ML19270G280
| ML19270G280 | |
| Person / Time | |
|---|---|
| Site: | 07106400 |
| Issue date: | 04/26/1979 |
| From: | Michel C NUCLEAR FUEL SERVICES, INC. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 12681, NUDOCS 7906060024 | |
| Download: ML19270G280 (9) | |
Text
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?bs 7/-09,,90 Nuclear Fuel Services, Inc. ERWIN. TENNESSEE 37650 t
+r 3'y-Q ; A Subsidiary of Getty Oil Company (615) 743-9141 iA J
.i li 43 ApSil26,1979 3
to 4
/ro Mr. Charles E. flacDonald, Chief Transportation Branch p
DOCKnO Division of Fuel Cycle and Material Safety UsNac O
U. S. Nuclear Regulatory Commission p
Washington, D. C.
20555 E-APR 3 01979 c, a NMss hy,'SFC7rc.y
Reference:
(1) Docket 70-143, SNM 124 g
(2) Letter, C. J. Michel to C. E. MacDonald, S
C N
dated December 22, 1978 g
(3) Letter, C. E. MacDonald to C. J. Michel,
=-
dated February 26, 1979
Dear Mr. MacDonald:
In response to reference 3, NFS submits the attached Safety Analysis Report for Plutonium Packaging. This Report demonstrates the follow-ing:
1.
Compliance with the double containment requirement for plutonium as specified in 10 CFR 71.42 utilizing the Super Tiger packaging with specification 17H inner con tainers.
2.
That the form of the plutonium to be packaged in Type A fiberglass reinforced plywood containers with-in the Super Tiger. package is nondispersable and essentially nonrespirable such that it should be determined to be exempt from the double containment requirement per 10 CFR 71.42(b)(3).
This Report further justifies the amendment to Certificate of Compliance 6400 that was requested in our referenced letter.
Your earliest review and approval of this amendment is requested in order that we may proceed with the decommissioning plans for our plutonium f acili ty.
Very truly yours, 79060600d
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C. J. Michel Administrative Manager CJM:kj Attachment
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MMi 2276.42
I SAFETY ANALYSIS REPORT FOR PLUiONIUM PACKAGIdG I.
INTRODUCTI0d Nuclear Fuel Services proposes to utilize the Super Tiger packaging presently licensed by the Nuclear Regulatory Commission as Certificate of Compliance USA /5400/B()F to transport contaminated waste generated in the decommissioning of its plutonium facility (see NFS Plan for De-commissioning of Plutonium and Uranium-233 Facilities, dated October 9, 1978). Although the Plan specifies decontamination of equipment prior to packaging, it is anticipated tnat some packaged objects will contain residue quantities of plutonium in excess of 20 curies.
Since the Super Tiger is not presently licensad to transport more than 20 curies of plutonium in oxide form, NFS requested, in a letter dated December 22, 1978, an amendment to the Certificate to pemit the Commission to specifically authorize shipments in excess of 20 curies of plutonium.
In response to this request for amendment, the NRC requested additional information in a letter dated February 26, 1979.
This Report contains the infomation requested in tjlat letter.
II.
SCOPE This Report is written to demonstra a:
(1) Compliance with the dochie containment requirement for plutonium, as specified in 10 CFR 571.42, utilizing the Super Tiger packaging with Specification 17H inner con-tainers, and (2) that the fom of the plutonium to be packaged in Type A fiberglass reinforced plywood containers within.the Super Tiger package is nondispersable and essentially nonrespirable such that it should be detemined to be exempt from the double containment require-ment per 10 CFR 71.42(b)(3).
d%Bi 2276
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Page 2 of 6 III.
SUPER TIGER /17H PACKAGING A.
Description The Super Tiger has been adequately described in the original application (see Engineering Evaluation of the Super Tiger Over-pack Designed for the Shipment of Large Quantities of Hazardous Materials, Dated flay 4,1970). Since no changes are proposed to the Super Tiger, the description is referenced. Similarly, the 17H packaging is well described in 49 CFR 5173.396 and 5178.118.
In addition, NFS proposes to equip each 17H container with a rigid polyethylene liner. The 17H with the liner is depicted in Figure 2.5.
The polyliner is 0.1 inch thick and closure is accomplished by using a slip fit poly lid that will be sealed with tape or adhesive. The 17H with polyliner is also described in RFP 2244 "ATMX-600 Rail Car Safety Analysis Report for Packaging", Rev.1.
B.
Testing Analysis The Super Tiger has already been successfully tested under both normal and accident conditions.
It provides the first barrier for plutonium containment. The second barrier for containment is provided by the 17H with the rigid polyliner. The integrity of the 17H container was demonstrated by the original Super Tiger tes ts. Two of the forty-two 55-gallon drums contained in the Super Tiger during testing were Specification 17H drums. As reported in the original application, these containers experienced little or no deformation and no liquid was lost from the containers.
