ML20138G156
| ML20138G156 | |
| Person / Time | |
|---|---|
| Issue date: | 10/16/1996 |
| From: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Morrison D NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| FRN-62FR5907 AF58-2-011, AF58-2-11, AF58-2-13, AF58-2-8, NUDOCS 9610180260 | |
| Download: ML20138G156 (13) | |
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UNITED STATES y
S NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 20066 4 001
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October 16, 1996 1
MEMORANDUM T0:
David L. Morrison, Director t
Office of Nuclear Reactor Research FROM:
Carl J. Paperiello, Director 3
(
j Office of Nuclear Material Safety h'
I and Safeguards
SUBJECT:
RULEMAKING TO AMEND 10 CFR PART 71 -
FISSILE MATERIAL EXEMPTIONS, GENERAL LICENSES TO SHIP FISSILE MATERIAL The purpose of this memorandum is to request development of a rulemaking plan to initiate rulemaking on an expedited basis to amend the fissile material exemptions in 10 CFR 571.53, and the general license provisions for shipping fissile material in 10 CFR 5571.18 and 71.22. The amendments are needed to address a potential safety problem identified by an NRC licensee in using one of the fissile material exemptions in 10 CFR 571.53.
Expedited action is required because the general licenses and exemptions allow any licensee to
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make shipments without first seeking a specific NRC approval.
1 An NRC licensee recently informed staff of a case where one of the' fissile material exemptions in 10 CFR 5 71.53 would not provide adequate safety when transporting an exempt quantity of fissile material in the presence of a special moderating material (i.e., beryllium).
NRC staff has reviewed and verified the licensee's calculations, and has concluded that the fissile material exemptions and general licenses in Part 71 need to be amended to 4
address the possible inclusion of beryllium and other special moderating materials (such as deuterium and graphite) in the shipment of fissile materials.
J A related problem, the lack of any control on the total number of fissile exempt packages in a shipment or conveyance, was identified during the recently completed revision process for development of the 1996 Edition of the International Atomic Energy Agency's (IAEA's) Regulations for Safe Transport of Radioactive Material (Safety Series No. 6).
This problem was addressed in Safety Series No. 6 by adopting a consignment limit on the amount of fissile exempt material that a shipper could ship as a private carrier or deliver to a common carrier for shipment. Directly limiting the total number of fissile exempt packages in a shipment is not readily enforceable, absent a requirement [)
1 for a transport index for each package, or for shipment by exclusive use. The latter would restrict the ability to use common carriers, while requiring a
Contact:
E. Easton, NMSS (301) 415-8520
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NRC IRE CENTER COPY 9610180260 961016 PDR ORO NOMA i
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D. Morrison 2
transport index would negate much of the advantage gained by the exemption.
Consignment limits represent a practical operating limit that would make the unwanted accumulation of fissile exempt materials on common carriers i
improbable.
Rulemaking that restricts special moderating materials and that includes consignment limits would address the safety concerns identified with the fissile material exemption provisions of 6 71.53 and the general license provisions of f 71.18 and S 71.?2. A draft revision of the fissile exemption provisions of 6 71.53 and the general license provisions of s 71.18 and 5 71.22 has been attached.
Efforts have been made to limit the proposed changes to those that specifically address the identified safety concerns.
I We understand OGC is looking into whether an immediate effective NRC rulemaking is legally feasible in this instance.
l Since similar concerns exist with U.S. Department of Transportation (D0T) fissile material regulations (49 CFR Part 173), the proposed revisions should to be coordinated with 00T.
Attachments:
1.
Draft 10 CFR 71.18 2.
Draft 10 CFR 71.22 1
3.
Draft 10 CFR 71.53 Distribution:
PUBLIC i
NRC F/C SFP0 r/f NMSS r/f Proofed: DHiggs on 10/4/96 Document Name:
S:\\PROJ\\USERI.103
- Please see previous concurrence.
