ML20010D617
| ML20010D617 | |
| Person / Time | |
|---|---|
| Issue date: | 06/24/1981 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-1860, NUDOCS 8108280376 | |
| Download: ML20010D617 (29) | |
Text
PD2 8)U)H r'
DATE ISSUED:
6/24/81 FMR,s-tggo MINUTES OF THE p
p53 A
P{.
ACRS SUBCOMMITTEE MEETING ON j
TRANSPORTATION OF RADI0 ACTIVE MATERIALS h#
h p
~
MAY 20,1981 j
WASHINGTON, D.C.
53 4 24198 The ACRS Subcommittee on Transportation of Radioactive Materials held a meeting on May 20,1981 at 1717 H Street, N.W., Washington, D.C.
Mr. Sam Duraiswamytwap Designated Federal Employee for this meeting. A list of documents submittq ti el Subcommittee and its consultants is included as Attachment A.
a c 1 81981
- T3 ATTENDEES ACRS Members:
C. P. Siess (Subcommittee Chairman), C. Mark q
ACRS Consultants:
J. Langhaar, L. Shappert, Z. Zudans g
C. MacDonald, W. Lake, L. Gordon, W. McNeil, D. Hhp nt Principal NRC Speakers:
Principal DOT Speakers:
J. Shuler, R. Rawl.
INTRODUCTORY STATEMENT Bf THE SUBCOMMITTEE CHAIRMAN Dr. Siess, the Subcommittee Chairman, convened the meeting at 8:30 a.m. and indicated that the purpose of the meeting was to hold discussions with the representatives of the Department of Transportation (DOT) and NRC on certain items related to the trans-portation of radioactive materials such as:
1.
Transportation activities associated with D0T and the role of DOT in transportation safety.
l 2.
Transportation accident / incident experience.
l 3.
Inspection and Enforcement activities associated with transportation.
4.
Quality Assurance (QA) program requirements.
l Dr. Siess said that the Subcommittee had received neither vritten comments nor requests for time to make oral statements from members of the public.
PRESENTATION BY D0T - MR. SHULER, MR. RAWL.
i Mr. Shuler said that there are nine different divisions in DOT and five of which have been involved in the inspection activities associated with the transportation of hazardous matJrials. There are about 1200 trained DOT inspectors who are working in the hazardous material inspection area either full or part time. He stated that about 55 full-time personnel are involved in the inspection of transportation activities associated I
with hazardous materials; about 396 personnel are involved in the inspection of a carrier l
t I
1C60 W
Transportation Meeting May 20,1981 or shipper transportation-related facility to determine whether the operations in such facilities aFe in compliance with the appropriate Federal Regulations; about 85 personnel are responsible for inspecting the operations of the carriers and about 610 people are involved in inspecting the operations of the shippers.
Dr. Mark asked, what fraction of the total shipment is actually inspected by DOT snspectors prior to a shipment gets on the rodd? Mr. Shuler responded that it has been estimated that there are approximately 20 million total shipments of hazardous materials shipped during the course of a year. He believes that about 228 vehicles were actually inspected by DOT inspectors in 1980.
Dr. Siess asked whether the number of inspections for radioactive material shipments is higher or icwer than for other types of hazardous material shipments. Mr. Shuler responded that he believes that the number of inspections for radioactive material shipments seems to be higher. When asked by Dr. Siess as to whether more emphasis is given to radioactive material shipments because they are more hazardous or to be more responsive to public concerns, Mr. Shuler responded that DDT believes that radio-active material shipments are less hazardnus than other hazardous material shipments.
However, more emphasis is given to radioactive material shipments because of the t
public concerns.
I Dr. Siess commented that it seems that the problem is not to protect the people from what harms them but to protect them frcm what scares them.
l l
In response to several questions from Dr. Siess with regard to the responsibilities l
of the shippers, Messrs. Shuler and Rawl stated that it is not required that the shippers nake sure that the carriers are qualified or to infonn DOT as to who the carriers would be. The shipper's responsibility is to make sure that the material is packaged properly in accordance with the applicable packaging require-i, ments. Although the carriers are not normally involved in activities that would l
contribute significantly to safety, they are required to comply with certain spect-fic requirements applicable to them. Further, even though the shippers are not required to check the qualifications of the carriers, it is obvious that they are not going to entrust their products and packages to some unknown or questionable Carriers.
l l
i
Transoortation Meeting May 20,1981 Dr. Siess commented that it seems inappropriate that a shipper is not required to use an approied carrier. He believes that the shipper's r;sponsibility should not end when he loads the package on a truck; the shipper should at least have the responsibility of knowing that the carrier knows all the rules applicable to him.
Transporcation Violations and Actions Mr. Shuler discussed briefly the DOT experience in transportation violations, indicating that so.a of the violations they found fall into the category of improper labeling, and improper palacarding, improper classification of packages.
Mr. Shuler reviewed briefly some of the actions that may be taken by DOT for certain violations:
1.
A compliance order may be issued in lieu of a fine.
2.
Whenever there is a substantial likelihood that death, serious illness or severe personal injury will result from a violation relating to the transportation of a particular hazardous material, an injunction may be issued.
3.
