ML19257C910
| ML19257C910 | |
| Person / Time | |
|---|---|
| Site: | 07109136 |
| Issue date: | 12/14/1979 |
| From: | Cunningham G GENERAL ELECTRIC CO. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 8001310073 | |
| Download: ML19257C910 (7) | |
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ENGINEERING GENERAL ELECTRIC COVPANY, P.O. box 460, PLEASANTON, C ANOW A 9566 DIVISION r
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Mr. Charles E MacDonald, Chief
'J Transportation Branch U.S. Nuclear Regulatory Commission g5 Washington, D.C.
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Dear Mr. MacDonalti,
As discussed with you and Mr. Odegaarden recently in your offices, General Electric is conducting an orderly deactivation of its Fuels Laboratory at the Vallecitos Nuclear Center under SNM-960. The deactivation involves the transportation of glove boxes and hoods which are being decontaminated and boxed for disposal.
General Electric hereby requests an exemption pursuant to 10 CFR 71, Section 71.6, from the requirements of Section 71.7(a) and concurrence to apply, in lieu thereof, the provisions of the August 17, 1979 proposed Section 71.8(b) for the packaging and transporting of approximately 30 glove boxes in accor-dance with the procedures described herein and with the applicable require-ments of the Department of Transportation proposed January 8,1979.
This request is filed at this time because of tne uncertainty of the future date at which the proposed Part 71 amendments will become effective and because of our urgent need to apply the new standards for the glove box shipments before the February 29, 1980 anticipated commercial waste burial restrictions become effective.
The technical basis for granting this exemption is, in summary, the assignment of individualized Type A auantities for each radionuclide and the addition of a new classification of radioactive material, " low level solid" (LLS) in the proposed amendment of Part 71.
Individualized Type A quantities for each radionuclide will properly remove the present unnecessarily restrictive grouping of all radionuclides such that allowable curies are based on the most toxic re-ber of the group.
The new LLS classification is similar to the present " low specific activity" (LSA) mate-rial, except tha+ the LLS concept permits more radicactive material in the contents of a pacuage while imposing greater restrictions on the di bility and on the Armissible method of ship er.t.
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As stated in introducing the August 17, 1979 Part 71 proposed revisions, "although substantive changeu are proposed in or:er to provide a more uniform daaree of safety for various types of shipments, the Commission's bas 1c stan-darcs for radioactive packaging would remain uganged.'
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hr. Charles E. MacDonald ' December 14, 1979 Upon receipt of the exemption requested herein, General Electric will:
1.
Apply the LLS standard defined in proposed new ("n") 71.4(g)(2) and decontaminate all surf aces of each glove box and hood (item) such that the radioactive material is in a non-readily dispt sible form and the level of contamination averaged over 1 m2 (or the area of the surface if it is less than 1 m2) does not exceed 2 pCi/cm2 Note:
See Attachment A for a summary of the preparation of the decontaminated itens.
2.
Apply the provisions of "n" 71.8(b) which exempts packages or shipments of LLS from all the "n" Part 71 requirements except "n" 71.5.
The fissile standards of "n" 71.9 are met, i.e., not more than 15 grams of fissile radionuclides in the fully loaded vehicle.
Actually, not more than 0.5 grams fissile will be present in any load.
"N" 71.5 requires compliance with the applicable reauirements of the Department of Transportation (00T) in "n" 49CFR Parts 127 and 170-189.
3.
Apply D0T "n" 127.213, Traasport Requirements for LLS, as follows:
(a)
LLS must be packaged in accordance with:
"n" 127.101 General:
handling and securing during transport, safe mechanical handling, lifting attachment (none), minimum water retention and package additions (none).
"n" 127.105(a) smallest dimension 4 inches.
(e) withstand acceleration, vibration without opening.
(9) packaging materials compatit,le.
(m) meet tests of "n" 127.611 without loss or dispersal of radioactive contents nor radiation level increase.
Note: The results of testing a prototype package to the requirements of "n" 127.611 are given in Attachment B.
4.
Meet any other special procedures required.
Your affirmative response to this request by mid-January 1980 will enable retention of the current operating staff averaging over five years of experi-ence in the laboratory.
To attempt the decontamination work at sore future time with a new, inexperienced crew would not be in the best interests of public health and safety.
Please let us know if additional information is needed.
