ML20138J754

Forwards Revs to Application for License for Dhtf Shipping Container for Transporting Enriched U Dioxide & Answers to NRC Questions

ML20138J754
Person / Time
Site:	07109203
Issue date:	11/26/1985
From:	Watters J BABCOCK & WILCOX CO.
To:	Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
26101, NUDOCS 8512170640
Download: ML20138J754 (12)

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RETU.TW IO. 396-SS RO/t e ",

Babcock & Wilcox E."$",MEL.,,,

/'l a McDermott company P.O. Box 11646

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i Lynchburg, VA 24506-1646 a

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(804) 522-6000

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( November 26, 1985 O

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Mr..C.

E. MacDonald, Chief

'RECENEQ Transportation Branch NOV2 7 085 g

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Division of Fuel Cycle and Mater)hl-Safety United States Nuclear Regulaf.ogy,C4mr%ssion Washington, D. C.

20555 was ys s

y ga sate

References:

(1)

SNM-1168, Docket 704 201 N

(2)

Letter t'o C.

E'. MacDonald from J. P.'Wa E'ers,3 dated 9 30-85 (3)

Letter to 7. E. Mac'DoRald from J.

P. Watters, dated 10-2345

-.ys Gentlemen:

The Babcock & Wilcox Co#1pany, Commercial Nuclear Fuel Plant has submitted an application _iPeferences 2 and 3) to your staff

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y requesting a specific license for the DHTF shipping contalher for transporting enriched uranium' dioxide.s The'purpdee-of this letter is to incorporate various revisions to the submittal x

resulting from questions flom membero of your staffy u

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O These questions were discussed by myself and Mr. R. H.

1 Odegaarden of your staff on 11/25/85.

Attachment I, lists 'each question'followed by a brief description of B&W's response.:

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Attachment II contains revised pages to the DHTF submittal which address the questions of your staff.

Please incorporate all of the pages in Attachmenf II into the original 9-30-85 application as supplemented by the 10-23-85 letter.

We appreciate your consideration in this matter.

If yo'u need additional information, please contact me at (804) 522-6202.

Gincerely, N

BABCOCK & WILCOX COMPANY s

p c1 COMMERCIAL NUCLEAR FUEI PLANT UWRC 7"

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J.P. Watters 9

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ATTACHMENT I The questions as presented to me by Mr. R. H. Odegaarden are listed here, followed by the B&W response (denoted by an asterisk

'*').

The degsity of the fiberboard should be specified at 16.5 1.

3 lbs/ft

+ 2 lbs/ft

• Drawing #MS-215E was revised to accommodate the density specification (NOTE 5 on the drawing).

Also, Page 1-2 was revised accordingly to reflect the density specification.

2.

Specify the weight of the contents at 270 lbs. and the maximum gross weight at 480 lbs. -

• Pages 1-2 and 2-9 were revised to indicate that the maximum gross weight is 480 lbs. and the maximum weight of the

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contents at 270 lbs.

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3.

Items 5-4, 8, and 9 on Drawing MS-215E should include a material specification.

4

• The Bill of Materials on MS-215E was revised to include a material specification for the hardware included in Items 5-4, 8 and 9.

4.

Operating Procedures, Page 7-1 (Section 7.2.4) should specify 4

that the Package ID # will be included on the container markings.

1

• Page 7-1 (Section 7.2.4) was revised accordingly.

l 5.

Operating. Procedures, Page 7-2 (Section 7.2.5) - The radiation level at contact should be 200 mrem /hr.

• Page 7-2 (Section 7.2.5) was revised accordingly, i

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ATTACHMENT.I (cont'd) 6.

The Operating Procedures (Section 7) should have a statement saying that the CNFP is in compliance with 10 CFR 20.205,

" Procedures for Picking Up, Receiving, and Opening Packages".

• Page 7-1 (Section 7.1) was revised to include the above statement.

7.

The Maintenance Procedures (Section 8) should have a replacement schedule for the inner container gasket.

• Pages 8-1 and 8-2 (Section 8.3) were revised to indicate the methodology concerning inner container gasket replacement.

The gasket will be replaced when inspection i

shows any defects or every twelve (12) months, whichever comes first.

(~s 8.

The DHTF application should specify a method and schedule for checking of moisture content in the fiberboard to preclude 2

excessive moisture buildup.

• Page 8-2 (Section 8.3) was revised to include an annual tare weight verification program which will indicate possible weight increase due to moisture absorption.

9.

The vent holes in the DHTF should be made larger to 3/8" diameter to release pressure buildup quicker.

• Drawing PE-215E was revised to indicate that the 4 vent holes will be 3/8" in diameter.-

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sufficient mechanical strength and thermal resistance to protect the contents from damage during normal and hypothetical accident conditions of transport.

Specification ASTM-C-208-72 sets forth requirements for several types of cellulosic insulating board; the DHTF uses filler material of the category " Roof Insulating Board, Construction Grade".

The stainless steel inner container uses a carbon steel plate closure lid (3/8" thick) which is secured by eiggt3/8-16NCbolts.

A 1/8" rubber gasket with a 500 F thermal rating is used between the inner container lid and body.