A person who violates the requirements of 49 CFR is liable for a civil
~
penalty of not more than $10,000 for each violation.
I 4.
Any person who willfully violates the requirements of 49 CFR is liable f
for a criminal penalty of not more than $25,000 or imprisonment for not more than 5 years or both.
Mr. Shuler pointed out tnat, for a similar type of violation, the fine imposed by NRC is two or three times larger than that imposed by DOT. He pointed out also that, in accordance with the memorandum of understanding between NRC and 00T, if DOT finds a violation that has been committed by an NRC licensee, DOT may decide whether to take enforcement action or give it to NRC for action.
Emergency Response Mr. Shuler said that to date there are no known deaths or severe injuries resulting from radioactive material involvement in transportation accidents. However, he be-lieves that there are adequate provisions available to handle emergency situations
May 20, 1981 Transportation Meeting associated with transportation accidents to help minimize the radiological conse-quences. He discussed briefly some of DOT's emergency-response functions, indicating that DOT is involved in two major federal interagency activities:
1.
Federal Radiological Preparedness Coordinating Committee (FRPCC) for Radiological Emergency Response Preparedness.
2.
Interagency Radiological Assistance Plan (IRAP).
He said that the main objective of FRPCC is to make sure that States have effective response systems and plans to cope with radiological emergencies at fixed facilities and in transportation.
DOT's role in the interagency program is to handle emergency transportation coordination.
He added that DOT provides also a valuable support resource for handling transportation accidents through the Coast Guard National Response Center. Further, DOT has developed recently two training projects to aid first-on-the-scene response personnel to cope with conditions during radioactive material transportation emergencies.
In addition, DOT has sponsored the development of two training courses (with input from FRPCC, NRC and FEMA) to train certain personnel, such as firemen, law enforcement officials, etc., to cope with emergency situations until the arrival of radiological authorities.
Mr. Shappert asked whether it is true that, during an inspection, DOT spends most of the time in inspecting mechanically-related safety functions such as brakes, labeling, etc., as opposed to inspecting whether the dose rate outside the package is proper or not. Mr. Shuler responded that so far it is true. However, D0T is tryin,; to make some changes in the nature of their inspection. DOT inspectors on thc field are being trained to use radiation detection equipment to measure the dose rates and several such equipment are already on the field for their use. He believes that it will take some time to change completely the present inspection system.
In response to a question from Dr. Zudans with regard to the criteria for reporting l
certain events, Mr. Rawl stated that if an' event results in contaminatio'n that ex-ceeds the maximum DOT allowable limit, it will be required to be reported as a viola-tion of 49 CFR; however, if it results in contamination lower than the maximum DOT limit, it is not required to be reported. However, certain carriers report such an event voluntarily as an incident.
w
May 20,1981 Transportation Meeting 00T Specification Packages Dr. Siess asked about DOT's 6M specification package design. Mr. Rawl responded that the loading of a 6M specification package should be in accordance with the requirements of 49 CFR 173 and the construction of a 6M package should be in accordance with the requirements specified in 49 CFR 178.
Dr. Siess asked whether the statement in 49 CFR 173, which states " construction is not authorized af ter March 31, 1975", applies to the construction of 6M specification packages. Mr. Rawl responded that the cytoff date specified in 49 CFR 173 does not apply to 6M specification packages.
It applies only to the construction of specifi-cation 55 which is a metal encased shielded container authorized only for domestic shipments of not more than 300 curies per package. Mr. MacDonald added that any container that is similar to specification 55 and constructed after March 31, 1975 will have to go through certain tests and analyses to qualify for use.
Dr. Siess commented that it is not clear that among the specification packages included in 49 CFR 178, which ones are used for what purpose and which ones are overpacks, etc.; he suggested that a decision table to provide clarification on these issues would be helpful.
Dr. Zudans asked whether new specification packages can be developed and incorporated into DOT regulations in the future. Mr. Rawl responded that new specification packages can be developed and incorporated into DOT regulations provided NRC reviews and approves the new design in accordance with the memorandum of understard-ing between NRC and DOT.
l Dr. Siess commented that based on past experience and for economic reasons, it m;.y be appropriate to grandfather existing packages; but he does not see the logic in grandfathering a concept. Mr. Rawl responded that there is not a complete disjoint between the two approaches because all the new designs fiave to'be evaluated against the performance criteria in accordance with the memorandum of understanding between NRC and DOT.
In response to several questions from Dr. Zudans as to how the NRC Staff reviews and approves a specification package design, Mr. MacDonald stated that a speciff-cation package design is reviewed against certain existing standards. However, when approving a specification package design, it is not specified anywhere that it meets the requirements of certain soecific reaulations.
~
May 20 1981 Transportation Meeting 0
With regard to the dual package (DOT specification packages and.dC certified packages) approval process, Mr. MacDonald expressed his opinion, indicating that he believes there is no need to continue with the dual package approval system at the present time.
It is very difficult to apply specific regulations for approving a specification package design because it is a generic design.
It is also very hard to keep track of all the users of specification packages. He believes that it is better to back off from approving specification package designs and continue with certain specific certified package designs. He believes also that it is easier to keep track of the users of the NRC certified packages.
