ML20128H547

Responds to Ltr to F Mcgoldrick Re Executive Branch Study Required by Public Law 102-486

ML20128H547
Person / Time
Issue date:	01/15/1993
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Abercrombie N HOUSE OF REP.
References
CCS, NUDOCS 9302170076
Download: ML20128H547 (3)

Text

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January 15, 1993 The Honorable Neil Abercromt'ie, Member Committee on Natural Resources United States House of Representatives Washington, D.C.

20515

Dear Mr. Abercrombie:

I am responding to your letter to Mr. Fred McGoldrick of the U.S. Department of State regarding the Executive Branch study required by Public Law 102-486, in your letter you identifici a report, " Definition of Bounding Physical Tests Representative of Transport Accidents -- Air and Marine," prepared for the Nuclear Regulatory Commission in 1983 by the Illinois Institute of Technology's Research Institute (IITRI).

You requested that this report be reviewed prior to completion of the Executive Branch study.

The IITRI report has been reviewed in preparation of the Executive Branch study.

In 1979 the NRC was concerned with frequent public criticism tha.

regulatory test requirements and performance standards for packages containing large quantities of radioactive material were not realistically linked to possible severe accident conditions.

For example, survival of a 30-ft drop on an unyielding surface without incurring significant leakage did not appear to be a stringent collision standard.

The NRC initiated a multiphase effort (the Modal Study) to evaluate the extent to which regulatory tests and performance standards bounded high severity transportation accidents, and to evaluate the residual risk from any accidents-which may not be bounded.- The initial phase.

of this effort resulted in two studies:

(1) Severe Rail and Truck Accidents:

Toward a Definition of Boundina Environments for Transportation Packaaes, by Ridihalgh, Eggers and Associates (REA); and (2) Definition of Boundina Physical Tests Renresentative of Transoort Accidents - Air and Marine, by the

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Illinois Institute of Technology Research Institute (IITRI)..

1 IITRT su' mitted their final report to the NRC in'1983.

The IITRI report o

devesped a series of physical tests, based on an analysis of marine and air accident data for 1970-1979. These included a crush test, penetration test, slash test and immersion test for extremely severe' marine accident conditions, as well as a separate test sequence comprised of a fire test, hose stream test, and an immersion test. A separate deep submersion test was also-prophed. The tests specified by the IITRI study appear to'be more severe than the traditional tests recommended and adopted by IAEA member states.

However, the study did not develop post-test acceptance criteria. While the tests seem more severe, the level of safety afforded by the suggested tests -

was not evaluated, and could not be determined without corresponding-acceptance criteria.

In the area concerning shipboard fires, the IITRI study concluded that the current IAEA packaging requirement that packages withstand a 30-minute 1475 F fire wnuld be more than adequate for below-deck fires. This conclusion is particularly germ,ne to plutonium shipments, where the greatest risk is 300091 9302170076 930115 PDR ORG NE E 1

l The Honorable Neil Abercrombie

• from respirable particles, such as those that may be produced in fires.

The llTRI study based this conclusion on its analysis of a collision between a cor.tainer snip (the Sea Witch) and an oil tanker which occurred in New York Harbor in 19D, an accident which is characterized by the Coast Guard (according to the llTRI report) as a " worst-case" accident.

About the time the ilTRI report was submitted, a reconsideration of program strategy led to a redirection of the Modal Study. This redirection was based on program costs and tining, since at that time, large numbers of road and rail spent fuel shipments were being projected (e.g., shipments to a monitored retrievable storage facility), many of which were anticipated to be made in new package designs. As a result, neither the llTRI or the REA study wcs pursued beyond its initial effort to develop package qualification tests (e.g., no efforts were undertaken to establish post-accident acceptance criteria).

Because of the redirection, neither the IITRI or REA reports were subjected to normal peer review.

Instead, NRC redirected its effort towards determining the adequacy of protection provided by spent fuel packages (built to Type B standards) when subjected to historically severe highway and railway accident conditions. The resulting study (NUREG/CR-48?9) showed that spent fuel packages, which are designed to the same international standards used for plutonium packages, would perform their safety functions under severe accident conditions.

In our consulting role in the Executive Branch study, the staff reviewed the llTRI report as well as Department of Energy and NRC risk studies previously performed.

lhe staff concluded that due to the low probability of severe marine accidents (as acknowledged in the IITRI report) and the minimal risk posed by such accidents, the current IAEA packaga standards provide adequate public health and safety for plutonium shipments by sea.

We hope that this addresses your concerns.

We expect that the Executive Branch study will be issued shortly.

Sincerely,

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ecutive Director for Operations l

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usagneten,ac tests

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December 14, 1992 The Honorable yred McGoldrick

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Acting Deputy Assistant secretary

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Nuclear Energy and Energy Technology Affairs-Bureau of oceans and International Environmntal and Scientific Affaire United States Department of State Washington, D.C.-

20520 Dear Mr. McGoldrickt

' Definition of Bounding Physical Enclosed is a: copy of a report, Tests Representative of Transport Accidents -

Air and Marine,*

He believe the report that was recently brought to our attention.

is highly relevant to the Executive Branch study now:being carried out in consultation with the Nuclear Regulatory Commission (NRc):

pursuant to Public 1.sw 102-486.

This report, prepared for the NRC in 1943,-includes a detailed set of tests for determining whether easke. used for. transporting radioactive : materials by sesi could withstand estremely severe Unfortunately, although the report was completed under.

accidents.

contract for NRC's-office of Nuclear Regulatory Research by a teean at the Illinois Institute - of Technology's Research : Institute (IITRI), the tests proposed in the report have never been. pursued.

This report was part of the Nodal 8tudy, a: Project begun-by NRC:in 1978 to examine safety issues related to various modes of-1 i

transportatic,n'of radioactive materials.

team; has identified. both ? historical ~ and? hypothetical The IITRI scenarios;for. severe. air-and marine transport accidents involving o

thie < dats : to 1 develop t radioactive material containers: and. used:

scenaries-for

" extremely severe credible ' accidents :for-each shipping mode."

IITRI then developed 1 teste for radioactive; material casks that would-simulate the stresssa that:actually occur

. It

' appears that: the report-Lin such severe accidents.

satisfactorily < defined

a. maximum-creditie. accident. scenario-

. involvingJ plutonium trar. sport - based. upon h. : urvey of-maritime -

. accidents ' and r an : assessment :.of the most severe - conditions u The study further:designedc L

which - such accidents - have occurred..

appropriate. test procedures to replicate such conditions.-

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