without an extension for the Model 1500 through CY-2011, JLSA may not be able to deliver on existing customer commitments, including key government contracts. A change to a different Type B package would impact program schedule, costs, and deliverables, and would necessitate procedural modifications, personnel re-training, re-tooling and possibly some form of facility modifications at the receiver's end.
Section (5) delineates GEH's and JLS plans to acquire a replacement package for the Model 1500.
(4)
Safety Justification for Continued Use and Proposed Compensatory Measures Safety Justification for Continued Use and Proposed Compensatory Measures. Since the expiring package designs may lack safety enhancements included in newer designs, the request must include a safety justification for continued use and a description of compensatory measures that will be used to provide an equivalent level of safety. Examples of compensatory measures that may be considered are: (a) special package inspections, tests, or determinations that ensure that the packaging is in unimpaired physical condition; (b) transport by exclusive use; (c) transport during time of low road usage; and (d) accompaniment of shipment by escort equipped to effect a recovery in an emergency situation or in case of a transportation accident.
GEH has approximately 30-years experience safely operating and maintaining the Model 1500 Package. GEH shall operate the 5939 Type B Package, Serial No. 1507, in accordance with the Quality Assurance Program Approval for Radioactive Material Packages, No. 0170, approved by the NRC under Docket No. 71-0170.
GEH safely accomplished four (4) Co-60 shipments, using the Model 1500 Package, Serial No.
1507, from March 27, 2009 through November 22, 2010 without incident of any kind, and that J.L. Shepherd & Associates (JLS&A) safely accomplished two (2) Co-60 shipments using the 1507 Package in CY-2010, without incident of any kind either.
The Transport Index (TI), the external packaging surface dose readings and Curie content for the proposed Co-60 shipments will be below the exclusive use criteria for radioactive materials shipments, i.e., 200 mRem/hr not to exceed 1000 mRem/hr at the surface of the Package (per 49CFR173.441). Historically, past Co-60 shipments using the Model 1500 Package have not exceeded a TI value of 5.
GE Hitachi Nuclear Energy DRK 2010-30 Renewal GEH Model 1500 Rl.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 5 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 GEH is committed to transporting the Model 500 Package as "Exclusive-Use", as defined in 49CFR173.403 mode of motor transport. The shipments shall include the use of either closed transport or flat-bed style transport vehicles. The Package shall be secured during transport so that its position remains fixed during transport. Unless there is an emergency situation, no loading or unloading operations shall be performed during transit, i.e., between the start and end of the transport, and all work shall be performed under the direction of the Shipper or Receiver. Radiologically trained personnel shall perform all loading and unloading operations. Resources for the safe handling of the Package will be provided, including written instructions to the carrier to avoid unnecessary delays or unnecessarily radiation levels or radiation exposures to transport workers or members of the general public. In addition, written instructions pertaining to security measures and emergency response shall be reviewed with the carrier for RAMQC and HRCQ shipments, should the carrier not have something comparable provided by their employer. The applicable security and emergency response measures will not be delineated in this application.
The shipment of empty Packages will be exempt from exclusive-use transport requirements.
The Model 1500 Packages contain no exterior surface residual radioactivity above "background levels". Further, since this Package is used primarily to transport sealed sources which meet Special form criteria, and the Packages' internal cavity is essentially free of loose-surface radioactive contamination.
Best efforts shall be made to initiate and deliver a radioactive material shipment during off-rush hour traffic, and to use all loops within major cities. Transport restrictions associated with exclusive-use vehicles carrying RAMQC or HRCQ cargo will not be delineated in this application.
While a hazardous materials recovery escort is not practical to implement, there is a prior shipment notification process for all RAMQC and HRCQ shipments (that will not be addressed in this application). Affected State agencies would have the discretion and option as part of the prior shipment notification process to provide escorts for said shipment, if deemed necessary.
Please note that GEH does not request any changes to the 5939 Package authorized contents listing, and that GEH will observe all operating and maintenance procedures on file with the NRC through the extended period. Further, GEH understands that this request will not be considered a form of certificate renewal, either under 10 CFR 71.38 or any other NRC regulation.