Dr. Siess commented that he agrees with Mr. MacDonald that there is no need to continue with the specification package designs because he does not see the logic in grandfathering a procedure rather than a product. Further, he believes that specification package designs are mostly based on prescriptive criteria as opposed to a particular package design that is based on performance criteria.
He believes that, in the long run, perfomance criteria will be better since they will help introduce new concepts and designs.
Mr. Shappert commented that the 6M specification packages could have met a set of perfomance criteria when they were developed; however, due to changes in regula-tions, they may not necessarily meet the existing criteria.
Commenting that the roles of DOT and NRC are clearly defined and separated as far as transportation safet) s concerned as compared to the package certification process where their roles and responsibilities are not that clear, Dr. Siess asked: were the spet.ification packages in existence before the Atomic Energy Commission ( AEC) got into the package activities and, how did this shared re-sponsibility in the package certification process come into. existence. Mr. Rawl responded that he believes that the AEC endoresed the specification packages and then approached DOT to get these pack' ages.i.acorporated into' their regulations. Mr.
Langhaar added that back in the 1960s packages were cert [ffed by AEC; a package certified for a particular applicant could not be used by other people unless they had that package recertified by AEC. There was a need for packages that anybMy could'use without having to go through the recertification process with AEC. When DOT was organize 1, pressure was put on them to adopt some specification packages that could be used by anybody without obtaining individual certification.
l r
Transportation Meeting May 20, 1981 As a result.qf that pressure, DOT got into the business of establishing specification packages.
In response to another question from Dr. Sless as to at what point the AEC or NRC gained the uponsibility for certifying Type P and Type A fissile packages, Mr. MacDonald stated that originally, AEC was responsible for certifying packages for transporting large quantity, and fissile-type radioactive materials.
00T thought that AEC should be responsible also for the Type B and lype A fist,ile pack-age certification. As a result, the memorandum of understanding between AEC and NRC was changed and AEC obtained the responsibility for certifying Type B and Type A fissile packages.
Mr. Rawl commented that there are many issues that need to be discussed in detail prior to making a decision on the continued use of specification packages. One of the important issues is the cost impact. An informal discussion between NRC and DDT indicates that it may require a separate rulemaking action to resolve the isstes associated with the elimination of specification packages.
Dr. Siess asked how many people make 6M specification packages. Mr. Rawl responded that he believes about five manufacturers are involved.
Dr. Siess asked about DOT's opinion on the dual package app-oval system. Mr. Rawl expressed his personal opinion, indicating that he believes that there should be a single regulatory agency that should be responsible for approving all of the packages that are used for transporting rudioactive materials. However, prior to implementing the policy shift that is being considered by NRC for eliminating speci-fication packages, NRC should consider all of the ramifications of such a shift in policy.
In response to a question from Dr. Siess as to whether there will be any risk-benefit analysis performed by liRC to estimate how much risk might be reduced to the public by eliminating or upgrading 6M specification packages, Mr. MacDonald staed that he believes some sort of value-impact analysis will be performed in the course of a rulemaking that would be used to e;ininate 6M specification packages.
S'
Transportation Meeting May 20,1981 Indicating that the 6M specification packages have been used by several foreign countries, Mr'. Langhaar asked about the impact on international trade of changing
~
or eliminating the 6M specification packages. Mr. Rawl responded that it would be difficult to predict such an impact. Several countries have modified the 6M specification packages in compliance with 1973 IAEA regulations. However, NRC and DOT are still in the process of revising their regulations to be consistent with 1973 IAEA regulatior,s. Som of the foreign countries are becoming 1.acreasingly resistant to accepting any packages that are not certified as meeting 1973 IAEA standards.
Dr. Siess suggested that the NRC try to provide a comparison of the 1973 IAEA requirements with 10 CFR Part 71 requirements in the next meeting.
Dr. Siess asked whether DOT has any strong objection to the certification proc ss that is based on performance criteria for certain classes of packages such a',
spent-fuel casks. Mr. Rawl responded that he does not have any objection co such a certification process.
NRC PRESENTATION Accident / Incident Experience l
Dr. Siess indicated that the Subcommittee's interest in the transportation accident / incident experience is twofold:
1.
Contribution of transportation accidents and incidents to risk to the public.
2.
Mechanisms to learn lessons from the transportation accidents and incidents.
He asked what kind of feedback does the Transportation Certification Branch of the NRC get on transportation incidents / accidents. Mr. MacDonald responcni that they receive preliminary notification and any other follow-up reports associated with transportation events that are issued by I&E.
Dr. Siess said that since the person who was scheduled to give the presentation on the Accident / Incident Experience item had to leave early, this topic will be rescheduled for discussion at the next meeting.
rr
May 20,1981 Transportation Meeting Quality Assurance Program Requirements Background /0bjectives - Mr. MacDonald Mr. MacDonald said that the requirements in early Part 71 gave all responsibilities to the licensee to establish and maintain operating procedues and also to inspect those procedures periodically to make sure that they are followed adequately. How-ever, as a result of certain incidents that occured under this system, it was realized that there was a need to upgrade the quality assurance (QA) program re-quirements so as to cet a commitment from the licensee management to comply properly with the QA requirements. The intent of the upgraded QA program is to reduce the probability of radiological incidents by controlled activities and to provide assurance that packaging is properly fabricated, used, and maintained. Mr. MacDonald indicated that he believes that implementation of the upgraded QA program would provide confidence to the NRC that proper compliance is being achieved and it would also pro-vide the public some benefit of knowledge that the safety programs are in force and are being complied with.
