ML20045H674
| ML20045H674 | |
| Person / Time | |
|---|---|
| Site: | 07109254 |
| Issue date: | 07/02/1993 |
| From: | Maxin A NUCLEAR FUEL SERVICES, INC. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20045H675 | List: |
| References | |
| 28T-93-0108, 28T-93-108, ACF-93-207, NUDOCS 9307210114 | |
| Download: ML20045H674 (15) | |
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NM MEMORANDUM 28T-93-0108 LIC-01 ACF-93-207 -
Division of Safeguards and Transportation July 2,u1993.'
U; S. Nuclear Regulatory Commission Washington, DC 20555 Attention:
Mr. Charles E. MacDonald, Chief Transportation Branch i
Reference:
1)
Docket No. 71-0249 2)
NFS C of C Application 40G-A, Revision 0, dated February 3,1993 to NRC.
3)
NRC Letter dated April 27,1993 from C. E. MacDonald to NFS.
Gentlemen:
Nuclear Fuel Services, Inc. (NFS) hereby submits the revision to reference ~ 2. The entire
. package is submitted for clarity.
Comments expressed by Reference 3 are incorporated into the. revision. Additionally, each '
comment is addressed in an enclosure to this letter indicating which sections of the revision
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have been changed. Revised sections are also indicated by a vertical line in the right margin.
NFS requests a meeting be held at your earliest convenience to discuss the contents of this submittal and the anticipated schedule for issuance of the certificate.
If you need additional information, please contact Mr. Rik'Droke at extension 1124, or me.
Please use our unique identification number (28T-93-0108) in any correspondence concerning.
this letter.
Sincerely, NUCLEAR FUEL SERVICES, INC.
f e
Andrew M. Maxin
-Acting Vice President Safety and Regulatory Management MLW/tkl ec:
. Mr. Stewart Ebneter Mr. Stephen P. Burris.
Regional Administrator.
NRC Resident Inspector U. S. Nuclear Regulatory Commission Region II 101 Marietta Street. NW. suite 2900
.rh.Ifl t/
Atlanta. GA 30323
'9307210114 93o702 F
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a ENCLOSURE to Letter Dated June 30,1993 A. M. Maxin to C. E. MacDonald
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NFS Response to NRC Comments RE: 400-A dated June 30.1993 Page 2 of 14 Contents NTC Comment Section 1.2.4, " Contents of Packaging", states that the marimum radioactisity present in a package is 45 mci. The table ofmaximum radioactivity shows 42.7 mCiper package. Correct this discrepancy. Provide calculations which show that the radioactisity listed in Section 1.2.4 '
meets the requirements oflow specipe activity, as defined in 10 CFR 671.4 NFS Response Sections 1.1 and 1.2.4 have been modified to reflect the amount of radioactivity not to exceed 38.4 mci.
Sections 1.2.1,1.2.4,4.6 and Figure 1 have also been modified to reflect a 333 pound gross weight. The method and formula for determining Low Specific Activity concentrations are described in Section 1.2.4; the formula is repeated below:
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, [Ay, + A.,,
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< g nCi na 399 m,,
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- WHERE, Agg, = activity assigned to each radionuclide in (nC]
m_ = mass of waste in (g) i RN A, Value (mCD 1
2"U 100 2
2"U 100 3
2"U 200 4
2"U 100 (assigned) 5 2"Pu 3
)
6 2*Pu 2
7
- Pu 2
'8
"' Am 8
9
"'Pu 3
10
"'Pu 100 1
-ENCLOSURE
NFS Response to NRC Commento RE: 400-A dated June 30,1993 Page 3 of 14 Structural NRC Comment 1.
The packaging description states that the closure uses a black neoprene 0-ring gasket. Rcrise Drawing No. 000-M0075-B to show that the gasket is a 3/8-inch 0-ring made ofsmooth black neoprene.
NFS Resqqrge Sections 1.2.1,4.6, and Drawing No. 000'M0075-B (Figure 1) have been revised to indicate that the gasket utilized is 3/8-inch half-round tubular, smooth, black neoprene.
NRC Comment 2.