(5)
A Plan and Schedule to Acquire Replacement Packages Details about the planned acquisition of replacement packages must be provided, along with key milestones, and proposed implementation dates, unless the licensee can show why acquiring a replacement package is not practical and why shipments cannot be made before the October 1, 2008, expiration date.
In February 2005, AOS entered into a contract with GEH to develop a Type B Transport Packaging System, in accordance with the provisions of 10 CFR Part 71, to replace the Model 1500. The application was submitted by AOS to the NRC in October 2007, and supplemented November 2007, under Docket No. 71-93 16. In a conference call between AOS and the NRC GE Hitachi Nuclear Energy DRK 2010-30 Renewal GEH Model 1500 Ri.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 6 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 on April 7, 2008, the NRC staff informed AOS of major technical deficiencies found in the application. On April 29, 2008, AOS informed the NRC staff, by letter, of its withdrawal of the AOS Transport Packaging System application, and intent to re-submit the application upon revising it to address the open technical issues identified by the NRC staff.
Revision B of the SAR was submitted by AOS to the NRC in September 2009. AOS received a Request for Supplemental Information (RSII in July 2009. Revision C of the SAR and responses to the July 2009 RSI's was submitted to the NRC on September 2009. AOS then received Request for Additional Information IRAI) in December 2009. Due to the number and extent of the RAI's, the RAI responses and Revision D of the SAR was submitted on September 30, 2010.
NRC design and licensing approval is expected in 2011 and the first package ready-for-use is anticipated 6-9 months thereafter.
JLS&A too is working on the design and licensing of a Type B Package to replace the GEH Model 1500 Package. Details of the JLS&A Package design and progress on the licensing of said Package are unknown to GEH.
GE Hitachi Nuclear Energy DRK 2010-30 Renewal GEH Model 1500 R1.doc
0 HITACHI GE Hitachi Nuclear Energy Donald R. Krause Manager, Regulatory Compliance and EHS Vallecitos Nuclear Center 6705 Vallecitos Rd Sunol, CA 94586 USA 22 December 2010 T 925 862 4360 F 925 304-7435 Donald.Krouse@ge.com Ms. Michele M. Sampson, Sr. Project Manager Licensing Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-001 ATTN: Document Control Desk copy to:
Associate Administrator for Hazardous Material Safety Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation 1200 New Jersey Avenue, S.E.
Washington, D.C. 20590-0001 Attn: Special Permits, PHH-31 LTR: DRK-2010-30
Subject:
APPLICATION FOR LIMITED CONTINUED USE OF THE MODEL NO. 1500 TYPE B PACKAGE, CERTIFICATE OF COMPLIANCE No. 5939
- 1)
NRC Letter to D.R. Krause, GEH, "Authorization for Limited Shipments in the Model No. 1500 Package, Certificate of Compliance No. 5939", Dated January 16, 2009.
References:
Dear Ms. Sampson:
GE - Hitachi Nuclear Energy Americas, LLC ("GEH"), with operations at the Vallecitos Nuclear Center (VNC), Sunol, California respectfully request an extension to the Authorization for limited continued use of the GEH Model No. 1500 Type B Package, Certificate of Compliance No. 5939, from December 31, 2010 to December 30, 2011 and for the authorization to make use of the Model 1500 to accomplish a maximum of seven (7) Cobalt-60 shipment in calendar year 2011, as detailed herein. I']
Please note that GEH does not request any changes to the Model 1500 design nor currently authorized contents, and that GEH will continue to maintain the Model 1500, Serial Number 1507, in accordance with the maintenance and operating procedures on file with the NRC through the requested time period. Further, GEH understands that this request will not be considered a form of certificate renewal, either under 10 CFR 71.38 or any other NRC regulation.
GE Hitachi Nuclear Energy DRK 2010-30 Renewal GEH Model 1500 Rl.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 2 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 GEH shall continue to operate the Model 1500 Type B Package in accordance with the Quality Assurance Program Approval for Radioactive Material Packages, No. 0170, approved by the NRC under Docket No. 71-0170.