OFC
- SFP0
- SFP0
- SFP0
- 0GC NW NM NO
[Mbp CPaNe'llo NAME EEaston/lg SShankman WTravers WReamer DATE 10/1/96 10/1/96 10/1/96 10/3/96 10//f/96 10/@/96 C o COVER E = COVER & ENCLOSURE N = NO COPY
{ 71.18 Generallicense: Fissile material, limited quantity per package.
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(a) A general licen: is issued to any licensee of the Commission to transport fissile material, or to deliver fissile material to a carrier for transport, without complying with the package standards of Subparts E and F of this part if the material is shipped in accordance with this section.
(b) The general license applies only to a licensee who has a quality assurance program approved by the Commission as satisfying the provisions of Subpart H of this part.
(c) Except as provided in paragraph (d), this general license applies only when a package contains no more than a Type A quantity of radioactive material, including only one of the following:
(1) Up to 40 g of uranium-235; (2) Up to 30 g ofuranium-233; (3) Up to 25 g of the fissile radionuclides of plutonium, except that for encapsulated plutonium-beryllium neutron sources in special form, an A quantity of plutonium may be present; i
or (4) A combination of fissile radionuclides in which the sum of the ratios of the amount of l
each radionuclide to the corresponding maximum amounts in paragraphs (c)(1), (2), and (3) of j
this section does not exceed unity.
4 (d) For packages where fissile material is mixed with substances having an average hydrogen density greater than water, this general license applies only when a package contains no more t' n a Type A quantity of radioactive material, including only one of the following:
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(1) Up to 29 g of uranium-235;
.o (2) Up to 18 g ofuranium-233; 4
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(3) Up to 18 g of fissile radionuclides of plutonium, or 1
(4) A combination of fissile radionuclides in which the sum of the ratios of the amount of j
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each radionuclide to the corresponding maximum amounts in paragraphs (d)(1), (2), and (3) of this section does not exceed unity.
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(e) Except for the beryllium contained within the special form plutonium-beryllium sources j authorized in paragraph (c), this general license applies only when beryllium, graphite or (v
hydrogenous material enriched in deuterium is not present in quantities exceeding 0.1% of the fissile material mass.
(f) (1) Except as specified in paragraph (f)(2) for encapsulated plutonium-beryllium sources,
'[this general license applies only when, a package is it,beled with a transport j
," y number given by the following equation, where the package contains x grams of uranium-235, y
' j grams of uranium-233, and z grams of the fissile radionuclides of plutonium:
Minimum Transport Index = (0.25x + 0.33y + 0.4z).
(2) For a package in which the only fissile material is in ths form of encapsulated plutonium.
(
4 NITACHMENT 1
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,, beryllium neutron sources in special form, the transport index based on criticality considerations may be taken as 0.025 times the number of grams of the fissile radionuclides of plutonium.
(3) Packages which have a transport index greater than 10 are not authorized under the general license provisions of this part.
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l i 71.22 Generallicense: Fissile material, limited quantity, controlled shipment.
(a) A generallicense is issued to any licensee of the Commission to transport fissile material, or to deliver fissile material to a carrier for transport, without complying with the package standards of Subparts E and F of this part iflimited material is shipped in accordance with this section.
(b) The general license applies only to a licensee who has a quality assurance program approved by the Commission as satisfying the provisions of Subpart H of this part.
(c) This generallicense applies only when a package contains no more than a Type A i
quantity of radioactive material and no more than 400 g total of the fissile radionuclides of plutonium encapsulated as plutonium-beryllium neutron sources in special form.
(d) This generallicense applies only when:
(i) the mass of fissile radionuclides in the shipment is limited such that the i
grams of umnium-235, grams of other fissile maten'al, 3 X
Y r
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where X and Y are the mass limits defined in Table V; or (ii) for encapsulated plutonium-beryllium neutron sources in special form, the total mass of the fissile radionuclides of plutonium in a shipment does not exceed 2500 g.