This information and other details can be found on pages 63 thru 65 of the Engineering Evaluation.
The exact location of the 17H 2276 ;44 N
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Page 3 of 6 i
B.
Testing Analysis (cont'd) containers within the Super Tiger was ret gi/en in the Evaluation.
It is important to note that the Super Tiger was subjected to four 40-inch puncture tests, impacting on three sides of the package. These tests should have maximized damage to the inner containers regardless of location.
It should also be noted that the drums were not equipped with polyliners, nor were they banded or shored. This loose packing of the inner containers was to maximize impact between the inner containers during testing.
C.
Special Considerations To minimize the impact between the 17H drums within the Super Tiger under normal and accident conditions, NFS proposes to band the drums together in groups of four. 'Jooden shoring will also be provided to minimize move. ment of the drums during transport.
This will reduce drum damage since the banding and sharing will absorb impact energy.
To minimize the possibility of packaged objects piercing the polyliner and/or the drum, heavy, dense objects such as sheet metal, pipes, and concrete that have piercing potential will be tightly packed in drums, and low density waste (plastic, paper, cardboard, etc.) will be packed between the heavy objects and the polyliner.
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Page 4 of 6
IV.
SUPER TIGER / TYPE A FRP PACKAGING A.
Descriotion A typical FRP box is depicted in Figure 2.6.
Box specifications are detailed in RFP 2460 Safety Analysis Report for Packaging -
00T-7A Fiberglass-Coated Plywood Box for Transuranium Solid llas te". NFS proposes to use the FRP box as described in RFP 2460 with two exceptions:
(1) The inner 0.C51" fiberboard liner and lid will not be provided, and (2) sizes of the boxes used will vary from the specified 4' x 4' x 7' dimensions.
The fiberboard liner will be replaced with 1/4" plywood sheets on four sides of the box. The plywood will provide better protection from objects piercing to the other FRP box in the area where piercing is most likely to cccur.
Boxes will be sized specifically for the bulky pieces of-equip-ment to provide for a tighter fit, thus minimizing internal movement during transport. The boxes will also be sized to pro-vide a tight fit within the Super Tigar, again to minimize move-ment.
It should be noted that the dimensions specified in RFP 2460 were determined primarily by the size of ATMX railcar.
Sizes of the NFS boxes will vary from 65" x 75" x 162" to 40" x 41" x 61".
These variatior,s in sizes will not significantly affect the integrity of the box.
8.
Testing Analysis The FRP box has been successfully tested to meet the requirements for a Type A packaging. Details of the test results are presented 2276 c.46 1FJ1
Page 5 of 6 B.
Testing Analysis (cont'd) in RFP 2460. flo testing has been performed on the Super Tiger /
Type A FRP packaging; however, it is logical to assume that the Super Tiger would have maintained its integrity independent of whether it had been loaded with boxes or drums. The integrity of the boxes, on the other hand, cannot be assumed, so that the double containment of the plutonium for the Super Tiger / Type A FRP packaging cannot be assumed under accident conditions.
C.
Plutonium Immobilization flFS proposes to immobilize the plutonium contamination on the equipment to be placed in FRP boxes in order to render the plutonium nondispersable and essentially nonrespirable. With the plutonium in this form, it should be determined that the double containment requirement of 10 CFR 71.42 is not applicable as provided for in 10 CFR 71.42(b)(3).
NFS preposes to apply Turco 5931 Stripable Coating, or equivalent, on all contaminated surfaces of equipment that are packaged in FRP boxes. This coating will adhere to both stainless steel and plexiglass surfaces.
It has elastic properties that minimize cracking and chipping during impact.
It will easily withstand temperatures of 150 F that were experienced within the Super Tiger during the fire test.
It is non-flammable and can be applied with a brush.
It also has the property of retaining contamination if it is removed from the surface.
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Page 6 of 6 D.
Soecial Considerations Equipment will be packed in the boxes as described in Sections III.C and IV./. to prevent internal piercing of the containers.
NFS also proposes to remove ail objects that protrude from the large pieces of equipment so as to eliminate the possibility of these objects piercing the FRP box. Any force caused by internal movement of the packaged equipment will be displaced over a large area of the container, thus minimizing damage, if any, to the container. The removed protruding objects will be packaged in 17H drums where better protection is provided against piercing.
The FRP boxes will be shored with wood within the Super Tiger to insure a close fit and to minimize movement.
When FRP boxes are loaded in the Super Tiger, along with 17H drums, protection will be provided to prevent the drums from damaging the boxes. This protection will consist of a sheet of 1/4" plywood between the box and the drum and inflated o innace bags between the plywood and the box. Where space permits, these dunnage bags will also be utilized between boxes and be:. ween boxes and ca Super Tiger.
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