If there are any questions on this request, or additional information is required, please contact me or our Technical
Contact:
Mr. Carlos Martinez at (925) 862-4481.
Sincerely, Donald R. Krause cn=Donald R. Krause, o=GE Hitachi Nuclear Energy, ou=Vallecitos Nuclear Center, email=donald.krause@ge.com, c=US 2010.12.22 15:38:30 -08'00' Donald R. Krause Mgr., Regulatory Compliance & EHS
Attachment:
Model 5939 Supplemental Information Docket No. 71-5939 TAC No. L24282 cc:
Gaby Francis (GEH)
Andrew Langston (GNF-A)
Carlos Martinez (GEH)
Louis Quintana (GEH)
Michael Schrag (GEH)
David Turner (GEH)
GE Hitachi Nuclear Energy DRK 2010-30 Renewal GEH Model 1500 Ri.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 3 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 NRC RIS 2008-18, Information on Requests for Extending Use of Expiring Transportation Packages GEH Model No. 1500 Type B Package, Certificate of Compliance No. 5939 Docket No. 71-5939; TAC No. L24282 GEH currently operates one (1) Model No. 1500 Package, Serial Number 1507. The primary use of this Package is for the transport of Cobalt-60 sealed sources, in Special form, for medical and commercial applications. The Package is operated and maintained under GEH's Quality Assurance Program, Approval No. 0170, approved by the NRC under Docket No. 71-0170.
(1)
Package Information.
NRC Certificate of Compliance Number. 5939 (2)
Identification of Shipments.
(a) Number of shipments; (b) number of packages per shipment; (c) packaging serial numbers; (d) package contents; (e) end use of the radioactive material; (f0 shipment origin and destination; (g) mode; (h) general timeframe; and ili date last shipment will be completed.
(a) Seven (7) Cobalt-60 shipments, using the Model 1500 Package, in calendar year 2011.
Ib) Each shipment shall be accomplished using one (1) Model 1500 Package.
(c) Each shipment shall make use of Model 1500 Package, Serial Number 1507.
(d) Each shipment shall be comprised of Cobalt-60 (Co-60) as sealed sources that meet the requirements of Special form radioactive material. The number of Co-60 sources, and corresponding activity, will depend on the Customer's order; however, the maximum quantity of material shall comply with the approved content limits specified in Certificate of Compliance No. 5939.
(e) The end-use of the Co-60 sealed sources is predominantly for industrial, sterilization applications, with some limited research applications.
(f) Four (4) Co-60 shipments would originate at the GE-Hitachi's Vallecitos Nuclear Center (VNC), Sunol, California (location of the Co-60 special form encapsulation facility) and terminate at J. L. Shepherd & Associates ("JLS&A"), San Fernando, California (where the individual sources are installed in commercial process irradiators). In addition, JLSA has expressed interest to lease the GEH Model 1500 Package a maximum of three (3) in calendar year 2011 to delivery/pickup Cobalt-60 sources from as of yet undetermined U.S. locales.
(g) All Co-60 shipments shall be accomplished by truck, as "Exclusive-Use", and are subject to security measures applicable to Radioactive Materials Quantities of Concern (RAMQC) or Highway Route Control Quantity (HRQC) shipments (h) GEH anticipates to makes one Co-60 shipment to JLS&A every quarter in calendar year 2011, and for JLS&A to lease the Model 1500 Package in the 2nd, 3rd and 4 th quarter of 2011, for a total of seven (7) Co-60 shipments in 2011.
Wi) The last proposed Co-60 shipment, using the Model 1500 Package, would be completed on or before December 30, 2011.
(3)
Reasons for Requesting Extended Use.