Mr. MacDonald pointed out that the non-compliance problems that they have experienced so far have been associated with Low Specific Activity (LSA) and Type A-nonfissile packages. He added that NRC has been discussing with DOT to develop some elaborate QA program requirements for these types of packages and' incorporate them into their regul ations.
l Dr. Mark asked what kind of reaction did NRC get from DOT when discussing development of elaborate QA programs for LSA and ;ype A-nonfissile packages. Mr. MacDonald re-sponded that it seems that itere is some kind of reluctcnce on the part of DOT to i
incorporate elaborate QA prograia requirements into their regulations for radioactive materials because they do not view radioactive materials as being much of a problem as compared to other hazardous materials where they have had some bad experience.
With reference to Annex 1 to the Draft Rcg'ulatory Guide, " Establishing Quality Assurance Programs For Packaging Used in the Transport of Spent Fuel, High-Level Waste and Plutonium", Dr. Siess commented that the ND.C Staff seems to suggest in this Guide that all the items associated with Qt program are equally important.
However, he i's 'not sure that they are all equall; 'mportant. He believes that there are two types of approaches to QA progra:
W
~
Transportation Meeting May 20,1981
- i. One approach is to identify everything that net.ds to be done and include in the QA program with the assumption that every identified item will be looked at thoroughly with equal importance.
2.
The second is a graded approach, using a fault-tree / event-tree type analysis to identify the major contributors to risk and concentrate on those.
He believes that the graded approach will provide better results than the other approach. He suggested that the NRC think about using such a graded 6pproach in the QA program for radioactive material transportation. Mr. MacDonald responded that he believes that the graded approach is being applied in the spent fuel package area to address those major items that are important to safety. However, it is up to the licensee to identify such items of safety significar.ce.
Dr. Mark commented that giving much importance to spent fuel casks is understandable and necessary. Hdwever, it does not seem appropriate to ignore small packages.
Ignorinj small packages is somewhat similar to ignoring small-break LOCAs.
Dr. Siess asked about the nature' of the QA program requirements fcr certain State licensees and aisc for Agreement State licensees. Mr. MacDonald responded that a State licensee must follow the DDT requirements which in turn refer them back to applicable NRC requirements. However, a State licensee is not required to have the same level of QA program as a NRC licensee. With regard to Agreement State programs, Mr.MacDonald said that if an Agreement State ifcensee tra.morts into an NRC State, then he has to have the same typc of QA standards that NRC has; however, within the Agreement State itself he does not have to have a QA program that is equivalent to what NRC requires of its licensees.
Dr. Siess commented that he thought, in accordance with the regulations, if a State wants to become an Agreement State to ragulate radioactive materials, it has to have the same type of standards that NRC has. He bellees that allowing a State to have different types of QA Standards does not seem appropriate and there seems to be a big loophole in the regualtions. Further, it is not clear to him to what extent NRC monitors or audits the Agreement State programs to assure itself that the Agreement States are doing an adquate job.
Transportation Meeting May 20, 1981 Mr. MacDonal.d stated that they are aware of this inconsisency and they working toward upgrading DDT requirements so as to avoid this loophole.
Mr. Shappert commented that he does not understand why such a loophole exists in view of the fact that an Agreement State agrees to have Standards similar to NRC Standards. He wondered why wouldn't the NRC convince itself that the QA part of the agreement was equivalent to what NRC requires.
QA Program - Mr. Lake Mr. Lake reviewed briefly the QA program and the specific QA requirements of 10 CFR Part 71. He stated that a QA program comprises of all those planned and systematic actions necessary to provide adequate confidence that a system or component will perform satisfactorily in service. He said that one of the major requirements of 10 CFR Part 71 is that anyone who is engaging in any activities in transportation must establish, maintain and execute a QA program.
In response to a question from Dr. Siess with regard to the QA program and procedures associated with a specification package, Mr. MacDonald stated that an Agreement State licensee using a specification package might not only not have a QA program but might not even have a good procedure to follow.
Mr. Lake said that Appendix E to 10 CFR Part 71 lists criteria for a QA program for shipping packages for radioactive materials. These criteria are bascially those that are included in Appendix B to 10 CFR Part 50, but are modified as appropriate to address transportation.
Dr. Siess commented that a major portion of Appendix E criteria seems to apply to people who are designing and.nanufacturing packages, but they do not seem to apply to those who are shipping packages.
It is not distinguished properly which of the criteria would apply to manufacturers and which would apply to shippers.
Dr. Siess asked about the QA program for facilities that are manufacturing radioactive f
materials. Mr. MacDonald responded that such facilities are not required to have a QA plan until they start shipping radioactive material.