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,h~ Table VI./
PERMISSIBLE MASS LIMITS FOR SHIPMENTS OF FISSILE MATERIAL, d
APPLICABLE TO $71.22 i
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- s Fissile material mass (g) /
Fissile material mass (g)
N Fissile material mixed with substances mixed with substances having a hydrogen density having a hydrogen density
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less than or equal to water greater than water Uranium-235(X) 500 290 q
Other fissile material (Y) 300 180
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I (e)
Except for the beryllium contained within the special form plutonium-beryllium
) sources authorized in paragraphs (c) and (d), this general license applies only when beryllium, I
A'ITAC19fENT 2
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graphite or hydrogenous material enriched in deuterium is not present in quantities exceeding 0.1% of the fissile material mass.
(f)
This general license applies only when shipment of these packages is made under procedures specifically authorized by DOT in accordance with 49 CFR Part 173 ofits regulations to prevent loading, transport, or storage of these packages with other fissile material shipments.
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4 g 71.53 Fissile materist exemptions.
Fissile materials meeting the requirements of one of the paragraphs in (a) through (d) of this section are exempt from fissile material classification and from the fissile material package standards of $ 71.55 and i 71.59, but are subject to all other requirements of this part. These exemptions apply only when beryllium, graphite, or hydrogenous material enriched in deuterium is not present in quantities exceedin
.1 percent of the fissile material mass.
(a)
Fissile material such that the
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3 grams of uranium-235 grams of other fissile maten'al, 3 X
Y 4
for an individual consignment, where X and Y are the mass limits defined in Table V, j
provided that, (i) each package contains no more than 15 g of fissile material. For unpackaged material the mass limit of 15 g applies to the conveyance; or e
(ii) the fissile material consists of a homogeneous hydrogenous solution or mixture where the minimum ratio of hydrogen atoms to fissile radionuclide atoms (H/X) is 5200 and the maximum concentration of fissile radionuclides within a package is 5 g/ liter; or
"(iii) there is no more than Sg of fissile material in any 10 liter volume of material and the material is packaged so as to maintain this concentration during normal transport.
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Table V.
CONSIGNMENT MASS LIMITS FOR EXEMPTIONS FROM THE t
REQUIREMENTS FOR PACKAGES CONTAINING FISSILE MATERIAL i
Fissile material mass (g)
Fissile material mass (g) mixed with substances mixed with substances j
Fissile material having an average hydrogen having an average
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density less than or equal to hydrogen density greater water than water i
Uranium-235(X) 400 290 I
Other fissile material (Y) 250 180 f
(b)
Uranium enriched in uranium-235 to a maximum of1 percent by weight, and with a total ATTAQ9ENT 3
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4 plutonium and uranium-233 content of up to 1 percent of the mass of uranium-235, provided that the fissile material is distributed homogeneously throughout the package contents and does not form a lattice arrangement within the package.
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'(c )
Liquid solutions of uranyl nitrate enriched in uranium-235 to a maximum of ercent by weight, with a total plutonium and uranium-233 content not exceeding ercent of the mass of uranium,7and with a minimum nitrogen to uranium atomic ratio (N/U) of 2.
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(d)
Plutonium, less than 1 kg, of which not more than 20 percent by mass may consist of plutonium-239, plutonium-241, or any combination of these radionuclides.
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BCbCOck & WilCOX Naval Nuclear
- c a mo==es -, ear Fuel Division To I
F. M. Alcorn, Manager, Nuclear Cdticality Safety 1
Frern l
File No.
R. J. Green, Nuclear Safety Engineer, FT&T Systems Engineering or Ref. RJG 96-01 subj.
Nuclear Cnticality Safety Concerns Related to DOT Requirements in Shipping U-BeO Wastes Date -
September 12,
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1996 l
cc:
R. J. Spickard R. S. Evans R. R. Jensen JeffMaloney This memo is to document safety concerns with shipping U-BeO wastes in accordance with j
requirements, specifically with the use of the I A2 shipping container and with shipping w accordance to the fissile exception in 49 CFR part 173.453 section (E).