GE Hitachi Nuclear Energy DRK 2010-30 Renewal GEH Model 1500 Rl.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 4 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 Justification for Requesting Extended Use. Justification for extending the use of expiring packages must describe why acquiring replacement packages is not practical and why shipments cannot be made before the October 1, 2008, expiration date. The justification must demonstrate that: (a) there are no alternative domestically approved packages available; (b) the contents cannot be reconfigured such that transport con be conducted in accordance with the regulations; and (c) the transport schedule cannot be adjusted so as to be conducted in accordance with the regulations. The justification must also describe any good-faith efforts to acquire replacement packages that meet the current package performance requirements, including a detailed description of past activities and the current status of acquiring replacement packages. In addition, any adverse impacts that will result if the shipment is not conducted should be fully described.
Without an extension for the Model 1500 through CY-2011, JLSA may not be able to deliver on existing customer commitments, including key government contracts. A change to a different Type B package would impact program schedule, costs, and deliverables, and would necessitate procedural modifications, personnel re-training, re-tooling and possibly some form of facility modifications at the receiver's end.
Section (5) delineates GEH's and JLS plans to acquire a replacement package for the Model 1500.
(4)
Safety Justification for Continued Use and Proposed Compensatory Measures Safety Justification for Continued Use and Proposed Compensatory Measures. Since the expiring package designs may lack safety enhancements included in newer designs, the request must include a safety justification for continued use and a description of compensatory measures that will be used to provide an equivalent level of safety. Examples of compensatory measures that may be considered are: (a) special package inspections, tests, or determinations that ensure that the packaging is in unimpaired physical condition; (b) transport by exclusive use; (c) transport during time of low road usage; and (d) accompaniment of shipment by escort equipped to effect a recovery in an emergency situation or in case of a transportation accident.
GEH has approximately 30-years experience safely operating and maintaining the Model 1500 Package. GEH shall operate the 5939 Type B Package, Serial No. 1507, in accordance with the Quality Assurance Program Approval for Radioactive Material Packages, No. 0170, approved by the NRC under Docket No. 71-0170.
GEH safely accomplished four (4) Co-60 shipments, using the Model 1500 Package, Serial No.
1507, from March 27, 2009 through November 22, 2010 without incident of any kind, and that J.L. Shepherd & Associates (JLS&A) safely accomplished two (2) Co-60 shipments using the 1507 Package in CY-2010, without incident of any kind either.
The Transport Index (TI), the external packaging surface dose readings and Curie content for the proposed Co-60 shipments will be below the exclusive use criteria for radioactive materials shipments, i.e., 200 mRem/hr not to exceed 1000 mRem/hr at the surface of the Package (per 49CFR173.441). Historically, past Co-60 shipments using the Model 1500 Package hove not exceeded a TI value of 5.
GE Hitachi Nuclear Energy DRK 2010-30 Renewal GEH Model 1500 Rl.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 5'of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 GEH is committed to transporting the Model 500 Package as "Exclusive-Use", as defined in 49CFR173.403 mode of motor transport. The shipments shall include the use of either closed transport or flat-bed style transport vehicles. The Package shall be secured during transport so that its position remains fixed during transport. Unless there is an emergency situation, no loading or unloading operations shall be performed during transit, i.e., between the start and end of the transport, and all work shall be performed under the direction of the Shipper or Receiver. Radiologically trained personnel shall perform all loading and unloading operations. Resources for the safe handling of the Package will be provided, including written instructions to the carrier to avoid unnecessary delays or unnecessarily radiation levels or radiation exposures to transport workers or members of the general public. In addition, written instructions pertaining to security measures and emergency response shall be reviewed with the carrier for RAMQC and HRCQ shipments, should the carrier not have something comparable provided by their employer. The applicable security and emergency response measures will not be delineated in this application.
The shipment of empty Packages will be exempt from exclusive-use transport requirements.
The Model 1500 Packages contain no exterior surface residual radioactivity above "background levels". Further, since this Package is used primarily to transport sealed sources which meet Special form criteria, and the Packages' internal cavity is essentially free of loose-surface radioactive contamination.
Best efforts shall be made to initiate and deliver a radioactive material shipment during off-rush hour traffic, and to use all loops within major cities. Transport restrictions associated with exclusive-use vehicles carrying RAMQC or HRCQ cargo will not be delineated in this application.