The inner container is 9.5" x 9.5" x 17.5" in size and is centered within the DOT 17C outer drum.

More details can be found on Babcock & Wilcox Drawing No.

MS-215E.

The. maximum gross weight of the DHTF will be 480 pounds when loaded with four cardboard boxes of uranium dioxide

• pellets; Table 1.1 provides details.

Actual gro's weight s

will vary from this for two reasons.

First, density of the fiberboard filler material will vary.

The fibergoard density wi}l be controlled to a value of 16.5 lbs/ft

+ 2 lbs/ft Second, the DHTF may carry fewer than four cardboard boxes of pellets.

O 1.2.2. Operational Features b

Operation of the DHTF container is typical of 55 gallon drums.

The cylindrical drum is sealed with a 16-gauge top lid secured by a 12-gauge closure ring with a S/8" bolt and nut through drop forged closure ring lugs.

Loading of the DHTF is accomplished by placing the loaded pellet boxes and stainless steel centerboard inside a nylon' strap as shown on B&W Drawing MS-215E.

This entire payload can then be lowered into the DHTF inner container.

Unloading of the container is accomplished in reverse fashion.

1.2.3 contents of Package The DHTF will carry a payload of up to four cardboard r

boxes of UO pellets.

Pellets are packed in one of two 3

methods, either neatly stacked on corrugated stainless steel trays, or randomly placed into a polyethylene bag within the cardboard box.. If pellets are packed on 1

corrugated trays, the DHTF is limited to a total payload i

of 100 kgs U (approximately 113.5 kgs UO ) for nuclear 3

' safety purposes.

No nuclear saftty limit exists if pellets are bagged, but physical dimensions of the inner O,

container limit the payload to a similar quantity of i

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of the container.

This was the last of the Nomal Conditions tests; the prototype container had already been subjected to the water spray, free drops, and compression tests. The 13 3/4 pound cylinder was dropped on the lid, on the bottom, and on the side of the drum.

It did not penetrate the outer skin, and the maximum local depression was.23 inches (on side of drum).

All damage was within the limits assumed in the criticality analysis. The damage from the penetration test is shown in Photos 28-1 and 28-2, 2.0.9 Sunrnary of Damage After completion of the structural testing program, the prototype container (#D01) was subjected to a comprehensive post-test inspection.

Dimensional checks verified that the inner container was not deformed and remained well within the limits imposed by the criticality analysis. Local deformations of the drum at the points of impact are not significant in terms of changes to the criticality analysis. After repeated drop. loads, some minor crushing of the fiberboard spacers was noted. These values translate into an insignificant shifting of inner container relative to the outer drum (less than a 5% change).

The criticality analysis bounds all postulated configurations.

2.7.

Hypothetical Accident Conditions - Drums D02 - D07 O

Evaluation of the DHTF package for the hypothetical accident conditions -

described in the regulations required.a series of tests performed in a given sequence.

Package performance was then assessed based oh the accumulated damage. An exception to this procedure is the 50-foot water imersion test where an undamaged container was used as required by 10 CFR71.73(c)(5).

Prototype containers used for the testing program were representative of the production containers as discussed in Section 2.4.1.

This includes material of construction, fabrication techniques and loading procedures.

The combined weight of the contents (four boxes and steel plate) for the prototype containers was 280 pounds.

For actual shipments, the maximum shipping weight will be 100 kgs uranium plus a steel plate for a combined weight of 270 pounds.

To ensure the testing program addressed all possible impact configurations where " maximum" damage was expected, a set of six containers were drop-tested. All the containers were subjected to a 30 foot drop in one of six orientations likely to cause maximum damage.

Figure 2.6 illustrates all six orientations used for the 30' drop tests including closure bolt location, inner container location, and overall drum attitude. Each container was then subjected to a series of four puncture tests (Figure 2.7).

By the end of these two mechanical tests, each of the six containers (D02 through D07) had experienced five drop / puncture tests.

Next, the entire set of six drums was placed in a

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furnace for the thermal test. A post-test examination was performed on 2-9

/D 7.

OPERATING PROCEDURES 7.1 General All operating procedures used for the DHTF shipping container are in compliance with Subpart D of 10 CFR 71 as described below.

All operating procedures for the DHTF are approved by CNFP Plant Management.

All appropriate areas of packaging, shipping, labeling, loading, and unloading are covered in the operating procedures as described below.

B&W will utilize the DHTF container in compliance with 10 CFR 20.205,

" Procedures for Picking Up, Receiving, and Opening Packages".

7.2 Procedures for Loading the DHTF 7.2.1 If shipping pellets on corrugated stainless steel trays, pellet boxes shall be loaded such that the following

. requirements are met:

o Maximum enrichment of 4.1% U-235 o

Maximum net weight of 28.0 kgs o

Maximum H:U ratio of 1.3

'o Labeled as to serial number, contents, net weight, and (J^)

enrichment 7.2.2'If shipping bagged UO, pellet boxes shall be loaded such that the followi$g requirements are met:

o Maximum enrichment of 4.1% U-235 o

Maximum of 150 gms of plastic Labeled as to serial number, contents, net weight, and o

enrichment 7.2.3 Each DHTF shipping container shall be inspected prior to each use to assure that the following requirements are met:

o No holes in the outer drum, nor dents greater than one-half inch deep o

Lid gasket not broken or deteriorated Inner container gasket replaced at any signs of o

visual degradation o

Inner container is closed with eight bolts o

Unbroken tamper seal o

Outer drum has at least two yellow radioactive labels that indicate contents, fissile class, number of curies, and transport index.