Three diferent types of closure were testedfor the package. Rnfy that the drum that passed the normal condition tests is identical to the drum shown on Drawing No. 00&M0075-B. Provide records amiphotogre.phs which show the damage and condition of the packagefollowing the tests.
NFS Response Drawing No. 000-M0075-B (Figure 1) depicts the 40-gallon drum and with a bolt-closure locking device. This is the drum that was used in the tests.- Field photographs, as supplied by the testing laboratory, are included for your review to demonstrate that no significant damage occurred to the containers.
NRC Comment 3.
The contents of the test packages were non-radiocctivs material. Provide the basis for the conclusion that there is no sigmjicant increase v radiation levels or substantial reduction in the efectiveness of the test specimens.
NFS Response The radioactive contents of the final package consist of dry, solid waste material of low specific activity, generated during decommissioning. Waste material may consist of compacted metal bales, bottles of non-respirable material and non-compactable building material. Items are wrapped and heat-sealed in polyethylene and PVC. The primary source of radiation from these items are alpha emitters from plutonium in the form of surface contamination. The container is not designed to provide shielding, only containment of contamination. As the heaviest and ENCLOSURE
NFS Response to NRC Commento RE: 40G-A dated June 30.1993 i
Page 4 of 14 potentially most damaging waste matrix, metal bales were chosen for packaging into the test drums. Structural integrity of the drums remained intact following drop testing, as evidenced by no breach of containment or dispersion of sand from the drums.
I NRC Comment 4.
The mid spaces in the test packages werefiled with sand, which could provide a cushioning efect. Show that the test packages adequately and conservatively represent the actualpackage.
NFS Response The test drums were packaged by placing non-radioactive metal matrix bales, oriented on their edges, into the 40-gallon drum. The bales, wrapped in three layers of plastic, filled the 18.25 inch diameter. Sand was placed in the voids on the sides of the bales as an indicator of containment breach. The orientation of bales in the drum presented the most severe potential for damage to the containment during the drop test.
An additional drop test was conducted without sand to verify that there was no cushioning effect. The bales were oriented parallel to impact surface to provide the most severe potential for damage. There was no indication of loss of containment of radioactive material.
NRC Comment 5.
Specify the weight of the test packages. Note that the weight of the test packages should be greater than or equal to the maximum uright of a loaded package.
NFS Response The initial test packages were 442 and 502 pounds which are greater than the maximum allowable weight for a loaded package.
The test packages without sand weighed 340 and 351 pounds, which are greater than maximum allowable weight for a loaded package.
NRC Comment 6.
Drawing No. 000-M0075-B specifies a maximum package weight of 282 pounds;
- however, Section 4.6 of the application specifies a maximum package weight of 333 pounds. Correct this discirpancy.
ENCLOSURE
NFS Risponse to NRC Comments RE: 400-A dated June 30.1903 Page $ of,'4 NFS Response The weight specifications in drawing No. 000-M0075-B (Figure 1) were in error.
The drawing cnd all applicable sections have been modified to reflect a total gross weight (drum and contents) not to exceed 333 pounds. This upper limit is required for compliance with packaging criteria and content weight specified in drum model no.110G-A (Certificate of Compliance No. 9247).
Containment NRC Comment 1.
The two drums initially testedfor increased and decreased external pressure
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conditionsfailed the tests. Jusufy the conclusion that the package is capable f withstanding the test conditions, when only one of three drums tested passed the tests. Describe the tests, inspections, and detenninations that will be made prior to each shipment to ensure that the package is properly sealed, such that the package can withstand the increased and decreased externalpressure conditions.
NFS Response As discussed in Section 2.6.6, the first test conducted was with a 40-gallon drum and a lever-lock closure ring. This closure would not allow the gasket to seat' adequately for reduced / increased pressure tests. The vendor was requested to provide a bolt-closure locking ring for a 40-gallon drum. The vendor-supplied a bolt-closure locking ring for a 43-gallon drum (standard inventory drum from vendor). This device was too large in diameter to allow proper seating of gasket.
A third test was conducted with the proper bolt-closure locking ring for the 40-gallon drum, as depicted in Drawing No. 000-M0075-B (Figure 1), which will be used for final packaging.
