ML20150E464

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Responds to 771230 & 780707 Request for Review of Model A1-M1 Package Designs.Model A1-M1 configuration-3 Is Not Acceptable.Addl Info Requested in Encl for configuration-1. Configuration-5 Is Different & Will Be Reviewed Separately
ML20150E464
Person / Time
Site: 07109507
Issue date: 12/08/1978
From: Macdonald C
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Mott W
ENERGY, DEPT. OF
References
NUDOCS 7812200024
Download: ML20150E464 (3)


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U.S. Department of Energy ATTN: Dr. William E. Mott Washington, DC 20545 Gentlemen:

This refers to your letter dated December 30, 1977, as supplemented July 7, 1978 requesting our review of the Model No. Al-M1 package designs, desig-nated as configurations-1, -3 and -5. Since the configuration-5 design and its contents is significantly different from the other two designs we are reviewing it separately (NRC Docket No. 71-9125).

We note that the Model No. Al-M1 configuration-3 design was subjected to actual tests to satisfy the hypothetical accident conditions of 10 CFR Part 71. Although the maximum temperature of the aluminum containment vessel is well below the melt temperature for aluminum for the 1/2 hour fire test, we are concerned that the containment vessel would be vulnerable if it got out of the drum. We believe that the package provides no defense in depth. We, therefore, conclude that the configuration-3 design is not acceptable for NRC approval. We have terminated our review of this design.

In connection with our review of the configuration-1 design of the Model No. Al-M1, we need the information identified in the enclosure to this letter.

Please advise us when this information will be provided.

Sincerely, l

Charles E. acDonald, Chief Transportation Branch Division of Fuel Cycle and Material Safety

Enclosure:

As stated cc: DOE, Albucuerque Operations Office ATTN: Mr. Jack R. Roeder P.O. Box 5400 Albuquerque, NM 87115

Model No. Al-M1 Configuration-1 Docket No. 71-9507 DEC 0 81978 Enclosure to letter dtd Drawings Revise Drawing No. 4-6896 to include details of the containment vessel weld specifications.  ;

l Structural

1. Provide an additional analysis to show that the containment vessel will not fail as a result of a 30-foot free fall drop test onto the bottom end.
2. Provide additional puncture protection to the pressure gages and valves which are exposed on the containment vessel. l Containment l
1. The fire test and subsequent leak test of the containment vessel were performed on packaging using silicone 0-rings. The design presented for review does not specify a silicone gasket for the containment vessel. Specify the 0-ring material to be used.

Justification for material other than the tested silicone should be provided.

2. Show that the containment capabilities of the package following normal conditions of transport and accident damage conditions are adequate. Regulatory Guide 7.4 may be used to develop an acceptable test to demonstrate adequate containment for the packaging.
3. The application should address how the requirements of 10 CFR 671.42 will be met. Note that the contents form has not been clearly specified.

Testing and Maintenance Discuss the testing and maintenance program to be used to ensure the package containment capability initially and under continued use. Tests should include initial, periodic and preshipment tests to be used on the containment system. The maintenance schedule should include the inspection, test and replacement schedule for components that comprise the containment systems.

Regulatory Guide 7.4 may be used for tests before first use and for periodic leak testing. For assembly verification testing, it is recom-mended that a test of sufficient sensitivity to detect a release of

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no more than a Type A quantity of material in 10 days. If leak testing is to be used for assembly verification, the maximum sensitivity may be 1 x 10 3 atm-cm 3 /sec, and the minimum sensitivity shall be 1 x 101 atm-cm /sec (air at 25 C and 1 atm leaking to a 10 2 atm ambient). The 3

tests should be applied to the containment vessel and any separate inner container used to meet the requirements of 10 CFR 71.42.

Criticality l

1. In order for any package to qualify as Fissile Class I it is neces-sary to demonstrate that the requirements of 10 CFR 971.38 are met.

In practice, Fissile Class I indicates that controls for criticality in transport are not required. This is possible since there is essentially no neutron interaction between packages under normal conditions of transport and at least 250 damaged packages are sub-critical. It should be recognized that Fissile Class I packages could be comingled with other fissile packages. In the case of the subject package, it has not been shown that any number (infinite array) of packages are subcritical for the normal conditions of transport. In this regard, we need a description of the criticality model and analysis and results which support a Fissile Class I designation.

2. Show how the requirements of 10 CFR 71.33 will be met for the chemical and physical form of the contents proposed.

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