ML20151Z223
| ML20151Z223 | |
| Person / Time | |
|---|---|
| Site: | 07105059 |
| Issue date: | 09/15/1998 |
| From: | David Tiktinsky NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Chappell C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9809210210 | |
| Download: ML20151Z223 (15) | |
Text
-ilo Cerrkr n
m t UNITED STATES f
j NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20666-0001
\p%,/*em s September 15, 1998 MEMORANDUM TO: Cass R. Chappell, Chief Package Certification Section, SFPO, NMSS l FROM: David H. Tiktinsky, Project Manager [
Package Certification Section, SFPO, MSS l l
SUBJECT:
MEETING
SUMMARY
REGARDING NUCLEAR FUEL SERVICES l (NFS) URANYL NITRATE TANK TRAILER PACKAGE Attendees l l
NBC NES Shaw Pittman Andrew Barto Patrick Koppell Phyllis Lovett David Tiktinsky Neil Newman Bill Hollaway Ross Chappell Rik Droke Wayne Hodges Tom Baer Washinoton Nucleat Bernie White K.D. Nensley Neil Jensen Andrea Genetta 10troduction A meeting was held on September 9,1998, in Rockville, MD, at the request of NFS. The purpose of the meeting was to discuss the Model No. NFS Uranyl Nitrate Tank Trailer package (Certificate of Compliance No. 5059). The package is used to transport bulk uranyl nitrate solutions. The meeting was a follow up to the discussions in a previous meeting held on August 25,1998. Attached are the handouts used by NFS for their i presentation. '
Discussion l
- 1. NFS presented their position on the A2 value of the enriched irradiated uranium recycled material they want to transport in the Model No. Uranyl Nitrate Tank Trailer / I package.
- 2. NRC indicated that the material to be transported must meet the conditions in the Certificate of Compliance and that it is not clear that the enriched irradiated uranium
[JN recycled material is an approved content for the Model No. Uranyl Nitrate Tank l Trailer package. l
- 3. NRC commented on the meeting handout which implies that NRC is imposing the 1996 lAEA standards without adopting those standards through rulemaking. NRC explained that the 1996 IAEA standards were discussed at the last meeting only to illustrate the point that the IAEA makes a distinction between irradiated and i unitradiated uranium and that there was no intent to impose the 1996 IAEA l standards without rulemaking.
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- 4. NRC reiterated that the package is grandfathered, and does not meet regulatory standards, since the package was not evaluated for cold temperatures and could release radioactive material under normal conditions of transport. In addition, the criticality safety of the package is based limiting the concentration of uranyl nitrate and that conditions that could result in reconcentration or precipitation of the fissile material have not been systematically identified and evaluated.
Docket: 71-5059 Attachments: Meeting Handcuts Distribution: PU8LIC 71-5059 NMSS r/f SFPO r/f WFKane WHodges CHaughney File Center "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFC NMSSISFPO E NMSS/SFPO NMSS/SFPO C NMSS/SFFO C NAME DThinsky ERZieglerN CR I DATE k /l[/98 / /98 9 //5'/98 7// 698 OFFICIAL RECORD COPY
i Use of NFS Uranyl Nitrate Package to Transport Enriched Uranium for the Disposition of Highly Enriched Uranium Program Meeting with NRC on September 9,1998 4
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Scope and Overview Scope e A 2value for 5% enriched uranium in NFS Uranyl Nitrate package e Other issues on package certification review will be addressed at another time Overview e Background on NFS Uranyl Nitrate package
. Issue: A 2value for 5% enriched irradiated uranium
. NFS' position on current NRC and DOT regulations e RecentIAEA actions e Rulemaking process f.
e Summary '
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Background on NFS Uranyl Nitrate Package
- Transport history
- Certification history
- Increased importance of enriched irradiated uranium (recycled) shipments l
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Increased Importance of Enriched Irradiated Uranium (Recycled) Shipments
. U.S. policy of disposing surplus highly enriched uranium through downblending
. Ability to transport irradiated enriched uranium is an industry-wide issue e Allows surplus weapons uranium to be used as fuel in civilian power plants e Essential part of swords-into-plowshares vision of using cold-war weapons material for peaceful purposes
. NFS, nuclear industry, and the U.S. government want to facilitate the goals ofintemational stability in as efficient and safe a manner as possible
- Most efficiait approach - - use existing packages specifically designed to transport such material; minimize number of shipments e $
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a Issue: A2Value for 5% Enriched Irradiated Uranium Ability of NFS Package to Carry Unlimited Quantity of Enriched Uranium, with Enrichment of 5% or less l
NRC POSITION: A 2'value of" Unlimited" does not apply to enriched l i !
irradiated uranium i
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[ NFS POSITION: NFS Uranyl Nitrate package can transport an " Unlimited" ;
I quantity of uranium enriched to 5% or less under current j l
NRC and DOT regulations, whether or not irradiated j 4 ;
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NFS' Position on Current NRC/ DOT Regulations
. 10 C.F.R. Q 71.4 e 10 C.F.R. { 71.55(a) e 10 C.F.R. Part 71 Table A-1 -- U (enriched 5% or less) -- A2 = Unlimited e 49 C.F.R. { 173.431(a) e 49 C.F.R. 173.435 -- U (enriched 5% or less) -- A2 = Unlimited
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- NRC regulations governing these packages do not distinguish between irradiated and 1
unirradiated material e NRC regulations do not define "$riltradiated uranium"
. NFS shipments meet definition of"unirradiated uranium" in DOT regulations e 49 C.F.R. 173.403
Recent IAEA Actions !
e 1994 Interim Guidance
- 1996 Amendments to1AEA Regulations l
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1994 Interim Guidance e k IAEA recognized that enriched uranium from irradiated sol pe material could fit into -
the 1990 definition of"unirradiated uranium"(TecDoc at page 10) e 1994 IAEA TecDoc proposed a revision of the definition of unirradiated uranium and states that the A2 values must explicitly be calculated for irradiated material (TecDoc at page 11) e 1994 IAEA TecDoc allows A2 to be " Unlimited"if 10 mg of material is less than ALI for that material (TecDoc at page 11) e 1994 IAEA TecDoc provides that reprocessed uranium with specific activity not exceeding 10" A 2/ gram shall be classified as LSA-II (TecDoc at page 11) f l
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NRC has not amended its regulations ot' incorporate the 1994 Interim Guidance I
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1996 Amendments to IAEA Regulations
. IAEA amended its regulations in 1996, scheduled to be effective in 2002 1996 Amendments will supersede 1985 (as amended 1990) IAEA regulations and its 1994 Interim Guidance 1996 Amendments will increase the A2 values for Uranium
. 1996 Amendments willincrease the A2 " Unlimited" enrichment limit quantity from 5% to 20% for enriched uranium e 1996 Amendments will differentiate between irradiated and unirradiated materials 3
J NRC has not amended its regulations to incorporate the 1996 Amendments to the IAEA :
regulations ,
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NRC Has Not Amended Its Regulations in Accordance with the Rulemaking Process
. Current NRC regulations in 10 C.F.R. Part 71 are based on the 1985 edition (as amended 1990) of the IAEA regulations (60 Fed. Reg. 50,248, September 28,1995) e NRC has not yet adopted provisions of the 1996 IAEA regulations e Incorporates the 1996 IAEA regulations to the NRC regulations without going through the notice and comment rulemaking process would violate the Administrative Procedures Act, the Atomic Energy Act, and NRC regulations l
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r NFS Material Meets IAEA's 10 mg Threshold for " Unlimited" A Value .
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- Radiation control is question ofisotopics and ALl's, not source of the material
- IAEA has recognized a " category of materials whose specific activities are so low that it is inconceivable that an intake could occur which would give rise for a significant radiation hazard..." SS-7 at 83 (1985 edition, as amended 1990).
- For these materials IAEA has established an A value of" unlimited" where 10 mg of the material is less than 1.00 ALI. SS-7 at 83 (1985 edition, as amended 1990).
- 1994 IAEA TecDoc explicitly applied the 10 mg threshold for unlimited A values to enriched irradiated uranium (TecDoc at page 11)
- 10 mg of NFS shipment material contains only 0.15 ALI, well within IAEA's 1.00 ALI thres, hold for unlimited A values f
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Summary e
Current NRC and DOT regulations have not adopted the 1996 Amendm IAEA regulations I
l e NFS shipments of 5% enriched uranium complies with the current N l
regulations NFS will continue to transport irradiated and enriched material in a safe h ls responsible manner to carry out the important national objectives of t e su highly enriched uranium program
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. Expected Frequency of
- UranylNitrate Tanker Crash
- Assume
- Number oftrips~= 550 One-way mileage per trip = 500 Crash rate = 216 per 100 million miles (NHTSA) f=(500)(550)(216) 10' or f=0.594 =0.6 In Virginia, crash rate = 584 per 100 million for primary roads with lanes s 10 ft, and 203 per 100 million for lanes 2 12 ft. 89% of secondary roads in Virginia have lane widths s 10 ft..