Mr. Lake discussed briefly the graded approach to QA programs, the types of guidance provided to licensees, and the roles of NMSS and I&E in the Q, program area
( Attachment B, Pages 1-4) y
4 Transportation Meeting May 20,1981 With regard to licensee QA program reviews, Mr. Lake stated that about 350 QA programs have been approved as of November 1980. From January 1979 until January 1981, NRR's QA Branch performed QA program reviews. However, in January 1981 NMSS has established in-house capability for QA review and since then the Fuel Cycle Transportation and Certification Branch of NMSS has the responsibility for performiag QA reviews.
QA Program Review Process - Mr. Gordon Mr. Gordon discussed briefly the review process for the QA program ( Attachment B.
Page 5). He stated that they basically perform the following three types of review in cupport of:
1.
Design, fabrication, testing, maintenance, and use of shipping packages to transport irradiated fuel, high-level waste, and plutonium.
2.
Design, fabrication, testing, maintenance, and use of shipping packages to transport normal and special form radioactive material.
3.
Procurement, maintenance, repair, and use of shipping packages to transport sealed sources used in radiography.
Dr. Siess commented that it does not seem appropriate to lump all of the categories (Design, Fabrication, Testing, Maintenance, and Use) together in the review pro-He does not believe that there are too many people who are performing cess.
all of these things.
Mr. Gordon discussed briefly the principal QA program evaluation criteria (Attach-ment B, Page 6).
QA Program Inspection - Mr. McNeil, I&E, Region, IV Mr. McNeil, representing the Vendor Inspection Branch ( Attachment B, Page 7) of the Region IV ISE Office of the NRC,* reviewed briefly the main objectives of that Branch, which at this time inspects only mhnufacturers of spent fuel shipping casks:
i 1.
To verify that the QA program is consistent with-the requirements delineated in Appendix E to 10 CFR Part 71.
2.
To verify that the QA program is properly implemented.
3.
To verify that the QA program is effective end give assurance of conformance to the design and the certificate.
4.
To identify any conditions which may adversely affect cask performance.
Transportation Meeting May 20,1981 Mr. McNeil discussed briefly the inspection requirements for welding processes (Attachment B. Pages 8 and 9).
In response to a question from Dr. Mark as to how they determine that a heat treatment operation associate with a certain type of welding process is pro-perly done, Mr. McNeil stated that they would nonnally go to the shop *and actually watch the welder and also check things such as the required settings on the amperage and voltage meters. -They will check also the welding procedure qualification record to determine the adequacy of the procedure itself.
Dr. Zudans asked if preheating is required in a welding operation, how do they check that it is preheated to the specified temperature? Mr. McNeil responded that if preheating is required, it has to be spelled out clearly in the procedure.
Further, the method of verification for the welder has to be spelled out.
I&E would normally verify these procedures and also check whether the welder is using the appropriate instruments such as contact pyrometers, etc.
Mr. McNeil provided a summary of the spent fuel shipping cask production in U.S.
and also a summary of the history of the cask inspections performed so far by the Vendor Inspection Branch ( Attachment B, Pages 10-14).
SUBCOMMITTEE REMARKS Dr. Siess said that the task in front of the ACRS is to review the procedures applied by the Transportation Certification Branch of the NRC in certifying packages for shipping radioactive materials to determine whether they are in compliance with the existing regulations. As a part of this review, the Subcommittee has decided not to review the regulations because they are subject to change. However, he is not sure whether the Subcommittee can review only the transportation certification procedures and avoid looking at the other part of the transportation program. He feels that the ACRS may want to infonn the Commissioners that it would like to provide some comments on the overall transportation program and on the role of NRC in that whole program.
Dr. Siess indicated that there seems to be some sort of disagreement between NRC and DOT about performance criteria versus prescriptive criteria.
NRC seems to be
Transportation Meeting May 20,1981 more comfortable with the use of performance criteria in the package certi-fication process.
Further, NRC intends to go strictly with the certified packages instead of specification packages such as 6M.
However, he believes that the economic implications of eliminating the specification packages have to be looked at carefully and it should also be determined whether there will be enough risk reduction potential to justify that kind of action.
With regard to the roles of Agreement States in transportation activities, he believes that the States should have the same type of requirements as NRC has and that they should enforce those requiremer.ts with the same degree of efficiency as NRC.
He believes that certain issues associated with the roles of Agreement States need to be clarified further; he feels that representatives from the State Programs office of the NRC should attend a future meeting to discuss some of these
~
issues with the Subcommittee.
FUTURE MEETING Dr. Siess said that there may be a two-day meeting sometime in the month of September which is expected to be held at Oak R.idge.
During that time, the Subcommittee may visit the Oak Ridge Laboratory to look at some of the package designs.
During this meeting, the Subcommittee will start discussing in detail the NRC's package certifi-cation procedures.
Dr. Siess thanked all participants and adjourned the meeting at 5:45 p.m.
l l
l e
Ir
Transportation Meeting May 20,1981 LIST OF DOCUMENTS 1.
Tentative Presentation Sch'edule.
2.
Minutes of the March 10, 1981 Subcommittee meeting on Transportation of Radioactive Materials.
3.
List of Manufacturers and QA Program approvals for Major Irradiated Fuel Shipping Casks.
4.
Staffing of the Transportation Certificaton Branch of the NRC with education and experience.
5.
Memorandum of understanding between NRC and DOT.
6.