Section 1.2.3 states that only new drums and gaskets are to be used. Inspections are conducted to assure that gaskets and sealing surfaces are smooth, clean and free of particulates which might inhibit containment of differential pressure. The section further states that the closure ring is tightened to 40 4 ft-lbs while tapping the ring with a rubber mallet to ensure the gasket seats completely on the drum.
NRC Comment
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2.
Describe in detail any damage that was caused to the containment system of the package by thefree drop test. Include photographs which show that the containment system of the package remained sealedfollowing thefree drop tests.
ENCLOSURE
a NFS Response to NRC Comments j
RE: 40G-A dated June 30,1993 Page 6 of 14 NFS Response The test drums were dropped from a four foot height at a 45* angle onto the locking ring and nut and onto the cylindrical side of the container. In both cases, the drops created inward dents on the container; however, there were no loss of contents detected or breach of containment. Field photographs supplied by the testing laboratory are included for your review to demonstrate that no significant damage occurred to the package.
NRC Comment 3.
Filling the void spaces in the drum with sand during the drop tests could provide a cushioning efectfor the waste materials within the drum. Show that the compacted materials and any non-compacted materials to be shipped would not pierce the thin (20 gage) metal drum body under thefcmr-foot drop test conditions.
NFS Response The test drums were packaged by placing non-radioactive metal matrix bales, oriented on their edges, into the 40-gallon drum. The bales, wrapped in three layers of plastic, filled the 18.25 inch diameter. Sand was placed in the voids on the sides of the bales as an indicator of containment breach during the drop test.
The orientation of bales in the drum presented the most severe potential for damage to the containment during the drop test.
An additional drop test was conducted without sand to verify that there was no cushioning effect. Bales were prepared by peening over any sharp points and triple-wrapped with plastic according to normal operating procedures. The bales were oriented parallel to impact surface to provide the most severe potential for damage.
There was no indication of loss of containment of radioactive material.
Operating Procedures NRC Comment 1.
Revise the operating procedures to specify the steps that will be taken to assure that i
the activity in the package does not exceed the LSA limit (see step 4.8.3, Section 4.8 of the application). Also, discuss how the contents will be repackaged If the activity.
exceeds the LSA limit.
i NFS Response Section 4.8 has been modified to include the operational steps required prior to packaging containers to verify LSA contents. Packaging configurations are modeled on computer before physical loading of waste is conducted. Algorithrns in the ENCLOSURE
l NFS Response to NRC Comments j
RE: 400-A dated June 30.1993 Page 7 of 14 software calculate waste parameters (LSA, weight, activity, heat of decay, etc.)
during modeling and flag the operator when limits are exceeded. Material is not packaged until waste parameter verification is made and approved. Process control measures prevent loading of drums that exceed specified !imits. Software and documentation are subject to full quality assurance protocol and management review / approval.
2.
Revise the operating procedures to include the tests, inspections, and determinations that are made prior to each shipment to ensure that the package is properly sealed.
NFS Response The operating procedure includes requirements for drum receipt, pre-use and loading inspections which are conducted to ensure that gaskets and sealing surfaces are smooth, clean and free of particulates which might inhibit proper sealing. The procedure further states that the bolt closure ring is tightened to 40 4 ft-lbs while tapping the ring with a rubber mallet to ensure the gasket seats completely on the drum.
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ENCLOSURE
Page No. IS Test Repon No. 42488-01 NFS Response to NRC Comments RE: 40G-A dated June 30,1993 Pays 8 of 14 2:mmr --.
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NFS Response to NRC Comments RE: 400-A dated June 30,1993 Page 9 of 14 j
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NFS Response to NRC Comments RE: 400-A dated June 30,1993 Page 10 of 14 i
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NFS Response to NRC Comments RE: 400-A dated June 30,1993 l
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Post-Drop Test 40-4P
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ENCLOSURE 4
NFS Response to NRC Comments l
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Page No. 7 l
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ENCLOSURE
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NFS Response to NRC Comments RE: 40G-A dated June 30,1993 Page 14 of 14 Page No. 8 Test Report No. 43396-01, 1
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ENCLOSURE I
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