While a hazardous materials recovery escort is not practical to implement, there is a prior shipment notification process for all RAMQC and HRCQ shipments (that will not be addressed in this application). Affected State agencies would have the discretion and option as part of the prior shipment notification process to provide escorts for said shipment, if deemed necessary.
Please note that GEH does not request any changes to the 5939 Package authorized contents listing, and that GEH will observe all operating and maintenance procedures on file with the NRC through the extended period. Further, GEH understands that this request will not be considered a form of certificate renewal, either under 10 CFR 71.38 or any other NRC regulation.
(5)
A Plan and Schedule to Acquire Replacement Packages Details about the planned acquisition of replacement packages must be provided, along with key milestones, and proposed implementation dotes, unless the licensee can show why acquiring a replacement package is not practical and why shipments cannot be made before the October 1, 2008, expiration date.
In February 2005, AOS entered into a contract with GEH to develop a Type B Transport Packaging System, in accordance with the provisions of 10 CFR Part 71, to replace the Model 1500. The application was submitted by AOS to the NRC in October 2007, and supplemented November 2007, under Docket No. 71-9316. In a conference call between AOS and the NRC GE Hitachi Nuclear Energy DGRK 2010-30 Renewal GEH Model 1500 Rl.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 6 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 on April 7, 2008, the NRC staff informed AOS of major technical deficiencies found in the application. On April 29, 2008, AOS informed the NRC staff, by letter, of its withdrawal of the AOS Transport Packaging System application, and intent to re-submit the application upon revising it to address the open technical issues identified by the NRC staff.
Revision B of the SAR was submitted by AOS to the NRC in September 2009. AOS received a Request for Supplemental Information (RSI) in July 2009. Revision C of the SAR and responses to the July 2009 RSI's was submitted to the NRC on September 2009. AOS then received Request for Additional Information (RAI) in December 2009. Due to the number and extent of the RAI's, the RAI responses and Revision D of the SAR was submitted on September 30, 2010.
NRC design and licensing approval is expected in 2011 and the first package ready-for-use is anticipated 6-9 months thereafter.
JLS&A too is working on the design and licensing of a Type B Package to replace the GEH Model 1500 Package. Details of the JLS&A Package design and progress on the licensing of said Package are unknown to GEH.
GE Hitachi Nuclear Energy DRK 2010-30 Renewal GEH Model 1500 Rl.doc
0 HITACHI GE Hitachi Nuclear Energy Donald R. Krause Manager, Regulatory Compliance and EHS Vallecitos Nuclear Center 6705 Vallecitos Rd Sunol, CA 94586 USA 22 December 2010 T 925 862 4360 F 925 304-7435 Donald.Krause@ge.com Ms. Michele M. Sampson, Sr. Project Manager Licensing Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-001 ATTN: Document Control Desk Copy to:
Associate Administrator for Hazardous Material Safety Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation 1200 New Jersey Avenue, S.E.
Washington, D.C. 20590-0001 Attn: Special Permits, PHH-31 LTR: DRK-2010-30
Subject:
APPLICATION FOR LIMITED CONTINUED USE OF THE MODEL NO. 1500 TYPE B PACKAGE, CERTIFICATE OF COMPLIANCE No. 5939
- 1) NRC Letter to D.R. Krause, GEH, "Authorization for Limited Shipments in the Model No. 1500 Package, Certificate of Compliance No. 5939", Dated January 16, 2009.
References:
Dear Ms. Sampson:
GE - Hitachi Nuclear Energy Americas, LLC ("GEH"), with operations at the Vallecitos Nuclear Center (VNC), Sunol, California respectfully request an extension to the Authorization for limited continued use of the GEH Model No. 1500 Type B Package, Certificate of Compliance No. 5939, from December 31, 2010 to December 30, 2011 and for the authorization to make use of the Model 1500 to accomplish a maximum of seven (7) Cobalt-60 shipment in calendar year 2011, as detailed herein. [1]
Please note that GEH does not request any changes to the Model 1500 design nor currently authorized contents, and that GEH will continue to maintain the Model 1500, Serial Number 1507, in accordance with the maintenance and operating procedures on file with the NRC through the requested time period. Further, GEH understands that this request will not be considered a form of certificate renewal, either under 10 CFR 71.38 or any other NRC regulation.