7.2.4 Each outer dram shall be inspected to assure it is marked as follows:

o Radioactiv3 material, Fissile Class II or III o

Package ID Number (USA /9203/AF, Type-A) 7-1

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c Model number (DHTF) o Serial number o

Gross weight not to exceed 480 lbs.

o Owner's name and address 7.2.5 Each DHTF package shall be surveyed prior to each use to assure:

Regovable surface contamination 1 2200 dpm per 100 o

cm o

Radiation levels 1 200 mrem per hour on contact Radiation levels 1 10 mrem per hour at 1 meter o

7.2.6 Each shipment involving the DHTF package shall have the following records retained for a minimum of two years:

o SNM content of each DHTF package, and of each pellet box within each DHTF o

Form NRC-741 for the shipment

.o Package inspection records showing conformanc.e to 7.1.3 above o

Contamination and radiation survey results o

Serial numbers of tamper seals applied to each DHTF 7.2.? Internal procedures shall be written and maintained to p

assure that the above steps are incorporated into the work sJ habits of workforce personnel.

7.3 Procedures for Unloading the DHTF-7.3.1 Prior to unloading, each shipment shall be checked to assure that it is accompanied by the following information:

o Form NRC-741 o

SNM content of each DHTF package, and of each pellet box within each DHTF o

Serial numbers of tamper seals applied to each DHTF 7.3.2 At least a sampling of the DHTF packages shall be surveyed prior to unloading to assure:

Removaglesurfacecontamination1-2200dpmper o

100 cm o

Radiation levels 1 200 mrem per hour on contact o

Radiation levels i 10 mrem per hour at 1 meter 7.3.3 Prior to opening any packages, tamper seals shall be checked to assure they are unbroken.

Serial numbers must agree with the shipper's records.

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7.3.4 The outer drums and inner containers may then be opened,

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l and pellet boxes unloaded.

Individual pellet boxes shall j

be weighed and/or sampled as necessary to establish a 7-2

O 8.

ACCEPTANCE TESTS AND MAINTENANCE PROGRAM 8.1 General All procedures for DHTF acceptance tests and maintenance are approved by CNFP Plant Management.

These procedures identify the routine inspection and maintenance requirements and acceptance criteria to be applied.

8.2 Acceptance Tests 8.2.1 Visual inspection shall be made of each DHTF package prior to initial use to assure the following requirements are met:

No holes in the outer drum, nor dents greater than

.o one-half inch deep o

Lid gasket not broken or deteriorated Lid lip and top drum curl are not damaged to the extent o

that the closure ring will not fit the outer drum

'o Outer drum has between one and four vent holes near the O

top (1/4-inch diameter) o Inner container is closed with eight 3/8-inch bolts "o

Fiberboard is loaded to the top of the outer drum 8.2.2 Components Drums shall be certified by the supplier as DOT 17C o

Fiberboard shall be checked to assure a minimum density o

of 14 pounds per cubic foot o

The inner container shall be measured to assure dimensions in accordance with the license drawing, and welds shall be inspected as required by the license drawing Inner container gaskets shall be certified by the o

supplier as silicone rubber, 40-60 durometer, 700 0

tensile, 225 elongation, 20 R compression, and 500 F 4

8.3 Maintenance Program The DHTF package is not a pressure vessel, employs no shielding materials, and does not require a cooling system or other thermal mechanism for dissipation of heat.

Materials of construction are commonplace, durable, and readily available.

The package contains no systems or subsystems such as valves, 1

rupture disks, or other moving.. components.

As such, the maintenance program for the DHTF consists of repair,

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refurbishment, or replacement as necessary.

Packages are visually inspected prior to each use, and deficiencies noted as recorded at that time.

Prior to each shipment, the insert 8-1

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(containment vessel) gasket shall be inspected.

This gasket shall be replaced if this inspection shows any defects or every twelve (12) months, whichever comes first. Packages with unacceptable conditions are sidelined until the package or component can be redressed.

For example, a shipping container with a torn inner gasket will not be used until a replacement gasket is procured; a DHTF whole outer drum with a hole or large dent will be removed from service until a replacement DOT 17C drum is obtained; etc.

Inspection prior to each use, and refurbishment prior to next use whenever deficiencies are noted, comprise the maintenance program for the DHTF shipping container.

The CNFP will utilize a tare weight verification program to check for moisture content buildup in the fiberboard.

Each DHTF container will have a unique tare weight associated with it.

At least annually, the tare weight of each. container will be checked to verify that there has not been a.significant weight gain'due to moisture content.

Any container showing a' significant weight gain

(+ 10 pounds) will be. visually inspected and all or part of the fiberboard packing material will be replaced if shown to be degraded by excess moisture.

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