DOT's 6M Specification Package.
7.
QA for Transport Packages.
S.
Transport of Radioactive Material Potential Hazards.
9.
Concern Expressed by Governors, etc.
10.
Summary of NRC-Inspection-Enforcement Activities Relating to Transportation of Nuclear Wastes (October-December 1980).
- 11. Experience in the NRC Program for Inspection and Enforcement of Nuclear Waste Transportation in the U.S. A. by A.W. Grella.
- 12. A review of U.S. Accident / Incident Experience Involving Transportation of Radioactive Material (RAM) 1971-1980 by J.D. McClure and E. L. Emerson.
- 13. ANSI N14.10.1-1973, " Administrative Guide for Packaging and Transporting Radioactive Materials".
- 14. State Surveillance of Radioactive Materials Transportation.
15.
Some Materials associated with Transportation activities in Japan.
ATracunsar 11, R~
IHE GRADED APPROACH FERTINENT REQUIREMENTS OF APPENDIX E APPLIED INACCORDANCEWITHSAhETYSIGNIFICANCE GENERIC--BY NRC, BASED ON PACKAGE TYPE SPECIFIC--BY LICENSEE, BASED ON SPECIFIC PACKAGE FACTORS AFFECTING 6ENERIC 6RADING
- COMPLEXITY OF PACKAGE TYPE
- RELATIVE HAZARD OF PACKAGE TYPE
- SPECIFIC OA REQUIREMENTS SATISFIED BY OTHER REGULATidNS FOR A PACKAGE TYPE FACTORS AFFECTING SPECIFIC GRADING
- SAFETY SIGNIFICANCE
- COMPLEXITY OR UNIQUENESS l
- SPECIAL REQUIREMENTS l
-NINSPECTABILITY
- 90ALITY HISTORY AND STANDARDIZATION 6111 DANCE TO APPLiCMIS AND llIEllSEE1
- GENERICALLY GRADED GUIDANCE
- FORMAT'FOR APPROYAL APPLICATIONS
- DEVELOP, ESTABLISH AND MAINTAIN hrrecHHent,8 QA PROGRAMS 3
Y
(
t G U n1 dance GENERIC 6RADE FORMAT SET-UP AND OPERATION (APPROVAL TYPE) 6UIDANC_f 9
QF O M ORRAM SPENT FUEL, HIGH-LEVEL LETTER TO LICENSEES DRAFT REGULATORY GUIDE WASTE AND PLUTONIUM DATEDMAY 22, 1978 (TP-020-4)
ALL ASPECTS OF GA FOR INTERIMbRANCHPOSITION DRAF.T REGULATORY GUIDE NORMAL /SPECIAL FORM
_"10 CFR 71 - AntENDix E, (TP-019-4, IN PREPARATION)
RADIDACTIVEMATERIAb ACCEPTANCE CRITERIA -
TRANSPORTATION PACKAGES EOR NORMAL /SPECIAL FORM RADIOACTIVE MATERIAL" QA PERTAINING TO PRO-LE[TERTOLICENSEES DRAFT REGULATORY GUIDE CUREMENT, USE, MAINTENANCE, DATED MAY 1, d978, AS (TP-021-4, IN PREPARATION)
ANC REPAIR OF PACKAGES FOR AMENDED INDUSTRIAL RADIOGRAPHY DEVICES m
-1 (3 - 2,
LifEtlSEE_D/LREQUBEMENLS.
GENERII_AND_SEECLEIC_6RADING ggngut SEEctrx ACTIVITY PACKAGES COMPONENTS AND ACTIVQIE_S.
l AFFEC
>NO C
AFET YES s
i EVALUATION I
- e, lgg jCRITERIA e
og AND i
A I
IMPORTANCE IlATING 8
l l
SCllEME A
g OTHER GRADED '
O FACTORS i
\\
i l
\\
I 6RADED 00 l
PROGRAM l
t i
< ()
6-3
3 13
[0MP_LIMENIARY_RQLES__OF NMSS AND_lE IN _0A IlMSS
> IS Tile ORGANIZATION AND MANAGEMENT CONTROL SUFFICIENT TO SATISFY DA REQUIREMENTS?
= DOES THE ESTABLISHED DA PROGRAM MEET:
APPENDIX E CRITERIA, APPROVAL CONDITIONS AND MANAGEMENT'S COMMITMENT?
NMSS/IE
=
ARE THE RULES AND REGULATIONS EFFECTIVE?
ARE THEY BEING IMPLEMENTED EFFICIENTLY?
O e
B - f....
l l1ll 11 1ll
- I e _
~5 B
t e
b L
3 A
P V
T O
- N 0
R I
0 P
O P
P A
g O
F N
I L
L A
A V
N 0
O B
I A
T V
P I
A R
D L
DA M
N R
D I
E T
R A E T
S G
T A C U
E 0
R T A NP U
A L IM 3
EC D P O
O E
P_
Q A
C F
R d
i N
I L
E
.D)
A T
S G E X N
A S
O T X O
U E
R E X I
Q C_
P K -
T E
0 C 1 R
A O 7 D
AD I
E_
Q D(
D N
W A
I E
L T
N I
V G
A O
I E
O T
M I
B R
T B
T P
I U
A M
S C
A B
I Q
U L
S P
PA TNAC a
I L
P P
A n
7'T PRINCIPAL QA PROGRAM EVALUATION CRITERIA APPLICANT IS REQUIRED TO:
DEMONSTRATE THAT INDIVIDUALS RESPONSIBLE FOR CHECKING AUDITING, INSPECTING, OR OTHERWISE VERIFYING AN ACTIVITY IS CORRECTLY PERFORMED IS INDEPENDENT OF
~
INDIVIDUALS CESPONSIBLE FOR PERFORMING SUCH ACTIVITIES.
DEMONSTRATE ENDORSEMENT OF AND CONTINUING INVOLVEMENT IN 9A PROGRAM.
DEMONSTRATE 0'j'LiTY-RELATED ACTIVITIES ARE CONDUCTED IN ACCORDANCE WITH WRITTEN POLI-CIES, PROCEDl;RES, AND INSTRUCTIONS.
DEMONSTRATE QUALITY-RELATED ACTIVITIES ARE CONTROLLED TO THE' EXTENT CONSISTENT WITH IMPORTANCI TO SAFETY.
DEMONSTRATE SUITABLE PROFICIENCY OF PEP.SONNEL PERFORMING QUALITY-RELATED ACTIVITIES INCLUDING PROPER INDOCTRINATION AND FORMAL TRAINING.
~
~
DEMONSTRATE MANAGEMENT WILL REVIEW STATUS AND ADEQUACY OF QA PROGRAM.
6 9
e 9
4 sc
U aC I
)
W w
J
=
l' U
DZ CO 2
q WC Hh JW-ZO W (C <
WW VCZ Z
EM}
c.
- Z.
u_C m 3 Q.
Om LLJ >- atl W
W Z
th Z
E W
>JO W
WEJ F
XJWI th 3 M CQ W GUEW M
W = < V. X EEZQO EE
!_" " L U 1 O Oi J
pg <. '....
OM lr.N mT.
< L.A 11 WW O.
W >= >
C% C/ J.
C Z.
p =
at:0 *= U U M'
IWW Ut/M Elt C'
W U">
W CL E
W O W
I D. U") Z U
. E- =;l'
< b-C
>DE M-OO<
-J Cl CLLLt.D d
- .J EJ Z
JZW-EO
. z,....
.w
--v"t- -r v)
W X >= W W W
>j F
to O E J >-
Z W E D U -.J D h CX/)
W &c E
o I
c.
3LCIO> m EO
=
U t/A C3 EO W
e-=
W F
- =
u 15 W
UC D.
Z th to Z toe >EQ ZO EWWWE WHJXW F
U3 J to.J E CQ WU WJOW<O yw zn12n v c_er M
E F
O CCM
<W M
~
g-
Joint Fitur pnd Ucidine Procedure no. : Sico:1 Issue Date:
2/../76 1
SECTION II INSPECTION PIQUIPIMENTS Survey ongoing fabrication activities and select typicci in-process operations representing different welding processes procedures and joint configurations for detailed review. This review will include the following:
1.
Verify that work is conducted in accordance with a " traveler" or similar document which coordinates and sequences all operatiens, references procedures or instructions" establishes hold points and provides for production and QC signoffs. This document should be available at the work station.
2.
Verify that welding procedures, detailed dravings and instructions if applicable, and weld data sheets are at the work station and readily available.
3.
Verify that the WPS assign =ent is in accordance with the applicable ASMI Code require =ents.
This is accomplished by comparing the essential variables of the WPS to the production veld.
4.
Verify that welding technique and sequence requirecents are specified.
5.
Verify that the base metals, velding filler materials, fluxes, gases and backing materials are of the specified type and l
grade, have been properly inspected, tested and identified and I
are traceable to test reports or certifications.
6.
Verify that weld joint geometry is as specified and that surfaces to be welded have been prepared, cleaned and inspected in accordance with applicable procedures or instructions.
7.
Verify that parts to be welded are assembled and held in place l
within specified gap and alignment tolerances and verify that the alignment is within limits allowed by the ASME Code.
8.
Verify that temporary attachments such as bridging bars or fit-up clips have been attached by qualified welders, in accordance with qualified WPS.
II-1 El-8 m
[,..
Joint Fitup and k'aldire Procedure Ec. :
55902E Issue Date:
2/18/76 SECTION III INSPECTION GUIDANCE
References:
10 CFF. 50. Appendi.i B ASME Code - Sections III and IX Reg. Guide 1.31 - Contrel of Steinicss Steel Welding Reg. 1.4,4 - Control of the Use of Sensitized Stainless St N1 Reg. Guide 1.5v - Control of Prcheat Te=perature for Weldin; of Low-Alley Steel In conducting this inspection, the inspector should attempt to obtain a good cross section of production velding.
It is not necessary that all of the appliccble requirenents be verified on each production weld selected for review.
Cu==ulative coverage (review of several welds at different stages of co=pletion) can be substituted if desired.
A worksheet listing the basic requirements and identifying specific produttien velds used for each verification mzy help to organize the inspection effort.
Qualification of welders and welding operators identified in para. 23 of Section II will be reviewed under Procedure No. 55906.