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Background
f As you know, B&W was recently awarded a contract to process U-Be material and therefore will
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generate U-Be wastes. Prior to processing this material, a general NCS evaluation was performe to characterize critical parameters for U-Be, U-water, and U-Be-water systems. The results i
generally show that if some sort of geometric comrol is in place, U-water is more reactive than U-i Be and U-Be-water mixtures (see LLW95-17). However, for large geometry system with low i
uranium concentrations U-Be is dramatically more reactive than U water. For example, in an infinite system, the mimmum critical U-235 concentration for uranium and full density wate approximately 11.7 g U-235/1 verses 0.58 g U-235/1 concentration for uranium snd full den j
beryllium. The minimum critical concentration was later shown to decrease sieniAc*atly mo with lower beryllive oxide densities.
j B&W's U Be Processing U Be material is dissolved and sube*fy prae *W through solvent extraction. The rnWinstes generated fkom solvent extraction will cantain (pdmarily) beryllium, U-235, water, nitrates and small quantities of. fluorides. The rafHnates will be transferred to beryllium clean-up pr discharged to waste water treatment. Beryllium clean-up operations begin with the pr of the rafEnate using sodium hydroxide. The slurry is then pumped through a filter press the precipitate solids. The fiher cake is then transferred to 55-gallon drums for analysis and storage. The fiher cake is primarily made up of water, beryllium hydroxide, and uranium. The maximum U-235 concentration is expected to be 0.5 g U-235/1.
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3 Aealysis L aal-lens and K.e calculations on inanite slabs were performed using SCALE-PC. All calculations assumed a 0.5 g U-235/l concentration with various Be and BeO d l
was included in say calculations, which is conservative. K. was less than 1.0 for Be greater than 1.0 for BeO. A reduction in the density ofBeO resulted in higher L values example, half the theoretical density resulted in a L of 1.6 compared to 1.2 for full i
the system is over moderated, K. will continue to increase with a density decrea j
moderation is reached. If the water in our U-BeO waste container is removed in drying through evaporation, the BeO density is estimated to be between 10 and 20 percent of theoretical value. The minimum critical concentradon of an infinite system with
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10% theoretical is approximately 0.032 g U-2354.
K effective calculations were based on a 200 cm high infinite slab with no reflection in the
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directions. Using a 0.5 g U 235/1 value, K-affwas 1.06 for theoretically dense BeO an
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half of thetheoreticalvalue.
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Results l
Based on these calculation, and assuming the waste containers contain no water, waste in accordance with the fissile exceptions stated previously (less than 0.5 g U-23 i
not be safe. Per DOT requiramante, this material may be shipped in large ses/ land containe j
exceed safe mass, concentration and geometry limits for U-BeO mixtures. Also, followin i
shipping requirements of the I A2 container win snow up to seventy two 55-ganon dmms o
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uranium bearing material containing 350 g U-235, with no restriction on beryllium.
i ADDITIONALINFORMATION i
A single SEA / LAND contamer was also modeled using SCALE-PC. The container was fbil 100% enriched uranium at a concentration of o.5 g U-235/ liter and beryllium oxide at severa i
densities. The results, along with an ov esck of the calculations, are attached in MVM96 i
should be noted that all these cases meet the fissile exceptions in 49CFR. Also =maha l
(2) input files.
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_.;g.;,,,.. g,;..; g g,,g, y,,, j,;, -
--- g g g,, ;, g -;,;,; - - - --
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<SAS25 BE-OXIDE & U-235 SEA / LAND CONTAINER (8' BY 8' BY 20'), B ARE 27GROUPNDF4INFHOMMEDIUM 2
i U-235101.281E-6 END BE 10 0.0725 END
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010 0.0725 END END COMP GUL=0.5 READ PARA GEN =100 END PARA j
READ GEOMETRY CUBOID 1 12P121.92 2P304.8 2P121.92 END GEOMETRY END DATA i
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=CSAS25 1/2 DENSITY BE-OXIDE & U-235 SEA / LAND CONTAINER, FULL R 27GROUPNDF4INFHOMMEDIUM U-235101.281E-6 END BE 10 0.03625 END O 10 0.03625 END ORCONCRETE 21 END END COMP GUL=0.5 READ PARA GEN =100 END PARA l
READ GEOMETRY CUBOID 112P121.92 2P304.8 2P121.92 REPLICATE 216*30.481 i
END GEOMETRY END DATA O
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- s Babcock & Wilcox Naval Nuclear Fuel Division To l
I F. M. Almm, Manager, Nuclear Criticality Safety, X5157 Fmm FM i
File No.