CE Hitachi Nuclear Enerav DRK 2010-30 Renewal GEH Model 1500 Rl.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 2 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 GEH shall continue to operate the Model 1500 Type B Package in accordance with the Quality Assurance Program Approval for Radioactive Material Packages, No. 0170, approved by the NRC under Docket No. 71-0170.
If there are any questions on this request, or additional information is required, please contact me or our Technical
Contact:
Mr. Carlos Martinez at (925) 862-4481.
Sincerely, Donald R. Krause cn=Donald R. Krause, o=GE Hitachi Nuclear Energy, °u=Vallecitos Nuclear Center, email=donald.krause@ge.com, c=US 2010.12.22 15:38:30 -08'00' Donald R. Krause Mgr., Regulatory Compliance & EHS
Attachment:
Model 5939 Supplemental Information Docket No. 71-5939 TAC No. L24282 cc:
Gaby Francis (GEH)
Andrew Langston (GNF-A)
Carlos Martinez (GEH)
Louis Quintana (GEH)
Michael Schrag (GEH)
David Turner (GEH)
GE Hitachi Nuclear Energy DERK 2010-30 Renewal GEH Model 1500 Ri.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 3 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 NRC RIS 2008-18, Information on Requests for Extending Use of Expiring Transportation Packages GEH Model No. 1500 Type B Package, Certificate of Compliance No. 5939 Docket No. 71-5939; TAC No. L24282 GEH currently operates one 1) Model No. 1500 Package, Serial Number 1507. The primary use of this Package is for the transport of Cobalt-60 sealed sources, in Special form, for medical and commercial applications. The Package is operated and maintained under GEH's Quality Assurance Program, Approval No. 0170, approved by the NRC under Docket No. 71-0170.
(1)
Package Information.
NRC Certificate of Compliance Number. 5939 (2)
Identification of Shipments.
(a) Number of shipments; (b) number of packages per shipment; (c) packaging serial numbers; (d) package contents; (e) end use of the radioactive material; (ft shipment origin and destination; (g) mode; (h) general timeframe; and (i) dote last shipment will be completed.
(a) Seven (7) Cobalt-60 shipments, using the Model 1500 Package, in calendar year 2011.
NbI Each shipment shall be accomplished using one (1) Model 1500 Package.
(c) Each shipment shall make use of Model 1500 Package, Serial Number 1507.
(d) Each shipment shall be comprised of Cobalt-60 (Co-60) as sealed sources that meet the requirements of Special form radioactive material. The number of Co-60 sources, and corresponding activity, will depend on the Customer's order; however, the maximum quantity of material shall comply with the approved content limits specified in Certificate of Compliance No. 5939.
(e) The end-use of the Co-60 sealed sources is predominantly for industrial, sterilization applications, with some limited research applications.
(f) Four (4) Co-60 shipments would originate at the GE-Hitachi's Vallecitos Nuclear Center (VNC), Sunol, California (location of the Co-60 special form encapsulation facility) and terminate at J. L. Shepherd & Associates ("JLS&A"), San Fernando, California (where the individual sources are installed in commercial process irradiators). In addition, JLSA has expressed interest to lease the GEH Model 1500 Package a maximum of three (3) in calendar year 2011 to delivery/pickup Cobalt-60 sources from as of yet undetermined U.S. locales.
(g) All Co-60 shipments shall be accomplished by truck, as "Exclusive-Use", and are subject to security measures applicable to Radioactive Materials Quantities of Concern (RAMQC) or Highway Route Control Quantity (HRQC) shipments (h) GEH anticipates to makes one Co-60 shipment to JLS&A every quarter in calendar year 2011, and for JLS&A to lease the Model 1500 Package in the 2nd, 3Yd and 4 th quarter of 2011, for a total of seven (7) Co-60 shipments in 2011.