Yours very truly, A
G. E. Cu ingham Sr. Licensing Engineer 1843 053 GEC:rjy Attachments
t ATTACHMENT A AFL GLOVE 80X/H000 DECONTAMINATION PLAN
==
Introduction:==
This plan summarizes tb 3 major steps to be accomplisned to decontaminate AFL Glove Boxes and Hoods :]ntaminated with racioactive naterials.
The objective of this effort is to prcpare those glove boxes and hoods for shipment to approved burial siter in containers meeting regulatory requirements for radio-active contamination levels remaining in the glove boxes / hoods after decontami-nation.
Plan:
o Remove all bulk SNM.
o Remove all process and support equipment.
o Vacuum all interior glove box surfaces.
o Wipe all interior surfaces with absorbent pads campened with 0.6m HNO -
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Thoroughly clean all interior window and glove port gaskets with dampened absorbent pads.
o Replace glove box outlet pre and absolute filters, box gloves and bags.
o Bag out waste materials and let glove box interior surfaces dry.
o Perform a scan survey of all glove box interior surf aces using calibrated survey instrument.
o Note hot spots on plot map.
o RTV (silicon rubber mastic) all interior window and glove port ganets; let mastic set por manuf acturer's instructions.
o Decontaminate interior alove box surf aces per Process Operating Instruc-tion Number 6.1.8.
o Dry, survey and record survey results.
o Repeat as needed, including the use of abrasive v. heels until hot spots are reduced to release level 2 pci/cm2 averaged over not more than 1 m 2, o
Vacuum or damp wipe all interior glove cox surfaces, let dry and perform final survey.
o Submit survey results to Nuclear Safet. Technoloay (NST) for evaluation and release for shipping.
1843 054
ATTACHMENT A (Continued) o When NST release is received, thoroughly spray all interior glove box surf aces with an acrylic or paint film heavy enough to assure complete coverage of all surfaces.
o Apply RTV beads to all exterior glove box caskets.
Spray all exterior alove box gaskets, windows and penetrat on areas with an acrylic or paint i
film.
o Cover windows, alove and bag ports with 1/a" thick plywood covers. Secure covers by special AFL approved tape.
1843 055
ATTACHMENT B TESi REPORT FOR AFL GLOVE B0X PACKAGE
==
Introduction:==
Department of Transportation regulation 49CFR 127.611 (proposed)* prescribes tests to be conducted for proposed packaginc for transport of low level solids (LLS) radioactive materials. A prototype was prepared in accordance with 127.605 and tested.
The packar,ing, see Attachrent C, is constructed of 3/4" plywooc' on 2x4-inch fir framework with a 2"-thick base on 4x4-inch skids.
Vertica! corners, lower edges and joints are reir. forced by 20-gage mild steel angles. All internal and external. surf aces are painted.
The lid, also of 3/4" plywood on 2x4-inch fir framing, is similarly painted; edges are covered with flexible acrylic latex rubber caulk and fastened to the body with washered lag screws.
Design, fabrication and testing were performed under specific written quality assurance plan QAP 1-0-1.
Testing (127.611)
(a)
Water spray test Although the packaging is constructed of painted wood and all seams and joints are caulked, the prototype box was subjected to the one hour water spray test as specified in 127.611(2).
There was no distortion of edges or surfaces. At the coinpletion of all subsequent tests of 127.611 the lid was removed and inner surfaces were dry.
(b)
Penetration test There was no puncture of the 3/4" plywood (tF.e thinnest components of the packaging) a7ter the 40-inch drop of the 13 pound, 1-1/4 inch diameter rod.
(c)
Free drcp test The packaging specimen loaded to its maximum 2,500 porno capacity was dropped on a bottom corner in a manner evaluated to cause maximum damage to the safety feature being tested, i.e., the g L e box or hood must remain within the plywood box in such a nanner as to be retrievable for replacement on the vehicle to continue transport.
(Since all contamination is in a non-readily dispersible form within the inner surf aces of the packaged item, a simple opening of a box joint - wt'ch did not occur - would not have jeopardized sa'ety so long as the package rerrair:s transportable).
- All references are to numbers of proposed 30T regulations published January 8, 1979 (44 FR 1852 et. seq.)
1843 056
ATTACHMENT B (Continued)
(d)
Compression test The package consists of the packaging within which rests the stainless steel glove box or hood shored up with wood donnage to present an essentially solid mass to an adjacent package or array of such packages.
Thus, the only effect of a compressive load five times the weight of the package would be compressing of wood fibers in the packaging.
General Electric will arrange the transport as full-load; the containers will not be stacked during transport and will be used only once.
1843 057
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