M. V. Mitchell, Engineer, Nuclear Criticality Safety, X5195 orRef. MVM96 34 i
subj.
" Double check" of calculations relied upon in RJG96 01 Date I
September 11,1996 I have been asked to " reproduce" the results of calculations used in RJG96 I
of a SEA / LAND container (8' X 8' X 20'), with and without 12 inches of Oa reflection. The material contained had a U-235 density of 0.5 g/cc and the Be internal containment. The physical walls of the S l
For an additional data point, I modeled the same material loaded into 5 placed into the SEA / LAND container. Taking the dimensions of the 55 ga i
5 X 11 X 2 square pitched array was modeled with and without 12 inches of O reflection.
The physical wa!!s of the SEA / LAND container and the 55 gallon drums we j
explicitly modeled.
4 Ron's Mine Descripdos LD.
keKie LD.
ken e Rho (BeO)= 3.Oli g/cc, BE10.IN 1.01909 i 0.00303 MVMBE001 1.01363 0.00192~
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Bare j
Rho (BeO) = 3.011 g/ce,12 "
bel 1.IN 1.02372 0.00285 MVMBE002 1.03062 0.00182
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Concrete Reflection
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Rho (BeO) = 2.258 g/cc, BE12.IN 1.06942 0.00337 MVMBEOO3 1.06274 0.00238 i
Bare Rho (h0) = 2.258 g/cc,12 "
BE13.IN 1.08623 0.00337 MVMBEOO4 1.08567 t 0.00227 j
ConcreteReflection Rho (BeO) = 1.506 g/cc, BE14.IN 1.03535 1 0.00371 MVMBEOO5 1.03505 0.00248 l
Bare I
Rho (BeO)= 1.506 /ce,12 "
BEI5.IN 1.09929 0.00351 MVMBEOO6 1.09689 0.00247 3
i ConcreteReflecticer 5 X 11 X 2 Array of 55 N/A N/A MVMBEOO7 0.65900 2 0.00177 i
Gallon Druma, Rho (BeO)=
l 3.011 g/ce, Bare 5 X 11 X 2 Array of 55 N/A N/A MVMBEOO8 0.74848 0.00194 i
Gallon Drums, Rho (BeO) =
l 3.011 g/cc,12 " Concrete i
Reflection 1
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Babcock &Wilcox
- n..isoci..,ro.i oivi. ion s\\
a McDermott company P. o. Box 785 Lynchburg, Virginia 24505-0785 (804) 522-6000 September 20,1996 96-093 Mr. W. D. Travers, Director Spent Fuel Project Office, NMSS U.S. Nuclear Regulatory Commission Mail Stop 6 F-18 Washington, DC 20555-0001 Gentlemen:
Babcock & Wilcox, Naval Nuclear Fuel Division, (B&W) notified NRC by telephone on 4
September 11,1996 of a potential problem that could exist when shipping radioactive materials containing uranium and beryllium (U-Be). Based upon calculations performed by B&W, shipping certain U-Be material in accordance with DOT regulations without any other control of physical configuration or total quantity per shipment could be unsafe.
In accordance with telephone discussions with your staff on September 18,1996, B&W will not ship U-Be materials without prior authorization of the NRC.
If you have any questions or require additionalinformation, please contact us.
Sincerely, J. A. Eanes, Manager Safe'ty & Safeguards cc:
U.S. Nuclear Regulatory Commission Region II NRC Resident Inspector Q G " 30 9 'N' I,f