(i) The last proposed Co-60 shipment, using the Model 1500 Package, would be completed on or before December 30, 2011.
(3)
Reasons for Requesting Extended Use.
GE Hitachi Nuclear Energy DGRK 2010-30 Renewal GEH Model 1500 Ri.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 4 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 Justification for Requesting Extended Use. Justification for extending the use of expiring packages must describe why acquiring replacement packages is not practical and why shipments cannot be made before the October 1, 2008, expiration dote. The justification must demonstrate that: (a) there are no alternative domestically approved packages available; (b) the contents cannot be reconfigured such that transport can be conducted in accordance with the regulations; and (c) the transport schedule cannot be adjusted so as to be conducted in accordance with the regulations. The justification must also describe any good-faith efforts to acquire replacement packages that meet the current package performance requirements, including a detailed description of post activities and the current status of acquiring replacement packages. In addition, any adverse impacts that will result if the shipment is not conducted should be fully described.
Without an extension for the Model 1500 through CY-2011, JLSA may not be able to deliver on existing customer commitments, including key government contracts. A change to a different Type B package would impact program schedule, costs, and deliverables, and would necessitate procedural modifications, personnel re-training, re-tooling and possibly some form of facility modifications at the receiver's end.
Section (5) delineates GEH's and JLS plans to acquire a replacement package for the Model 1500.
(4)
Safety Justification for Continued Use and Proposed Compensatory Measures Safety Justification for Continued Use and Proposed Compensatory Measures. Since the expiring package designs may lock safety enhancements included in newer designs, the request must include a safety justification for continued use and a description of compensatory measures that will be used to provide an equivalent level of safety. Examples of compensatory measures that may be considered are: (a) special package inspections, tests, or determinations that ensure that the packaging is in unimpaired physical condition; (b) transport by exclusive use; (c) transport during time of low road usage; and (d) accompaniment of shipment by escort equipped to effect a recovery in an emergency situation or in case of a transportation accident.
GEH has approximately 30-years experience safely operating and maintaining the Model 1500 Package. GEH shall operate the 5939 Type B Package, Serial No. 1507, in accordance with the Quality Assurance Program Approval for Radioactive Material Packages, No. 0170, approved by the NRC under Docket No. 71-0170.
GEH safely accomplished four (4) Co-60 shipments, using the Model 1500 Package, Serial No.
1507, from March 27, 2009 through November 22, 2010 without incident of any kind, and that J.L. Shepherd & Associates (JLS&A) safely accomplished two (2) Co-60 shipments using the 1507 Package in CY-2010, without incident of any kind either.
The Transport Index (TI), the external packaging surface dose readings and Curie content for the proposed Co-60 shipments will be below the exclusive use criteria for radioactive materials shipments, i.e., 200 mRem/hr not to exceed 1000 mRem/hr at the surface of the Package (per 49CFR173.441). Historically, past Co-60 shipments using the Model 1500 Package have not exceeded a TI value of 5.
GE Hitachi Nuclear Energy DRK 2010-30 Renewal GEH Model 1500 Rl.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 5 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 GEH is committed to transporting the Model 500 Package as "Exclusive-Use", as defined in 49CFR173.403 mode of motor transport. The shipments shall include the use of either closed transport or flat-bed style transport vehicles. The Package shall be secured during transport so that its position remains fixed during transport. Unless there is an emergency situation, no loading or unloading operations shall be performed during transit, i.e., between the start and end of the transport, and all work shall be performed under the direction of the Shipper or Receiver. Radiologically trained personnel shall perform all loading and unloading operations. Resources for the safe handling of the Package will be provided, including written instructions to the carrier to avoid unnecessary delays or unnecessarily radiation levels or radiation exposures to transport workers or members of the general public. In addition, written instructions pertaining to security measures and emergency response shall be reviewed with the carrier for RAMQC and HRCQ shipments, should the carrier not have something comparable provided by their employer. The applicable security and emergency response measures will not be delineated in this application.
