ML12254B467
| ML12254B467 | |
| Person / Time | |
|---|---|
| Issue date: | 11/07/1990 |
| From: | Taylor J NRC/SECY |
| To: | Carr K, Curtiss J, Remick F, Rogers K NRC/OCM |
| References | |
| SECY-90-376 | |
| Download: ML12254B467 (4) | |
Text
November 7, 1990 POLICY ISSUE SECY-90-376 For:
(Information)
The Commissioners From: -
James M. Taylor Executive Director f o r Operations
Subject:
PLUTONIUM A I R TRANSPORT (PAT) PACKAGING REQUIREMENTS
Purpose:
To respond t o a s t a f f requirements memorandum dated September 21, 1990, i n which the s t a f f was requested t o 1) compare the proposed PAT packaging requirements, drafted t o s a t i s f y P.L.
100-203, t o e x i s t i n g requirements, developed e a r l i e r under P.L.
94-79, and 2) recommend whether r e v i s i o n o f the l a t t e r i s needed.
Background:
Section 5062 o f Public Law No. 100-203, known as the Murkowski Amendment, applies t o the transportation of plutonium, by a i r c r a f t, through U.S.
a i r space, from one foreign nation t o another, and requires:
(1)
U.S.
Nuclear Regulatory Conmission (NRC) c e r t i f i c a t i o n t o Congress t h a t the container used i s safe; (2) actual drop t e s t o f the container from maximum cruise a1 ti tude; (3) actual crash t e s t o f a cargo a i r c r a f t f u l l y loaded w i t h containers, unless the Commission determines, a f t e r consul t a t i o n w i t h an independent s c i e n t i f i c review panel, t h a t the stresses produced on the container by other t e s t s used i n developing the container exceed the stresses t h a t would occur during a worst-case plutonium air-shipment accident; and (4)
Commission evaluation o f the container c e r t i f i c a t i o n under the National Environmental Pol i c y Act (NEPA),
and compliance w i t h other applicable laws, including Pub1 i c Law 94-79 (Scheuer Amendment).
"NOTE:
TO BE MADE PUBLICLY AVAILABLE I N 10 WORKING DAYS FROM THE DATE OF THIS PAPER" CONTACT:
~
J. R. Conk. NMSS
The Commissioners At the request of the Power Reactor and Nuclear Fuel Development Corporation (PNC) of Japan, the Commission agreed to develop draft pac kage-testing criteria that would satisfy the Murkowski requirements (SECY-88-329).
The Commission subsequently identified the crash of Pacific Southwest Airlines Flight 1771 as representative of a worst-case aircraft accident, for the purpose of developing the draft test criteria (SECY-88-344).
After extensive study, Lawrence Livermore National Laboratory (LLNL), NRC's technical support contractor, reported that in worst-case accidents, the impact conditions are the most damaging factors. The Flight 1771 impact conditions consisted of an impact velocity of 925 feet per second (ft/sec) onto weathered rock.
Consequently, these impact conditions were used to establish both the draft aircraft-crash test criteria (SECY-89-208) and the draft controlled-test criteria (SECY-90-301). To facilitate testing, the draft-control led test criteria also provide for an impact onto a harder (essentially unyielding) test surface at a lower, but kinematically equivalent velocity.
Earlier, the Scheuer Amendment (Public Law 94-79, enacted in 1975), restricted NRC from licensing air transport of plutonium, until NRC certified to Congress that a safe container, which would not rupture under crash and blast-testing equivalent to the crash and explosion of a high-flying aircraft, had been developed and tested.
In response to the Scheuer Amendment, NRC developed qua1 if ication criteria for packages used for export, import, and domestic shipment of pluto~~ium by air (NUREG-0360, "Qualification Criteria to Certify a Package for Air Transport of Plutonium," 1978).
The test criteria in NUREG-0360 are based on an analysis of aircraft accidents that indicates that most aircraft accidents occur during the landing and take-off phases of the flight, and that the maximum airspeed permitted in approach and departure patterns is 250 knots (422 ft/sec). The test criteria in NUREG-0360 require a series of six sequential tests (impact, compression, puncture, tear, fire, and immersion), with an impact velocity not less than 422 ft/sec at a right angle onto a flat, essentially unyielding surface.
The Commissioners Discussion:
The NUREG-0360 criteria received an independent technical review and endorsement by both the NRC Advisory Committee on Reactor Safeguards and the National Academy of Sciences.
Two packagings (PAT-1 and PAT-2) have been certified by NRC as satisfying the NUREG-0360 criteria. To date, PNC packaging development testing has been to NUREG-0360 criteria; no packaging has been tested to the Murkowski Amendment requirements.
Although the impact velocity derived on the basis of the worst-case accident exceeds that of NUREG-0360
( e., impact velocity at 925 ft/sec onto a yielding surface or approximately 720 ft/sec onto an unyielding surface, for a representative package, vs. 422 ft/sec onto air unyielding surface), the staff's view of the technical adequacy of the NUREG-0360 criteria has not changed. The qualification criteria ensure that package survival will approach certainty in aircraft accidents occurring during take-off, landing, or ground operations. These types of accidents represent the majority of all zircraft accidents. The intention in developing the criteria was to clearly and conservatively encompass a reasonable upper limit of severity for such accidents. Considering the conservatism inherent in the criteria for protecting against take-off and landing accidents, the criteria also ensure a high degree of protection against extreme severity accidents in other phases of flight, including mid-air collision and high-speed crashes. The work performed to develop the draft worst-case accident criteria confirms that the NUREG-0360 criteria encompass more than 99 percent of all aircraft accidents on record, and that the frequency of a severe accident with impact velocity exceedjng 422 ft/sec, for large commercial jets, is 1.49 x 10- per departure, or one accident for approximately every 6,700,000 departures.
To calculate the probability of a plutonium shipment being involved in a severe accident, the forementioned value should be further reduced by the ratio of the departures, with and without a plutonium shipment. At present, the staff is not aware of any planned shipment of plutonium by air.
Considering the level of safety provided by the NUREG-0360 criteria, the low level of estimated risk in domestic plutonium air shipments, and the fact that the Murkowski Amendment explicitly stated that it "shz~ll not apply to any containers for the shipment of plutonium previously certified as safe by the Nuclear Regulatory Commission under Public Law 94-79...," the staff does not believe
The Comnissioners revision of the existing domestic requirements for the air shipment of plutonium is necessary. Accordingly, staff will continue to rely on NUREG-0360 packaging criteria for any export, import, or domestic shipment of plutonium by air. KRC has certified two packagings to meet the NUREG-0360 criteria: PAT-1, developed in 1978, with a maximum quantity of 2.0 kg radioactive material; and PAT-2, developed in 1981 with a maximum quantity of 15 grams fissile material. There have been no shipments of plutonium by air in the U.S. since the certification of PAT-1. The package design now under development by PNC would have a higher n~aximum quantity than the PAT-1. Should the PNC design be certified, a larger selection of packagings would be avbilable for U.S.
air transport of plutonium.
In compliance with Section 5062 of Public Law 100-203, if a package design for shipment from a foreign nation through U.S. airspace to a foreign nation is submitted to NRC for certification, it will be required to meet the Murkowski Amendment requirements in addition to meeting the NUREG-0360 criteria.
Coordination:
This paper has been coordinated with the Office of the General Counsel, and it has no legal objection.
ecutive D"irector for Operations DISTRIBUTIOE: