ML20041B467
| ML20041B467 | |
| Person / Time | |
|---|---|
| Site: | 07105552 |
| Issue date: | 01/26/1982 |
| From: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Ross D ENERGY, DEPT. OF |
| References | |
| NUDOCS 8202240069 | |
| Download: ML20041B467 (2) | |
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Gentlemen:
This refers to our review of your Safety Analysis Report for kagkh (SARP) for the Model No. Gas Cylinder Fire Impact Shield package, submitted by letter dated July 31, 1978, and supplemented on July 10, 1981 in response to our letter of December 27, 1978. With the exception of the response to our requests concerning shielding and leak testing (under the heading Testing and Maintenance) we find the responses provided in the July 10, 1981 letter to be inadequate. The other items in our December 27, 1978 letter should be addressed and resubmitted, subject to the comments provided below.
To evaluate the perfcmance of package safety features (i.e., containment barriers) they must be identified and defined through drawings and specifications. Each containment vessel requested for approval should be identified.
It appears that the flanged drum is the design requested for approval; however,10 CFR Part 71, Appendix B tests were performed on a different drum. Although the drum does not provide containment, it does provide physical protection for the containment vessel.
It must be sh'own that the drum continues to provide protection through all of the sequential hypothetical accident tests of 10 CFR Part 71, Appendix B.
To evaluate the ability of the gas cylinder to contain its radioactive contents under nomal and accident conditions, a containment criteria must be established. The package performance must be evaluated to detemine the response of the containment vessel to the test conditions of 10 CFR Part 71, Appendixes A and B.
The detemined perfomance must be expressed in tems of containment capability, and must be shown to satisfy the established containment criteria. A general arrangement drawing for each package in its shipping configuration should be provided.
The padded inserts used to secure the gas cylinder in the outer drum should be addressed in the evaluation; they should be specified and shown to maintain their position in the package if they provide significant protection under the test conditions of 10 CFR Part 71.
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U.S. Department of Energy 2-JAN 2 6 g The response to our request concerning gamma shielding is inconsistent with the DOE approval for this package. The DOE letter of July 10,1981 states that only tritium gas will be transported in Type B quantities, but the DOE approval (Certificete No. 5552, Rev. No. 3) is for no more than 30,000 Ci of tritium or any noble gas. Based on your July 10, 1981 letter we will consider your request to be for an approval for shipment of 30,000 C1 of tritium gas.
Please advise us within thirty (30) days from the date of this letter when the above information will be provided.
Sincerely, Charles E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety, HMSS cc: DOE, Oak Ridge Operations Office ATTN: Mr. William H. Travis P.O. Box E Oak Ridge, TN 37830 Distribution /:
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