The shipment of empty Packages will be exempt from exclusive-use transport requirements.
The Model 1500 Packages contain no exterior surface residual radioactivity above "background levels". Further, since this Package is used primarily to transport sealed sources which meet Special form criteria, and the Packages' internal cavity is essentially free of loose-surface radioactive contamination.
Best efforts shall be made to initiate and deliver a radioactive material shipment during off-rush hour traffic, and to use all loops within major cities. Transport restrictions associated with exclusive-use vehicles carrying RAMQC or HRCQ cargo will not be delineated in this application.
While a hazardous materials recovery escort is not practical to implement, there is a prior shipment notification process for all RAMQC and HRCQ shipments (that will not be addressed in this application). Affected State agencies would have the discretion and option as part of the prior shipment notification process to provide escorts for said shipment, if deemed necessary.
Please note that GEH does not request any changes to the 5939 Package authorized contents listing, and that GEH will observe all operating and maintenance procedures on file with the NRC through the extended period. Further, GEH understands that this request will not be considered a form of certificate renewal, either under 10 CFR 71.38 or any other NRC regulation.
(5)
A Plan and Schedule to Acquire Replacement Packages Details about the planned acquisition of replacement packages must be provided, along with key milestones, and proposed implementation dates, unless the licensee can show why acquiring a replacement package is not practical and why shipments cannot be made before the October 1, 2008, expiration date.
In February 2005, AOS entered into a contract with GEH to develop a Type B Transport Packaging System, in accordance with the provisions of 10 CFR Part 71, to replace the Model 1500. The application was submitted by AOS to the NRC in October 2007, and supplemented November 2007, under Docket No. 71-9316. In a conference call between AOS and the NRC GE Hitachi Nuclear Energy DRK 2010-30 Renewal GEH Model 1500 Rl.doc
GEH Application for Limited Continued use of the Model No. 1500 Page 6 of 6 Type B Package, Certificate of Compliance No. 5939 22 December 2010 on April 7, 2008, the NRC staff informed AOS of major technical deficiencies found in the application. On April 29, 2008, AOS informed the NRC staff, by letter, of its withdrawal of the AOS Transport Packaging System application, and intent to re-submit the application upon revising it to address the open technical issues identified by the NRC staff.
Revision B of the SAR was submitted by AOS to the NRC in September 2009. AOS received a Request for Supplemental Information (RSI) in July 2009. Revision C of the SAR and responses to the July 2009 RSI's was submitted to the NRC on September 2009. AOS then received Request for Additional Information (RAI) in December 2009. Due to the number and extent of the RAI's, the RAI responses and Revision D of the SAR was submitted on September 30, 2010.
NRC design and licensing approval is expected in 2011 and the first package ready-for-use is anticipated 6-9 months thereafter.
JLS&A too is working on the design and licensing of a Type B Package to-replace the GEH Model 1500 Package. Details of the JLS&A Package design and progress on the licensing of said Package are unknown to GEH.
GE Hitachi Nuclear Energy DRK 2010-30 Renewal GEH Model 1500 Rl.doc
GE-Hitachi Nuclear Energy Americas LLC DOMESTIC SN No: VAL34645 1989 Little Orchard St., San Jose, Ca. 95125 Page:
I Shipping Notice SN Date:
01/04/2011 Ref PO:
Frt Acct:
105454 1
ShipTo:
NRC Div Spent Fuel Storage & Trans.
Office Nucl. Mat'l Safety & Safeguards Washington DC 20555 Attn:
Document Control Desk TelNo:
Total Cases:
Total Cubic Feet:
I Marks:
Terms: Prepay Date:
Via: Federal Express Inv:
Need By Reason for Shipment:
Mati To Be Returned:
No Est Return Date:
Requested by: Carlos Martinez Phone: (925)862-4481 Description of Goods, Composition, DWG No.,
Catalog No., Case No., etc.
leach Rev 3 letters GEH's application for Limited Continued use of the Model No. 1500 Type B Package certificate No. 5939 Country of Manufacture: