ML20155J228

Draft Value/Impact Statement for Proposed Rev 2 to Reg Guide 7.9,Task Fc 416-4, Std Format & Content of Part 71 Applications for Approval of Packaging for Radioactive Matl

ML20155J228
Person / Time
Issue date:	05/31/1986
From:	NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:
References
TASK-FC-416-4, TASK-RE REGGD-07.009, REGGD-7.009, NUDOCS 8605220373
Download: ML20155J228 (52)

Text

_____ _ _____ _ .

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1. a nso% Mpy 1986 3

/ U.S. NUCLEAR REGULATORY COMMISSION Du.nsion 7 to OFFICE OF NUCLEAR REGULATORY RESEARCH

- r Tcsk FC 416-4 o, DRAFT REGULATORY GUIDE Atl0 VALUE/ IMPACT STATEMENT

Contact:

R. H. Odegaarden (301)427-4122 4

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PROPOSED REVISION 2 TO REGULATORY GUIDE 7.9 STANDARD FORMAT AND CONTENT OF PART 71 APPLICATIONS I

FOR APPROVAL OF PACKAGING FOR RADI0 ACTIVE MATERIAL 8605220373 860031 PDR REGGD 07.009 R PDR This regulatory guide and the associated value/fmpact statement are being issued in draf t fore to involve the public in the e:rly stages of the development of a regulatory position in this area. They have not received complete staff review and do not represent an of f tetal NRC staff position.

Public coments are being solletted on both drafts, the guide (including any implementation schedule) and the value/ impact statement. Coments on the value/ impact statement shovid be accompanied by supporting data. Written coments may be srbeltted to the Rules and Procedures Branch. ORR. A0ff. U.S. Nuclear Regulatory Comission. Washington OC 20555. Coments may also be delivered to Room 4000. Maryland National tank Batiding. 7735 Old Georgetown Road. Bethesda. Maryland from 8:15 a.m. to 5:00 p.m. Coples of coments received may be esaminsd f t R M C P A1)c Document Room. 1711 H 5treet NW.,

Washington. DC. Comuments will be most helpful if received by J L11 43, 1700.

R: quests for single copfes of draft guides (which may be reproduced) or for placement on an automatfc distribution IIst for single copies of future draft guides in specific divisions shuuld be epde in writing to the U.S. Nuclear Regulatory Comission.

Washington DC 20555. Attention: Of rector. Division of Technical Information and Document Control.

TABLE OF CONTENTS.

Page INTRODUCTION......................................................... vii

1. GENERAL INFORMATION............................................. 1-1 1.1 Introduction............................................... 1-1 1.2 Package Description...................................... . 1-1 1.2.1 Packaging........................................... 1- 1 1.2.2 Operational Features................................ 1-2 1.2.3 Contents of Packaging............................... 1-2 1.3 Appendix................................................... 1-2

2. STRUCTURAL EVALUATION........................................... 2-1 2.1 Structural Design.......................................... 2-1 2.1.1 Discussion.......................................... 2-1 2.1.2 Design Criteria..................................... 2-1 2.2 Weights and Centers of Gravity............................. 2-2 2.3 Mechanical Properties of Materials......................... 2-2 l

2.4 General Standards for All Packages......................... 2-2 2.4.1 Minimum Package Size ............................... 2-2 2.4.2 Tamperproof Feature ................................ 2-2 2.4.3 Positive C1osure.................................... 2-3 2.4.4 Chemical and Galvanic Reactions..................... 2-3 2.5 Lifting and Tiedown Standards for All Packages............. 2-3 2.5.1 Lifting Devices .................................... 2-3 2.5.2 Tiedown Devices ................................... 2-3 2.6 Normal Conditions of Transport............................. 2-4 2.6.1 Heat................................................ 2-4 2.6.2 Co1d................................................ 2-5 2.6.3 Reduced External Pressure .......................... 2-5 2.6.4 Increased External Pressure......................... 2-5 2.6.5 Vibration .......................................... 2-5

• Lines indicate substantive changes from Revision 1.

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TABLE OF CONTENTS (Cont'd)

I Page 2.6.6 Water Spray......................................... 2-5 2.6.7 Free Drop........................................... 2-5 2.6.8 Corner Drop......................................... 2-6 2.6.9 Compression......................................... 2-6 2.6.10 Penetration ........................................ 2-6 2.7 Hypothetical Accident Conditions........................... 2-6 2.7.1 Free Drop........................................... 2-6 2.7.2 Puncture............................................ 2-9 2.7.3 Thermal............................................. 2-10 2.7.4 Immersion - Fissile Materia 1........................ 2-10 2.7.5 Immersion - All Packages ........................... 2-11 2.7.6 S umma ry o f D ama g e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-11 2.8 Special Form............................................... 2-11 2.9 Fuel Rods.................................................. 2-11 2.10 Appendix................................................... 2-11

3. THERMAL EVALUATION.......... . ... .. . , ,,,, ... ...., 3-1 3.1 Discussion................................................. 3-1 q 3.2 Summary of Thermal Properties of Materials. . . . . . . . . . . . . . . . . 3-1 3.3 Technical Specifications of Components..................... 3-1 3.4 Thermal Evaluation for Normal Conditions of Transport...... 3-2 3.4.1 Thermal Model....................................... 3-2 3.4.2 Maximum Temperatures................................ 3-2 3.4.3 Minimum Temperatures................................ 3-2 3.4.4 Maximum Internal Pressures.......................... 3-3 3.4.5 Maximum Thermal Stresses............................ 3-3 3.4.6 Evaluation of Package Performance for Normal Conditions of Transport............................. 3-3 3.5 Hypothetical Accident Thermal Evaluation. . . . . . . . . . . . . . . . . . . 3-3 3.5.1 Thermal Model....................................... 3-4 3.5.2 Package Conditions and Environment.................. 3-4 3.5.3 Package Temperatures................................ 3-4 3.5.4 Maximum Internal Pressures.......................... 3-5 3.5.5 Maximum Thermal Stresses............................ 3-5 3.5.6 Evaluation of Package Performance for Hypothetical Accident Thermal Conditions............ 3-5 3.6 Appendix................................................... 3-6 4

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TABLE OF CONTENTS (Cont'd) l P_ag

4. CONTAINMENT..................................................... 4-1 4.1 Containment Boundary....................................... 4-1 4.1.1 Containment Vesse1.................................. 4-1 4.1.2 Containment Penetrations............................ 4-1 4.1.3 Seals and We1ds..................................... 4-1 4.1.4 Closure............................................. 4-1 4.2 Requirements for Normal Conditions of Transport............ 4-2 4.2.1 Containment of Radioactive Material................. 4-2 4.2.2 Pressurization of Containment Vesse1................ 4-2 4.2.3 Containment Criterion .............................. 4-2 4 2 Containment Requirements for Hypothetical i Accident Conditions........................................ 4-2 4.3.1 Fission Gas Products................................ 4-2

4. 3. 2 Containment of Radioactive Material................. 4-3 4.3.3 Containment Criterion............................... 4-3 I 4.4 Special Requirements....................................... 4-3 4.5 Appendix................................................... 4-3

5. SHIELDING EVALUATION............................................ 5-1 5.1 Discussion and Results..................................... 5-1 5.2 Source Specification....................................... 5-1 5.2.1 Gamma Source........................................ 5-1 5.2.2 Neutron Source...................................... 5-1 5.3 Model Specification........................................ 5-2 5.3.1 Description of Radial and Axial Shielding Configuration.................... ........ 5-2 5.3.2 Shield Regional Densities........................... 5-3 5.4 Shielding Evaluation....................................... 5-3

5. 5 Appendix................................................... 5-3

6. CRITICALITY EVALUATION.......................................... 6-1 6.1 Discussion and Results..................................... 6-1 6.2 Package Fuel Loading....................................... 6-1 v

TABLE OF CONTENTS (Cont'd) l Pag 6.3 Model Specification........................................ 6-1 6.3.1 Description of Calculational Mode 1.................. 6-1 6.3.2 Package Regional Densities.......................... 6-4 6.4 Criticality Calculation.................................... 6-4 6.4.1 Calculational or Experimental Method................ 6-4 6.4.2 Fuel Loading or Other Contents Loading Optimization........................................ 6-4 6.4.3 Criticality Results................................. 6-5 6.5 Critical Benchmark Experiments............................. 6-5 6.5.1 Benchmark Experiments and Applicability............. 6-5 6.5.2 Details of Benchmark Calculations................... 6-5 6.5.3 Results of Benchmark Ca1culaticns................... 6-6 6.6 Appendix................................................... 6-6

7. OPERATING PROCEDURES............................................ 7-1 7.1 Procedures for Loading Package............................. 7-1 l 7.2 Procedures for Unloading Package........................... 7-2 7.3 Preparation of Empty Package for Transport................. 7-2 7.4 Appendix................................................... 7-2

8. ACCEPTANCE TESTS AND MAINTENANCE PR0 GRAM........................ 8-1 8.1 Acceptance Tests........................................... 8-1 8.1.1 Visual Inspection................................... 8-1 8.1. 2 Structural and Pressure Tests....................... 8-1 8.1. 3 Leak Tests.......................................... 8-1 8.1. 4 Component Tests..................................... 8-1 8.1.5 Tests for Shielding Integrity....................... 8-2 8.1.6 Thermal Acceptance Tests............................ 8-3 8.2 Maintenance Program........................................ 8-3 1

8.2.1 Structural and Pressure Tests....................... 8-3 8.2.2 Leak Tests.......................................... 8-4 8.2.3 Subsystem Maintenance............................... 8-4 8.2.4 Valves, Rupture Discs, and Gaskets on i Containment Vessel.................................. 8-4 i 8.2.5 Shielding........................................... 8-4 '

8.2.6 Thermal............................................. 8-4 8.2.7 Miscellaneous....................................... 8-4 DRAFT VALUE/ IMPACT STATEMENT......................................... VI-1 vi

INTRODUCTION This regulatory guide has been compiled by the staff of the United States Nuclear Regulatory Commission (NRC) as an aid in the preparation of applications for approval of packaging to be used for the shipment of type B and fissile radioactive material. It is not intended as an interpretation of Commission regulations, within the meaning of SS 30.5, 40.6, 70.6, or 71.2 of Parts 30, 40, 70, or 71, respectively, of Title 10 of the Code of Federal Regulations.

Nothing contained in this guide may be construed as having the force and effect of NRC regulations, or as indicating that applications supported by safety analyses and prepared in accordance with the recommendations of this regulatory guide necessarily will be approved, or as relieving any licensee from the requirements of 10 CFR Parts 30, 40, 70, and 71 and any other pertinent regu-lations.

This r q alatory guide should not be considered a substitute for reference to 10 CFR Part 71, " Packaging and Transportation of Radioactive Material." Its primary purpose is to assist the applicant in preparing an application that thoroughly and completely demonstrates the adequacy of the package in meeting the regulations. In addition to an approval of packaging, the applicant must have an approved quality assurance program in accordance with the provisions of S 71.101 through S 71.137 of 10 CFR Part 71. Additional information will be requested in support of an application if NRC believes that such information is necessary to provide reasonable assurance of the safety of the proposed ship-ment. In preparing an application for approval of packaging, the applicant may find it useful to refer to other regulatory guides of Division 7, "Transporta-tion." Inquiries about these regulatory guides may be directed to the U.S.

Nuclear Regulatory Commission, Washington, D.C. 20555, Attention: Director, Division of Technical Information and Document Control.

Any information collection activities mentioned in this regulatory guide are contained as requirements in 10 CFR Part 71, which provides the regulatory basis for this guide. The information collection requirements in 10 CFR Part 71 have been cleared under OMB Clearance No. 3150-0008.

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Purpose of Standard Format-l The purpose of the Standard Format and Content of Part 71 Applications for Approval of Packaging for Radioactive Material (hereinaf ter " Standard Format")

is to indicate the information to be provided in the application and to estab-lish a uniform format for presenting the information. Use of this format will help ensure the completeness of the information provided, will assist the NRC staff and others in locating the information, and will aid in shortening the time needed for the review process. The application is the principal document in which the applicant provides the information and bases for the NRC staff to determine whether or not the package meets the requirements of 10 CFR Part 71.

Applicability of Standard Format This Standard Format applies specifically to applications for approval of packaging of type B and fissile radioactive material under 10 CFR Part 71.

The Standard Format identifies general and detailed information required and will help ensure the completeness of the information provided.

I Use of Standard Format The Standard Format presents a format for applications for approval that is acceptable to the NRC staff. Conformance with the Standard Format, however, is not required. Applications for approval with different formats will be acceptable to the staff if they provide an adequate basis for the findings requisite to the approval of packaging. However, because it may be more diffi-cult to locate needed information, the staff review time for such applications may be longer.

Upon receipt of an application, the NRC staff will perform a preliminary review to determine if the applicatien provides a reasonably complete presenta- t tion of the information that is needed to form a basis for the findings required before approval of a package in accordance with 10 CFR Part 71. The Standard Format will be used by the staff as a guideline to identify the type of informa-tion needed. If the application does not provide a reasonably complete presen-tation of the necessary information, further review of the application will not viii

be initiated until a reasonably complete presentation is provided. The informa-tion provided in the application should be up to date with respect to the state of technology for transportation of radioactive materials and should take into account recent changes in NRC regulations and guides, industry codes and stand-ards, results of recent developments in transportation safety, and experience in the construction and use of radioactive material packaging.

Style and Composition The applicant should strive for clear, concise presentation of the infor-mation provided in the application. Confusing or ambiguous statements and unnecessarily verbose descriptions do not contribute to expeditious technical review. Claims of adequacy of designs or design methods should be supported by technical bases, i.e., by an appropriate engineering evaluation or description of actual tests. Terms as defined in the packaging and transport regulations rust be used.

The application should follow the numbering system and headings of the I Standard Format at least to the headings with three digits, e.g., 2.4.3 Positive Closure. When a particular requirement does not apply to a package, the corre-sponding subsection should not be omitted but should be addressed with the term "Not Applicable." A reason should be offered for not addressing a particular requirement when there is doubt as to its applicability.

Appendices to each chapter of the application should include detailed information omitted from the main text for clarity. A list of reports or other d:cuments that are referenced in the text of the application should be included in the appendix at the end of the chapter in which they are referenced. When specific items are referenced, page numbers should be provided. If proprietary d:cuments are referenced, a nonproprietary summary description of the document should also be referenced.

All physical tests of components and packages should be supported by photo-graphs in the appendices of the appropriate chapter. Appendices to the applica-tion may also be used to provide supplemental information not explicitly iden-D tified in the Standard Format. Examples of such information are (1) summaries ix

l of the manner in which the applicant has treated matters addressed in NRC regu-latory guides and (2) supplementary information regarding calculational methods or design approaches used by the applicant or its agents.

l Where numerical values are stated, the number of significant figures given should reflect the accuracy or precision to which the number is known. Where possible, estimated limits of error or uncertainty should be given. Signifi-cant figures should not be dropped or rounded off if, by doing so, subsequent conclusions are inaaequately supported.

Abbreviations should be consistent throughout the application and should be consistent with generally accepted usage. Any abbreviations, symbols, or special terms unique to the proposed packaging or not in general usage should be defined in each chapter of the application where they are used.

Drawings, diagrams, sketches, and charts should be used where the informa-tion can be presented more adequately or conveniently by such means. Due con-cern should be taken to ensure that all information presented in drawings is legible, symbols are defined, and drawings are not reduced to the extent that visual aids are necessary to interpret pertinent items of information presented in the drawings.

Revisions Data and text should be updated or revised by replacing pages. " Pen and ink" or " cut and paste" changes should not be used.

The changed or revised portion on each page should be highlighted by a

" change indicator" mark consisting of a bold vertical line drawn in the margin opposite the binding margin. The line should be the same length as the portion actually changed.

All pages submitted to update, revise, or add pages to the application should show the date of change and a change or amendment number. A transmittal letter, including a guide page listing the pages to be inserted and the pages to be removed, should accompany the revised pages. Where applicable, supple-mental pages may follow the revised page.

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All statements on a revised page should be accurate as of the date of the submittals.

Special care should be taken to ensure that the main sections of the application are revised to reflect any design changes reported in supplemental information, i.e. , responses to NRC staff requests for information or respon:,es to regulatory positions.

l Physical Specifications All material submitted as part of the application should conform to speci-fic standards as to the physical dimensions of page size, quality of paper and inks, and numbering of pages, exhibits, and attachments. More specifically:

1. Paper Size (not to exceed)

Tc;t pages: 0-1/2 x 11 inches.

Drawings and graphics: 8-1/2 x 11 inches preferred; however, a larger size is acceptable provided:

a. After reduction, the size does not exceed 11 x 17 inches, including a 2-inch margin at left for binding.

b. The finished copy when folded does not exceed 8-1/2 x 11 inches.

All drawings should have a drawing number, sheet number, company name, title, revision number, date of revision, and signature or initials indicating approval of the drawing and each revision.

2. Paper Stock Weight or substance: 20 pound for printing on both sides.

16 to 20 pound for printing on one side only.

Composition: Wood chemical sulphite (no groundwood) and a pH of 5.5.

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Color: White is preferred, but pastel colors are acceptable provided the combination of paper stock and ink is suitable for microfilming.

3. Ink Color sufficiently dense to record on microfilm or image-copying equipment.

4. Page Margins A margin of no less than 1 inch should be maintained on the top, bottom, and binding side of all pages.

5. Printing Composition: Text pages should be single spaced.

Type font and style: Must be suitable for microfilming.

Reproduction; itay be mechanically or photographically reproduced. Text pages should preferably be printed on two sides with the image printed head to head.

6. Binding Pages should be punched for standard 3-hole looseleaf binder and contained within a binder supplied by the applicant.

7. Page Numbering Pages should be numbered by chapttr and sequentially within the chapter.

8. Separators Separators should be provided between each chapter of the application.

9. Number of Copies Ten copies of the application should be provided.

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1. GENERAL INFORMATION This chapter of the application should present an introduction and general package description.

1.1 Introduction This section should include the proposed use of the package, the model num-ber, and, in the case of fissile packages, the proposed fissile class or classes, and the number of packages per shipment or transport index, as appropriate.

1. 2 Package Description 1.2.1 Packaging The packaging description should include the gross weight, materials of I

construction, materials used as neutron absorbers or moderators, external dimen-sions and cavity size, internal and external structures, receptacles, valves, sampling ports, means of heat dissipation, volumes and types of coolant, outer and inner protrusions, lif ting and tiedown devices, amount of shielding, pres-sure relief systems, closures, and means of containment. The containment vessel should be clearly identified. Overall and cutaway sketches (8-1/2 x 11 inches) of the package should be included as part of the description.

Drawings that clearly detail the safety features considered in the analy-sis should be included in Appendix 1.3; e.g., material lists, dimensions, valves, fasteners, and welder and welding procedure qualification requirements should be included on the drawings. The drawings should specify, by appropriate weld symbol, the requirements for all packaging weld joints, including the method of nondestructive examination and the acceptance standard. Gasketed joints in the containment system should be sufficiently detailed to show, as a minimum, the surface finish and flatness requirements of the closure surfaces, the gasket specification, and, if appr priate, the method of gasket retention. Detailed h

F construction drawings of large, complex packages should not be included.

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1.2.2 Operational Features q

In the case of a complex package system, a discussion of the operation of the package should be provided. This would include a schematic diagram showing all valves, connections, piping, openings, seals, containment boundaries, etc.

1.2.3 Contents of Packaging State the quantity of radionuclides (in the case of irradiated fuel ship-ments, also estimate the quantity of radionuclides available for immediate release within the void space of the fuel rods), chemical and physical form, material density, moderator ratios, configurations as required for nuclear safety evaluation, the maximum amount of decay heat, maximum pressure buildup in the inner container, and any other loading restrictions.

1.3 Appendix This appendix should include detailed information describing the packaging, I

operational features, and contents of the packaging such as dimensional drawings, detailed operational schematics, and loading configurations.

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2. STRUCTdRAL EVALUATION This chapter of the application should identify, describe, discuss, and cnalyze the principal structural engineering design of the packaging, components, cnd systems important to safety and to compliance with the performance require-ments of 10 CFR Part 71.

2.1 Structural Design l l

2.1.1 Discussion Identify the principal structural members and systems such as the contain-ment vessel, impact limiters, closure devices, and valves that are vital to safe operation of the package. Reference the location of these items on draw-ings, a.d discuss their hLructural design and performance.

2.1.2 Design Criteria Describe the load combinations and factors that serve as design criteria.

Design criteria may be used if judged acceptable by the NRC staff in meeting the structural requirements of SS 71.41 through 71.51 of 10 CFR Part 71. For cach of these criteria, state the maximum allowable stresses and strains (as a percentage of the yield or ultimate values) for ductile failure; describe how the other structural failure modes (e.g., brittle fracture, fatigue, buckling) are considered. If different design criteria are to be allowed in various parts of the packaging or for different conditions, the appropriate values for each case should be indicated. Include the criteria that will be used for impact evaluation. Identify all codes and standards that are used to determine material properties, design limits, or methods of combining loads and stresses. In cases of deviation from standard codes, or if certain components are not covered by such codes, provide a detailed description of the design criteria used as substitutes.

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2.2 Weights and Centers of Gravity List the total weight of the packaging and contents. Tabulate the weights of major individual subassemblies such that the sum of the parts equals the total of the package. Locate the center of gravity of the package and any other centers of gravity referred to in the application. It is not necessary to in-clude the calculations rr.ade to determine these values, but a sketch or drawing that clearly shows the individual subassembly referred to and the reference point for locating its center of gravity should be included.

2.3 Mechanical Properties of Materials List all the material mechanical properties used in the structural evalua-tion. This may include yield stress, ultimate stress, modulus of elasticity, ultimate strain, Poisson's ratio, density, and coefficient of thermal expansion.

If impact limiters are used, include either a compression stress-strain curve for tha material or the force-deformation relationship for the limiter, as appropriate. For materials subjected to elevated temperatures, the appropriate mechanical properties under these conditions should be specified. The source of all information in this section should be clearly and specifically referenced l as to publication and page number. Where material properties are determined by testing, the test procedure, conditions, and measurements should be described in sufficient detail to allow the staff to conclude that the results are valid.

2.4 General Standards for All Packages

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This section should state that the general standards for all packaging, specified in S 71.43, are complied with, as demonstrated in the following para-graphs.

I 2.4.1 Minimum Package Size 2.4.2 Tamperproof Feature 4

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2.4.3 Positive Closure Describe and discuss the package closure system in sufficient detail to show that it cannot be inadvertently opened. This demonstration should include covers, valves, or any other access that must be closed during normal transpor-tation.

2.4.4 Chemical and Galvanic Reactions Discuss possible chemical, galvanic, or other reactions in the packaging or between the packaging and the package contents. For each component material of the packaging, list all chemically or galvanically dissimilar materials with which it has contact. Indicate any specific measures that have been taken to prevent contact or reaction between materials, and discuss the effectiveness of such measures.

2. 5 Lifting and Tiedown Standards for All Packages 2.5.1 Lifting Devices Identify all devices and attachments that can be used to lift the package or its lid. Show by testing or analysis that these devices comply with the requirements of paragraph 71.45(a) of 10 CFR Part 71. Provide drawings or sketches l that show the location and construction of these items. Determine the effects of the forces imposed by lifting on vital package components, including the interfaces between the lifting device and other packaging surfaces. Documented values of the yield stresses of the matr; rials should be used as the criteria to demonstrate compliance with paragraph 71.45(a).  !

2.5.2 Tiedown Devices Identify all devices that are a structural part of the package and can be used as tiedowns. Discuss the overall tiedown system. Show by testing or analysis that these devices comply with the requirements of paragraph 71.45(b) of 10 CFR Part 71. Provide drawings or sketches that show the location and

> construction of these devices and the overall tiedown system. Determine the effect of the imposed forces on vital package components, including the 2-3

interfaces between the tiedown devices and othe package surfaces. Documented values.of the yield stresses of the materials should be used as the criteria to ldemonstratecompliancewithparagraph71.45(b).

2. 6 Normal Conditions of Transport In this section, state that tte package, when subjected t~o the conditions and test (.aormal conditions of transport) specified in S 71.71 of 10 CFR Part 71, meets the standards specified in SS 71.43 and 71.51 ef 10 CFR Part 71, as demon-strated in the following paragraphs. The package should be assessed against each l condition separately and a determination made that the applicable performance requirements specified in the regulatians have been satisfied.

2.6.1 Heat The ther.T.al evaluation for the heat test should be reported in Section 3.4.

2. 6.1.1 Summary of Pressures and Temperatures. Summarize all pressures and temperatures, determined in the ttermal evaluation (Chapter 3), that will {

be used to perform the calculations required for paragraphs 2.6.1.2, 2.6.1.3, and 2.6.1.4.

2.6.).2 Differential Thermal Expansion. Calculat.ethecircumferential and axial deformatione and stresses (if any) that resu i t from differential thermal expansion. Consider steady-state and transien: conditions. These cal-culations must be sufficiently comprehensive to demonst rate package ' integrity under nornal transport conditions.

2.6.1.3 Stress Calculations. Criculate the stro.ises due to the combined effects of thermal gradients, pressure , and mechanical loads (including fabrica-tion stresses from lead pour and lead cooldown). Provide sketches that.show the configuration and dimensions of the menbars or systems being analyzed, and locate the points at which the stresses are.being calculated. The analysis should consider whether repeated cycles of thermal loacings, together with other loadings, will cause fatigue failure or extensive accumulations of deformation.

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2.6.1.4 Comparison with Allowable Stresses. Make the appropriate stress combinations, and compare the resulting stresses with the design criteria in Section 2.1.2 of the application. Show that all the performance requirements specified in the regulations have been satisfied.

2.6.2 Cold Assess the package for the effects of a steady-state ambient temperature of -40 F (-40 C). Consider both material properties and possible freezing of liquids and lead shrinkage under this condition. Identify, for vital components of the package, the resulting temperatures and their effect on operation of the package. Brittle fracture should be considered. (Note: For the sequential hypothetical accident test series, -20 F (-29 C) is the lowest service temperature that need be considered. See paragraph 71.73(b).)

2.6.3 Reduced External Pressure Assess the package for the effects of external pressure equal to 3.5 psia.

I 2.6.4 Increased External Pressure Assess the package for the effects of external pressure equal to 20 psia.

2.6.5 Vibration Assess the package for the effects of vibrations normally incident to trans-port.

2.6.6 Water Spray Assess the package for the effects of the water spray test.

2.6.7 Free Drop Assess the package for the effects of the free drop test. The general comments in Section 2.7.1 also apply to this condition. (Note that the free drop test follows the water spray test.)

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2.6.8 Corner Drop If applicable, assess the package for the effects of corner drops.

2.6.9 Compression If applicable, assess the package for the effects of compression.

2.6.10 Penetration Assess the package for the effects of penetration. (Note that the point of impact could be at any location on the exterior surface of the package.)

2.7 Hypothetical Accident Conditions In this section, state that the package, when subjected to the tests (hypo-thetical accident conditions) as specified in S 71.73 of 10 CFR Part 71, meets the standards specified in S 71.51 of 10 CFR Part 71, as demonstrated in the 4

following paragraphs.

The hypothetical accident conditions are to be considered in t.he sequence specified by the regulations. Damage caused by each test is cumulative, and the evaluation of the ability of a package to withstand any one test must con-sider the damage that resulted from the previous tests. It should be noted that a determination must have been made in Section 2.6 that the effectiveness of the package has not been reduced as a result of the normal conditions of transport. Brittle fracture should be considered.

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1 2.7.1 Free Drop '

The performance and structural integrity of a package must be evaluated for the drop orientation that causes the most severe damage. An orientation I that results in the most damage to one system or component may not be the must damaging for other systems and components. For this reason, it is usually necessary to consider several drop orientations. The minimum requirement is 1

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l that orientations for which the center of gravity is directly over the point of impact must be considered.

The assessment of the package may be by analysis, prototype testing, model testing, or comparison to a similar package.

a. Analysis Calculations should be presented in sufficient detail to allow the results to be verified. Adequate na, ration and use of sketches and free body force diagrams should be included. For equations used in the analysis, either the source should be referenced or the derivation should be included.

The analysis should show hcw all the kinetic energy will be dissipated and which local deformation and dynanic forces occur during impact. The response of the package in terms of stress and strain to components and struc-tural members should be shown. The structural stability of individual members, as applicable, should be investigated as well as stress due to impact combined with those stresses caused by temperature gradients, differential thermal expan-sions, pressure, and other loads. Show that the performance requirements of 10 CFR Part 71 are met.

b. Prototype Testing Describe the test method, orocedures, and target that were used.

Indicate the package orientation at time of impact. If the package tested is not identical in all respects to the package described in the application, explain the differences and show that these differences would not affect the test results.

Describe the materials used as substitutes for the radioactive contents during the tests. Show that. this substitution would not af fect the test results. Consider the effects c.f internal decay heat and pressure buildup if these effects had arisen with the actual loading.

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Indicate in a quantitative manner the damage caused by the impact and the results of any measurements that were made. Include both interior and exterior damage. Provide photographs of the damaged packaging.

Show that the performance requirements of 10 CFR Part 71 have been met for the damaged package.

c. Model Testing Describe the model completely, and provide detailed drawings that show its dimensions and materials of construction. Specify the dimensional toler-ances to which the model was fabricated, and compare these to the tolerances that will be used for the prototype.

State the scale factor that was used for the model. Describe in detail the laws of similitude that were used for testing, considering time scale, material density, velocity at impact, and kinetic energy. Show that the model test will give conservative results for peak g-force, maximum deforma-

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tion, and dissipated energy.

For the actual model tests, provide all the information required for item b above.

Correlate the damage done to the model with damage to a prototype, and show that the prototype would be adequate to meet all the performance requirements of 10 CFR Part 71.

d. Comparison to Similar Packages The comparison must demonstrate that the proposed package is, in all respects, better than or equal to the package previously approved and that the proposed package can meet all the regulatory performance requirements. The following information should be provided:

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(1) The dimensions, materials, and configurations of both packages, (2) The overall weight of both packages, and (3) The weight and form of the contents of both packages.

The comparison should demonstrate:

(1) 'That the packages will have a similar response to the specified tests, (2) That *he forces acting on all vital safety systems and components of the proposed package are less than the tested package or that all vital safety systems and components of the proposed package have sufficient structural integrity, and (3) That the proposed package will meet all the regulatory perform-ance requirements.

2.7.1.1 End Drop. Assess the package for the effects of the end drop test.

I 2.7.1.2 Side Drop. Assess the package for the effects of the side drop test.

2.7.1.3 Corner Drop. Assess the package for the effects of the corner drop test.

2.7.1.4 Oblique Drops. Assess the package for the effects of oblique drops, or provide information that shows that the end, side, and corner drops are more damaging to all systems and components vital to safety.

2.7.1.5 Summary of Results. Discuss the condition of the package af ter each drop test. Summarize the extent to which the packaging would be damaged in each orientation.

2.7.2 Puncture

} Assess the effects of the puncture test. Consider both local damage near the point of impact and the overall effect on the package. Note that the point 2-9

of impact could be at any location on the exterior surface of the package. It is particularly important that all valves and fittings necessary for containment be considered. Most of the general comments provided in Section 2.7.1 also apply to this test condition.

2.7.3 Thermal The thermal test should follow the free drop and puncture tests and should be reported in Section 3.5.

2.7.3.1 Summary of Pressures and Temperatures. Summarize all the tem-peratures and pressures, as determined in the thermal evaluation (Chapter 3) of the application, that are used in paragraphs 2.7.3.2, 2.7.3.3, and 2.7.3.4.

2.7.3.2 Differential Thermal Expansion. Calculate the circumferential and axial deformations and stresses (if any) that result from differential thermal expansion. Consider peak conditions, postfire steady-state conditions, and all transient conditions.

2.7.3.3 Stress Calculations. Calculate the stresses due to thermal gra-dients, differential expansion, pressure, and other mechanical loads. Provide sketches showing configuration and dimensions of the members of systems under investigation, and locate the points at which the stresses are being calculated.

2.7.3.4 Comparison with Allowable Stresses. Make the appropriate stress combinations, and compare the resulting stresses with the design criteria in Section 2.1.2 of the application. Show that all the performance requirements specified in the regulations have been satisfied.

2.7.4 Immersion - Fissile Material Assess the effects and consequences of the water immersion test condition for fissile packages.

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2.7.5 Immersion - All Packages Immerse package under 50 ft (15 m) of water for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. For test purposes, an external gauge pressure of water of 21 psi (145 kPa) is considered to meet these conditions.

2.7.6 Summary of Damage l

Discuss the condition of the package after the accident test sequences.

Summarize the extent to which vital safety systems and components have been damaged, and relate to the acceptance standards.

2.8. Special Form As applicable, in this section when special form is claimed, state that the contents meet special form requirements given in S 71.75 when subjected to the applicable test conditions of S 71.77 of 10 CFR Part 71. Describe the chemical and physical form. If the source is not a doubly encapsulated right I circular cylinder of welded construction, provide a detailed drawing of the encapsulation showing the dimensions, materials, manner of construction, and method of nondestructive examination.

2.9 Fuel Rods In Chapter 4, " Containment," where fuel rod cladding is considered to provide containment of radioactive material under normal or accident test conditions, provide an analysis or test results showing that the cladding will maintain sufficient mechanical integrity to provide the degree of containment claimed.

2.10 Appendix This appendix should include information such as justification of assump-tions or analytica.1 procedures, test results, photographs, computer program descriptions and input / output, reference lists, and applicable pages from ref-I erenced documents.

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3. THERMAL EVALUATION This chapter of the application should identify, describe, discuss, and analyze the principal thermal engineering design of the packaging, components, and systems important to safety and to compliance with the performance require-ments of 10 CFR Part 71.

3.1 Discussion Describe the significant thermal design features and operating character-istics of the package. The operation of all subsystems (e.g., auxiliary cooling systems, expansion tanks) should be discussed. Identify any thermal criteria that will be applied directly to thermal results (e.g., maximum fuel tempera-ture, shield temperature not to exceed melt). Also identify properties evalu-ated here but used to support other evaluations (e.g., pressure, temperature, distributions relative to thermal stress). Summarize the significant results I of the thermal analysis or tests and the implication of these results on the overall package. State the minimum and maximum decay heat loads assumed in the thermal evaluation. The maximum decay heat load assumed should be consistent with the source terms assumed in the shielding analysis.

3.2 Summary of Thermal Properties of Materials List the thermal properties of all materials used in the thermal evaluation.

References for the data cited should be provided.

3.3 Technical Specifications of Components Include the technical specifications of package components. For example, in the case of valves or relief valves, the operating pressure range and temper-cture limits should be included. The properties of fabricated insulation and coatings should be tabulated. Test data should be supplied in support of per-formance specifications and should be presented in detail in Section 3.6.

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3.4 Thermal Evaluation for Normal Conditions of Transport Section 71.71 of 10 CFR Part 71 defines the normal conditions of transport.

These conditions are to be applied to the test item or analytical model. The test item or analytical model should be described. Particular attention should be given to justifying the use of simplifying or scaling assumptions. When the package design involves various operating modes or configurations such as different fuel loadings and different coolants, each mode must be evaluated within its operating range to determine the adequacy of the design.

3.4.1 Thermal Model 3.4.1.1 Analytical Model. Describe the analytical thermal model in detail.

The model should include gaskets, valves, fuel assemblies, and the overall pack-l age. Modeling assumptions should be fully justified.

3.4.1.2 Test Model. Describe the test item and procedures used. Provide the details of the procedures used to correlate the test data to the thermal environment for normal conditions of transport, as defined in S 71.71. Tempera-ture data should be taken at gaskets, valves, and other containment boundaries as well as from the overall package.

3.4.2 Maximum Temperatures List the maximum temperature distribution for the package for normal condi-tions of transport, including the contents, containment vessel, shielding mate-rial, gaskets, valves, etc.

3.4.3 Minimum Temperatures List the minimum temperature distribution for the package for normal condi-tions of transport. This evaluation should include the minimum decay heat load that will be transported. When a decay heat load greater than zero is required for safe operation, assurance of that heat load must be provided. The tempera-tures of significant components such as gaskets and valves should be reported.

The shipment of an empty package should be addressed.

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3.4.4 Maximum Internal Pressures The conditions within the range of normal conditions of transport that result in the limiting internal pressures (i.e., maximum normal operating pressure) and the limiting combination of thermal loadings should be identified. The internal pressures for these conditions should be determined. The evaluation should consider the effects of phase change, gas generation, chemical decomposi-tion, etc., as well as fluid expansions and compressions. The additional pres-sure buildup that would result from fuel rod failure while in transport should be considered.

3.4.5 Maximum Thermal Stresses Determine the conditions within the range of normal conditions of transport and fabrication (e.g. , lead pour) that result in the limiting combination of ther-mal gradient and isothermal stresses. List the resulting temperature distribu-tion.

I 3.4.6 Evaluation of Package Performance for Normal Conditions of Transport Evaluate the package performance, including system and subsystem operation, for normal conditions of transport with respect to the results of the thermal analysis or tests performed. Take into account significant conditions to be found in the ranges bounded by the minimum and maximum ambient temperatures and minimum and maximum decay heat loads. Compare the results with allowable limits of temperature, pressure, etc., for the package components. Designate the information that is to be used in other chapters of the review. Present the information in summary tables along with statements and appropriate comments.

3.5 Hypothetical Accident Thermal Evaluation In this section, the effects of the hypothetical accident thermal condi-tion on the package should be evaluated. The hypothetical accident conditions are defined in S 71.73; they are to be applied sequentially. The thermal j test follows the free drop and puncture tests. Discuss the tests or analytical procedures used to evaluate the package performance for the hypothetical acci-dent thermal condition. When the package design involves various operating 3-3

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modes or configurations such as different fuel loadings and different coolants, each mode must be evaluated within its operating ranges to determine the adequacy of the design.

l 3.5.1 Thermal Model 3.5.1.1 Analytical Model. Describe the analytical thermal model in detail.

l The model should include gaskets, valves, fuel assemblies, and the overall pack-l age. Modeling assumptions should be fully justified. When contents may vary or their heat absorption capability cannot be ensured, they should not be included in the model as a heat sink but should be included as a heat source.

3.5.1.2 Test Model. Describe the test item and procedures used. Provide the details of the procedures used to correlate the test data to the thermal environment for the hypothetical accident conditions, as defined in S 71.73.

Temperature data should be taken from gaskets, valves, and other containment boundaries as well as from the overall package.

3.5.2 Package Conditions and Environment Describe and discuss any damage to the package resulting from the free drop or puncture tests. The effect of any such damage on the package thermal performance is to be evaluated. The limiting package condition from a thermal standpoint will be chosen from the range of damage conditions following the free drop and puncture. This limiting case is to be used in the thermal analysis.

3.5.3 Package Temperatures The transient results of the thermal analysis or test should be presented.

The temperatures reported should include those temperatures at locations in the package that are significant to the safety analysis and review. The temperatures for such items as contents, gaskets, valves, and lead shielding are especially important and should be reported. The calculations of transient temperatures should trace the temperature-time history up to and somewhat past the time at which temperature maximums are achieved and begin to fall.

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3.5.4 Maximum Internal Pressures Determine the maximum internal pressures that result during the fire test and cooldown. The pressures that result in the most severe loading in combina-tion with any other loads developed should be determined. Provide details of the pressure calculations. These details should include temperatures and I quantities of fluids as well as the associated fluid volumes. Where chemical reactions or phase changes occur, the following should be discussed: (a) the reaction or phase change mechanism, (b) the reactants and products involved, (c) estimates of the extent and the rate of reaction or phase change, and (d) the consequences of the reaction or phase change. The additional pressure buildup that would result from fuel rod failure while in transport should be considered.

3.5.5 Maximum Thermal Stresses Determine the most severe thermal stress conditions that result during the fire test and subsequent cooldown. Report the temperatures corresponding to I

the maximum thermal stresses.

3.5.6 Evaluation of Package Performance for Hypothetical Accident Thermal Conditions Evaluate the package performance, including system and subsystem operation, for the hypothetical accident thermal conditions with respect to the results of the thermal analysis or tests performed. Compare the results with allowable limits of temperature, pressure, etc., for the package components. Estimate the damage to the package either from interpretation of the analysis or from test observation. This assessment should include structural damage, breach of containment, and loss of shielding.

Designate the information to be used in other chapters of the review. This information should be presented in summary tables and statements wii.h appropriate comments. The comments are to include destination and use information and the specific conditions that the data simulate.

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3. 6 Appendix This appendix should include information such as justification of assump-tions or analytical procedures, test results, photographs, computer program descriptions and input / output, and applicable pages from referenced documents.

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4. CONTAINMENT This chapter of the application identifies and discusses the package con-tainment for the normal conditions of transport and the hypothetical accident conditions.

4.1 Containment Boundary Identify the containment boundary claimed for the package.

4.1.1 Containment Vessel A summary of design specifications for the containment vessel should be provided.

4.1.2 Containment Penetrations I

Identify all penetrations into the primary containment. Provide a summary of the performance specifications for all components that penetrate the contain-ment boundary.

4.1.3 Seals and Welds Identify all seals and welds that affect the package containment. A sum-mary of the design specifications for these seals and welds should be provided.

4.1.4 Closure Identify the closure devices used for the containment vessel. Specify the initial bolt torque that will be required to maintain a positive seal during normal and accident conditions of transport.

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4.2 Requirements for Normal Conditions of Transport Summarize and use the pertinent results of the analysis or test performed =

in Chapters 2, " Structural Evaluation," and 3, " Thermal Evaluation," to demon-strate that the package meets the containment requirements of S 71.51 for normal conditions of transport as defined in S 71.71.

4.2.1 Containment of Radioactive Material Determine the containment criteria for radioactive materials that satisfy S 71.51.

4.2.2 Pressurization of Containment Vessel Any mixture of vapors or gases that could form in the containment vessel should be identified. Show that any increase in pressure or explosion within the containment vessel due to these vapors or gases could not significantly reduce the package effectiveness.

4.2.3 Containment Criterion Specify a verifiable containment criterion (e.g., leak test) to be used to demonstrate that the containment criteria of Section 4.2.1 are satisfied.

4.3 Containment Requirements for Hypothetical Accident Conditions Summarize and use the pertinent results of the analysis or test performed in Chapters 2 and 3 to demonstrate that the package meets the containment requirements of S 71.51 for the hypothetical accident conditions defined in S 71.73.

4.3.1 Fission Gas Products For spent fuel shipments, establish the maximum quantity of fission gas products that could be available for release in the containment vessel under the hypothetical accident conditions.

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4.3.2 Containment of Radioactive Material Determine the containment criteria for radioactive materials that satisfy S 71.51.

4.3.3 Containment Criterion Specify a verifiable containment criterion (e.g. , leak test) to be used to demonstrate that the containment criteria of Section 4.3.2 are satisfied.

4.4 Special Requirements For packaging subject to the special requirements for plutonium shipments (S 71.63), the secondary containment should be discussed. This should include the identification and drwings of the separate inner container and the response of the separate inner container when subjected to the normal conditions of transport to retain its plutonium contents, as demonstrated to a sensitivity of 10 6 A 2per hour. If the entire package is subjected to the I hypothetical accident conditions, the separate inner contair.er must restrict the loss of plutonium to not more than A in2 1 week.

4.5 Appendix This appendix should include supporting information and analysis.

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5. SHIELDING EVALUATION This chapter of the application should identify, describe, discuss, and analyze the principal shielding design of the packaging, components, and systems important to safety and necessary to comply with the performance requirements specified in SS 71.47 and 71.51 of 10 CFR Part 71.

5.1 Discussion and Results Discuss the significant shielding design features of the package and the adequacy of the shielding evaluation. Table 5.1 should be completed. For pack-aging designed for spent fuel transport, assumed fuel burnup, power density, and cooling times should be stated.

5.2 Source Specification I

In thfs section, state the contents and the gamma and neutron source terms used in the shielding analysis. (Address any increase in source terms with time.)

5.2.1 Gamma Source State the quantity of radioactive material included as contents, and tabu-late the gamma decay source strength (MeV/sec and photons /sec) as a function of photon energy. Describe in detail the method used to determine the gamma source strength and distribution.

5.2.2 Neutron Source State the quantity of radioactive material included as contents, and tabu-late the neutron source strength (neutrons /sec) as a function of energy.

Describe in detail the method used to determine the neutron source strength and distribution.

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TABLE 5.1

SUMMARY

OF MAXIMUM DOSE RATES l S 71.47 EXTERNAL RADIATION STANDARDS FOR ALL PACKAGES (mrem /hr) 1 Meter from Package Surface Surface of Package Side lop Bottom Side Top Bottom Normal Conditions Gamma Neutron Total Hypothetical Accident Conditions Gamma Neutron Total 10 CFR Part 71 Limit ---- ---- ----

1000 1000 1000 5.3 Model Specification In this section, describe the model that was used in the shielding evaluation.

5.3.1 Description of Radial and Axial Shielding Configuration Include sketches, to scale, and dimensions of the radial and axial shield-ing materials. Dose point locations for the various calculations exterior to the package should be shown relative to the source regions in the sketches supplied. Voids or irregularities not taken into account in the model should be discussed in detail showing that the resultant dose rates are conservative.

Differences between the models for the normal conditions and the accident condi-tions of transport should be clearly identified.

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5.3.2 Shield Regional Densities The material densities (g/cm )3 and the atomic number densities (atoms / barn-cm) for constituent nuclides of all materials used in the calculational models for the normal and accident analyses are to be given in this paragraph. The source of the data for uncommon materials should be referenced.

5.4 Shielding Evaluation Provide a general description of the basic method used to determine the gamma and neutron dose rates at the selected points outside the package for both the normal and accident conditions of transport. This should include a description of the spatial source distribution and any computer program used, with its referenced documentation. The basic input parameters should be dis-cussed in detail. The basis for selecting the program, attenuation and removal cross sections, and buildup factors should be provided. Flux-to-dose rate conversion factors as a function of energy should be tabulated. Data are to be g supported by appropriate references.

5.5 Appendix This appendix should include information such as justification of assump-tions or analytical procedures, test results, photographs, computer program descriptions and input / output, and applicable pages from referenced documents.

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6. CRITICALITY EVALUATION This chapter of the application should identify, describe, discuss, and analyze the principal criticality engineering physics design of the packaging, components, and systems important to safety and necessary to comply with the performance requirements specified in SS 71.55, 71.57, 71.59, and 71.61 of 10 CFR Part 71. These requirements are summarized in Table 6.1.

6.1 Discuseion and Results Discuss the significant criticality design features of the package and the adequacy of the criticality evaluation. Table 6.2, summarizing the criticality evaluation, should be included in this section.

6.2 Package Fuel Loading I

Provide a summary table stating the maximum fuel loading and fuel parameters for the package for normal and accident conditions of transport.

6.3 Model Specification This section should describe the model used in the evaluation.

6.3.1 Description of Calculational Model Dimensioned sketches, to scale, or the geometric model used in the calcula-tion should be given. The sketch should identify the materials used in all regions of the model. Differences between the actual package configuration and the model should be identified, and the model should be shown to be conserv-ative. Differences between the models for the normal conditions of transport and the accident conditions of transport should be clearly identified.

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TABLE 6.1 REQUIRED NUMBER OF PACKAGES TO BE DEMONSTRATED AS SUBCRITICAL UNDER SPECIFIC MODERATION AND REFLECTION CONDITIONS PER l SECTIONS 71.55, 71.57, 71.59, AND 71.61 0F 10 CFR PART 71 CONDITIONS OF SHIPMENT Fissile Class Normal Conditions Accident Conditions (No more than 5% reduction in the (All packages damaged per total effective volume of the hypothetical accident (HA) packaging on which nuclear safety specifications.)

is assessed.)

I Unlimited number of packages are 250 packages are to remain to remain subcritical with opti- subcritical in any arrangement mum interspersed hydrogenous under HA conditions with optimum moderation. No water reflection interspersed hydrogenous necassary. moderation and close reflec-tion by water on all sides of array.

II Five times the number of packages Two times the number of to be shipped are to remain sub- packages to be shipped are to critical in any arrangement when remain subcritical in any this array is closely reflected arrangement under HA condi-by water. tions with optimum interspersed hydrogenous moderation and close reflection by water on all sides of array.

Since the maximum value of the Transport Index (TI) for an individual package of Fissile Class II is 10 and the TI equals 50 divided by the allowable number of packages, 5 is the smallest value for the maximum allowable number of packages in a shipment. Therefore, the minimum number of packages in the array that must be considered in the criticality analysis is:

5 x 5 or 25 packages 2 x 5 or 10 packages for normal transport for accident conditions III One shipment of packages is to One shipment of packages remain subcritical when it is in is to remain subcritical contact with an identical ship- under HA conditions with ment and the two-shipment array optimum hydrogenous modera-is reflected on all sides by tion and close reflection by water. water.

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TABLE 6.2

SUMMARY

OF CRITICALITY EVALUATION Fissile Class (I, II, III)

Fissile Class Normal Conditions I II III Number of undamaged packages calculated to be subcritical (Fissile Class I must be infinite; Fissile Class II must be at least 25; and Fissile Class III must be at least identical shipment.)

Optimum interspersed hydrogenous moderation (required for Fissile Class I)

Closely reflected by water (required for Fissile Classes II and III)

Package size, cm 3 Accident Conditions

} Number of damaged packages calculated to be subcritical (Fissile Class I must be at least 250; Fissile Class II must be at least 10; and Fissile Class III must be at least 1.)

Optimum interspersed hydrogenous moderation, full water reflection Package size, cma Other Transport Index (must not exceed 10 for Fissile Class II)

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6.3.2 Package Regional Densities The material densities (g/cm )a and the atomic number densities (atoms / barn-cm) for constituent nuclides of all materials used in the calculational models for the normal and accident analyses should be given. Fissionable isotopes should be considered at their most reactive credible concentration. Masses for all regions should be given consistent with atomic number densities and volumes occupied.

6.4 Criticality Calculation This section should describe the calculational or experimental method used to determine the nuclear reactivity for the maximum fuel loading or other maxi-mum contents loadings intended to be transported in the package.

6.4.1 Calculational or Experimental Method A general description of the basic calculational method used to calculate the effective multiplication constant of the package under the normal conditions of transport and accident conditions of transport to demonstrate compliance with the appropriate NRC regulations should be provided. This should include a description of the computer program and neutron cross sections used with their referenced documentation. The basis for selecting the program and cross sections should be discussed.

If an experimental method were used to determine the compliance of the pack-age with criticality requirements, include a complete description of the experi-ment and a discussion demonstrating that it conservatively takes into account the normal and accident conditions of transport for the package.

6.4.2 Fuel Loading or Other Contents Loadira Optimization Demonstrate that the correct fuel loading or other contents loading for the maximum reactivity has been evaluated for both the single package and arrays of packages for normal and accident conditions of transport. Approximations, 6-4

boundary conditions, calculational convergence criteria, and cross-section D adjustments should be itemized and discussed.

The requirements of S 71.55 of 10 CFR Part 71 should be satisfied for a single package. The requirements of SS 71.57, 71.59, or 71.61, as appropriate, should be satisfied for an array.

6.4.3 Criticality Results Results of the reactivity calculations establishing the most reactive configurations for the single package and arrays of packages for both normal and accident conditions of transport should be displayed in tabular and graphic form. Justification should be provided for any interpolations and extrapola-tions. A discussion of the validity and conservatism of the analysis should be included. The bias established with the benchmark calculations in Section 6.5 should be taken into account.

6.5 Critical Benchmark Experiments I

This section should provide justification for the validity of the calcula-tional method and aeutron cross-section values used in the analysis by presenting the results of calculations for selected critical benchmark experiments.

6.5.1 Benchmark Experiments and Applicability Provide a general description of selected critical benchmark experiments that are to be analyzed using the method and cross sections given in Section 6.4.1.

The applicability of the benchmarks in relation to the package and its contents should be shown. All similarities and differences should be noted and resolved respectively. References giving full documentation on these experiments should be provided.

6.5.2 Detai s of Benchmark Calculations Actual nuclear and geometric input parameters used for the benchmark cal-I culations should be provided.

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6.5.3 Results of Benchmark Calculations Provide the results of the benchmark calculations. Establish and provide a discussion of any calculational bias.

6.6 Appendix This appendix should include information such as justification of assump-tions or analytical procedures, test results, photographs, computer program descriptions and input / output, and applicable pages from referenced documents.

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7. OPERATING PROCEDURES This chapter of the application should describe the operating procedures to be used in the preparation for and performance of the processes of loading and unloading the package. The discussion of these procedures should be presented sequentially in the actual order of performance. At a minimum, this chapter should demonstrate the ability to comply with the operating procedure require-ments specified in Subpart G to 10 CFR Part 71 and should also demonstrate that the procedures to be used will ensure that occupational radiation exposures are maintained as low as is reasonably achievable as required by paragraph 20.1(c) of 10 CFR Part 20, " Standards for Protection Against Radiation."

7.1 Procedures for Loading Package The discussion should include inspections, tests, and special preparations of the package for loading. This discussion on inspection should include those I

inspections made prior to loading the package to determine that the package is not damaged and surface contamination levels are within the allowable limits of the regulations. The procedures should discuss the inspection of gaskets, criteria for replacement, and, if applicable, procedures for repair. The inspec-tion of each closure device and criteria for replacement should also be discussed.

The preparation of the package for loading should be discussed. If special considerations on the use of lifting lugs are necessary, they should be stated here (e.g. , limits on the angle of lifting slings or other restriction on the use of the lifting lugs). When there are optional loading arrangements, each should be described and the need for internal bracing, shoring, or spacer devices should be addressed. Procedures that address the installation of the package closure should discuss the use of alignment guides such as guide pins or align-ment marks. The procedures should specify the torque requirements for the closure devices as well as any other threaded devices that are part of the containment boundary.

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The procedures should also address the need to use an appropriate pipe thread sealant where threaded pipe plugs are used to seal vent and drain line openings. Details should be provided for procedures used to remove residual moisture from cavities intended to be dry. The procedures should demonstrate that the requirement 5 of S 71.47 and paragraphs 71.87(i)(1) and (2) will be complied with prior to releasing the package for shipment.

7.2 Procedures for Unloading Package This section should include inspections, tests, and special preparations of the package for unloading. As applicable, the procedures used to ensure safe removal of fission gases, contaminated coolant, and solid contaminants should be discussed. Also as applicable, describe any required cooldown proce-dure, and show that it does not affect the continued use of the package. A statement should be made regarding compliance with the requirements of 6 71.89.

7.3 Preparation of Empty Package for Transport inis section should discuss the inspections, tests, and special prepara-tions of the packaging necessary to ensure that the packaging is properly closed, the requirements of paragraphs 71.87(i)(1) and (2) for non-fixed radioactive contamination limits have been met, and the packaging has been delivered to a carrier in such a condition that subsequent transport will not reduce the effec-tiveness of the packaging (e.g., damage to sealing surfaces caused by the freez-ing of moisture not properly removed).

7.4 Appendix This appendix should include supporting documentation, detailed discussions and analysis of procedures, and graphic presentations.

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8. ACCEPTANCE TESTS-AND MAINTENANCE ?ROGRAM This chapter of the application'should discuts the acceptance test and l

maintenanceprogramtobeusedonthepackaging,incompliancewithSubpartGl of 10 CFR Part 71.

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8.1 Acceptance Tests '

Discuss the tests to be performed prior to the first use of the package.

8.1.1 Visual Inspection The visual inspections to be performed and the intended purpose behind cach inspecticn should be discussed. State the criteria for acceptance for cach of these inspections as well as'tne action to be taken if noncompliance is encountered.

I 8.1.2 Structural and Pressure Tests Describe the tests to be performed. Present the acceptance criteria.

Describe the action taken when the prescribed criteria are not met. An estimate of the sensitivity of the tests should be provided.

8.1. 3 Leak Tests s Describe the leak tests to be performed. Leak tests should be performed on the containment vessel as'well as auxiliary equipment such as shield tanks.

Describe the criteria for acceptance and the action to be taken if the criteria are not met. Estimate the sensitivity of these tests, and give the basis for the esticate.

8.1.4 Component Tests I

Discuss the tests for those components to be tested. Provide acceptance criteria and discuss the action to be taken if the criteria are not met. '

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8.1.4.1 Valves, Rupture Discs, and Fluid Transport Devices. These compo-nents should be tested under the most severe service conditions for which the package design assumes their acceptable performance. When the tests are pre-sumed to adversely affect the continued performance of a component, the results of tests on ccmponents of the same model and type may be substituted.

8.1.4.2 Gaskets. Gaskets should be tested under conditions simulating the most severe service conditions under which the gaskets are to perform.

Since these acceptance tests may degrade the performance of either the gasket under test or the package into which it is assembled or both, the tests are not necessarily performed on gaskets or packages to be put into service. The sim-ulation system must ensure adequate representation of those conditions that would prevail if the actual system were used in the test. Gaskets must be procured under a quality assurance program adequate to ensure that acceptance testing of a given gasketing device is equivalent to acceptance testing of all gaskets supplied and identified by that manufacturer as that model gasket.

8.1.4.3 Miscellaneous. Any component not listed in paragraphs 8.1.4.1 -

and 8.1.4.2 whose failure would impair the package effectiveness should be tested under the most severe conditions for which it was designed. Since these acceptance tests may degrade the performance of either the component under test or the system into which it is assembled or both, the tests are not necessarily performed on components or systems to be put into service. The simulation sys-tem should ensure adequate representation of those conditions that would prevail if the actual system were used in the test. Furthermore, components must be procured under a quality assurance program adequate to ensure that acceptance testing of a given component device is equivalent to acceptance testing of all devices supplied and identified by that manufacturer as that model device.

8.1.5 Tests for Shielding Integrity Discuss the tests to be performed to establish shielding for both gamma and neutron sources. The discussion should include the dimensions of the grid pattern or a description of the scanning procedure that demonstrates the inspection of 100 percent of the package surface area. The acceptance criteria y as well as the action to be taken if the criteria are not met should be described.

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8.1. 6 Thermal Acceptance Tests Discuss the tests to verify that each package performs, within some defined variance, in accordance with the results of the thermal analyses or tests for i norms 1 conditions of transport.

8.1.6.1 Discussion of Test Setup. Describe the tests. The description should include heat source, instrumentation, and schematic showing thermocouple and heat source locations as well as the placement of other test equipment.

Estimate the test sensitivity Lased on instrumentation, test item, and environ-mental variations.

8.1.6.2 Test Procedure. Discuss the procedures used in testing and data recording. Report the frequency of data recording during the test. The criteria used to define the steady-state (thermal equilibrium) condition of the test item should also be discussed.

8.1.6.3 Acceptance Criteria. Discuss the thermal acceptance criteria and

} the method employed to compare the acceptance test results with predicted ther-mal performance. Discuss the action to be taken if the thermal acceptance criteria are not met by a packaging unit.

8.2 Maintenance Program This section should describe the maintenance program used to ensure contin-ued performance of the packaging. The program should include periodic testing, inspection, and replacement schedules as well as criteria for replacement and repair of components and subsystems on an as-needed basis.

8.2.1 Structural and Pressure Tests Describe the tests to be performed and the frequency of performance. The instrumentation and test sensitivity should also be described.

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8.2.2 Leak Tests I

Describe the tests to be performed and the frequency of performance. Esti-mate the sensitivity of these tests. For most systems, this would include a test of each package before each shipment and an annual test of each packaging.

8.2.3 Subsystem Maintenance Describe the test and replacement schedule to be used for packaging subsys-tems (e.g., auxiliary cooling systems and neutron shield tanks) whose inadequate performance could impair the total package safety. Justify the schedules estab-lished, using verifiable test or manufacturers' data.

8.2.4 Valves, Rupture Discs, and Gaskets on Containment Vessel Specify the test and replacement schedule to be used for these components.

Justify the schedules established, using verifiable test or manufacturers' data. For most systems, this would include as a minimum a visual inspection prior to each closure and an annual gasket and seal replacement. I 8.2.5 Shielding Describe the test and inspection schedules as well as the corrective action to be used to ensure adequate shielding performance. Both gamma and neutron sources should be considered.

8.2.6 Thermal Describe the tests proposed and the frequency of these tests that would be performed on the total system. Show that the proposed test frequency will detect degradation in the thermal performance of the packaging prior to compro-mise of the package safety.

8.2.7 Miscellaneous

, Describe any additional test not considered previously that should be per- l 1

formed periodically on components and subsystems.

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I DRAFT VALUE/ IMPACT STATEMENT

1. PROPOSED ACTION 1.1 Description There is a need to ensure completeness for collecting and presenting information needed on Part 71 applications for approval of packaging for radioactive material.

Proposed Revision 2 to Regulatory Guide 7.9 has been compiled by the NRC staff as an aid in the preparation of applications for approval of packaging to be used for the shipment of type B and fissile radioactive material. It is not intended as an interpretation of Commission regulations, within the m.aning of SS 30.5, 40.6, 70.6, or 71.2 of Parts 30, 40, 70, or 71, j respectively, of Title 10 of the Code of Federal Regulations (10 CFR).

Nothing contained in this guide may be construed as having the force and effect of NRC regulations, as indicating that applications supported by safety analyses and prepared in accordance with the recommendations of this regulatory guide necessarily will be approved, or as relieving any licensee from the requirements of 10 CFR Parts 30, 40, 70, and 71 and any other pertinent regulations.

1.2 Need for Proposed Action The purpose of the proposed action, issuance of a proposed Revision 2 to , l R::gulatory Guide 7.9, is to establish a uniform format for presenting the information needed in 10 CFR Part 71, " Packaging and Transportation of Radio-active Material." Use of this format will help ensure the completeness of the information provided, assist the NRC staff and others in locating the informa-tion, and aid in shortening the time needed for the review process. The application is the principal document in which the applicant or licensee I provides the information and bases for the NRC staff to determine whether or not the package meets the requirements of 10 CFR Part 71.

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1.3 Value/ Impact of Proposed Action l

, The principal advantage of accomplishing the proposed action would be to l

[ establish an acceptable standard format for identifying both general and f detailed information to ensure packaging approval of type B and fissile radioactive material under 10 CFR Part 71. There are no obvious disadvantages to the applicant or licensee in complying with this revision since lack of information in an application will only extend the review process on the part of the NRC. The review process extension would be initiated in the form of deficiency letters to the applicant or licensee. It is expected that the l proposed action will eliminate at least one round of questions covered by a deficiency letter. A round of questions consists of preparation of a deficiency I letter by the NRC, a preparation and submittal of a response by the applicant or licensee, and a subsequent review by the NRC. Without the proposed revision, applications submitted for review and approval will be uneven in information content and could lengthen the NRC review process.

1.3.1 NRC Operations The proposed revision complies more closely with the intent of Commission I regulations in 10 CFR Parts 30, 40, 70, and 71, respectively. The proposed action should speed up the NRC review process by eliminating some questions raised in the first review of the application.

1.3.2 Other Government Agencies Planning and implementation of procedures for the proposed Revision 2 of Regulatory Guide 7.9 may also be followed by the Department of Energy (00E) and Naval Reactors (NR). It is anticipated that this revision will impact DOE and NR no dif ferently from other applicants or licensees.

1.3.3 Industry The proposed action should (1) reduce the applicant's or licensee's need for resources in responding to additional rounds of questions and (2) shorten the overall approval process anywhere from 3 to 6 months per application.

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1.3.4 Public I

The general public will not be affected by the proposed action.

1.3.5 Regulatory Efficiency The proposed action will result in improvements in industry reporting and testing requirements. While this attribute is difficult to quantify, it is expected that industry costs affecting report preparation and NRC's costs of processing and storing information contained in these reports would be ,

reduced.

l 1.4 Decision on Proposed Action The proposed action provides impacts that are not easily quantified.

However, NRC should revise Regulatory Guide 7.9 to bring it into conformity with the Nuclear Waste Policy Act of 1982 and to include additional necessary information.

2. PROCEDURAL APPROACH I

2.1 Procedural Alternatives Other than status quo, there are no alternatives in the guidance for the preparation of applications for approval of packaging to be used for the shipment of type B and fissile radioactive material. The proposed Revision 2 to Regulatory Guide 7.9 is directed toward ensuring completeness of the information provided by the applicant or licensee in the application and avoiding confusing or ambiguous statements that do not contribute to its expeditious technical review.

2.2 Value/ Impact of Procedural Alternatives The only alternative considered is not to adopt the revision (i.e., main-tain the status quo). Since the effect of the action is measured in terms of the change from the existing condition, the status quo is automatically considered.

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2.3 Decision on Procedural Approach I

The procedural approach specified in Section 1.1 should be undertaken based on the decision of the proposed action in Section 1.4.

3. STATUTORY CONSIDERATIONS 3.1 NRC Authority The requirements of 10 CFR Parts 30, 40, 70, and 71 and any other pertinent regulations provide the basis for this proposed action.

3.2 Need for NEPA Assessment Issuance or amendment of guices for the implementation of regulations in Title 10, Chapter I, of the Code oi Federal Regulations is a categorical exclusion under paragraph 51.22(c)(16) of 10 CFR Part 51. Thus, an environmental impact statement or assessment is not required for this action.

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4. RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES The proposed Revision 2 to Regulatory Guide 7.9 develops an effective .

l interface between the licensee and the NRC in determining whether applications h for approval of packaging for radioactive material meet the requirements of 10 CFR Part 71. It also parallels to a large extent the international regulations set forth by the IAEA. These are described in " Safety Series #6, IAEA Safety Standards, Regulations for Safe Transportation of Radioactive Material, 1985 Edition."

5.

SUMMARY

AND CONCLUSIONS The proposed Revision 2 to Regulatory Guide 7.9 on applications for approval of packaging for radioactive material will enhance the quality and completeness of the application and shorten the NRC review process considerably.

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