9 e
III-1
'B-q w-
T.ARY.0F SPENT FUEL SHIPPING CASKS i.
. Design Model C of C Fabricator g
GE IF 300 9001 GE/ STERNS 4
NFS-4 6698 NFS/ STERNS 2
NAC-1 6698 NAC/EXCELCO 5
NLI 1/2 9010 NLI/NLI 5
NLI 10/20 9023 NLI/NLI 2*
TN 8 9015 TNP/ROBATEL 0+2*
TN 9 9016 TNP/ROSATEL 1+1*
?
?
TN 12 s
- in fabrication TNP=Transnucleaire (Paris)
W o
/, -
B-m lr
StRetARY OF TIIE HISTORY OF CASK INSPECTIONS DATE DOCKET NO.
COMPANY INSPECTOR SCOPE FINDINGS Oct. '72 70-1299/72-01 Stearns Tillou Contract Weld Qualifica-QA Program tion QA Hanual Audits Audits Test Control Nonconformances X-Ray Test Control Records Records Control of Special Processes Dec. '72 70-0959/72-02 Stearns Brown Test Control Test Control Audits Records Control of Special Processes Jan. '73 99900045/73-01 Stearns Brown Records Test Control Feb. '73 70-1220/73-01 Stearns Ridgway Design Control Test Control Records Audits May '73 70-1220/73-02 Stearns,
Ridgeway lest Control Aug. '73 70-1220/73-03 Stearns Ridgeway Test Controls Procurement Procurement Control Control Jan. '74 99900090/74-01 NLI Sanders Procurement Control Audits Control of Special Processes May '74 99900091/92/14-01 Transnucleaire/
Brown Audits Rohntel Procurement Control Management Meeting I
sh
DATE DOCKET NO.
COMPANY INSPECTOR SCOPE FINDINGS l
l June '74 70-1220/74-05 Stearns Oller Procurement Control NaterialControl l
ifaterial Control l
Control of Special Processes Sept. '74 70-1220/74-07 Stearns Oller Test Control Oct. '74 99900091/92/74-02 Transnucleaire/
Brown QA Program l
Rohatel May '74 70-1510/74-01 NAC lierdt Design Control Design Control Audits Audits June '74 70-1510/74-02 Excelco Herdt Test Control Control of SpeciaD Control of Special Processes i
1 Processes' 4
l Oct. '74.
70-1510/74-03 Excelco lierdt Records
. Records Audits Test Control Test Control l
Control of Special l
Processes i
e i
i i
C6 si
N
SUMMARY
OF THE HISTORY OF CASK _I_NSPECT_I,0NS rINDINCS DATE COCKET NO.
COMPANY INSPECTOR _
SC_0PE _
March, 76 99900090/76-01 NLI M-Neill Material Control, Welding, NDE Document Control Welding, NDE, Process Control Document Control.
Process Control May, 76 99900091/76-01 TNP McNeill Design C,ntrol, Sub-M its, Records Tillou Vendor May, 76 99900092/76-01 Robatel McNeill Process Centrol, Welding, NDE Material Control Tillou Test Can',.rol, Welding Sub Vandor HDE, Material Control March, 77 99900090/77-01 NLI McNeill Test Control, Sub-Sub-Vendora Auditing, Trainir Vendor, Auditin".
Process Control, NDE Training June, 77 99900091/77-01 TNP McNeill Records, Audits, Non-Audits lloward conformance Controls June, 77 99900092/77-01 Robatel McNeill Calibration, Audi ts, Process Control, Test Contr linward lleat Treatment, Process Control, Test Control December, 77 99900090/77-02 NL1 McNeill lead Pour, Ifeat Treat-Records, Welding, sub-Vendt ment, Design Control, Process Control. Document Control, Records, Welding, Sub-Vendor March, 78 99900331/78-01 Excellco McNeill Document Control, Process Docuent Control, Procr Control, Welding, NDE Control, Wolding, NDE Code April, 78 99900090/78-01 NL1 McNeill Material Control, Process Material Control, Pror l
Wescctt Control, Test Control, Control, Test Control.
l TripP Welding Document Control Welding, Document Cont l
June, ~3 99900331/78-02 Excellco McNeill Training, Process Control, Training, Process Con' I
Sub-Vendor, Audi t Sub-Vendor, Audit, wel Dec., 78 99900331/78-03 Excellco McNeill Material Control, Calibration Material Control.
- fonconfomance Controls Calibration, Noncon-fomance Centrols, D
Weiriing April, 79 71006698/79-01 NAC licNeill Dimensional inspection
I
. DATE DOCKET No.
(nyppyg rNsfrCIm 3copg flNU)NGS_
July, 79 99900331/79-01 Excellco McNeill Records Records Conway Oct., 79 99900091/79-01 TNY McNeill Records Nov., 79 71006698/79-02 NAC McNeill flDE Ilunter Feb. 80 99900090/80-01 NLI McNeill Records Records Feb. 80 99900382/80-01 GE McNeill Records Records 71009001/81-01 Conway Odeparden July, 80 99900092/80-01 Robatel McNeill Test Controls, Test Controls, Nonconformand Nonconformance Controls Controls S
e f
B - %1.