ML20196B165

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Requests Addl Info Re Application Dtd 981118,requesting Coc for Sterigenics Eagle Transportation Package.Info Should Be Provided within 60 of Ltr & in Form of Revised Pages
ML20196B165
Person / Time
Site: 07109287
Issue date: 06/16/1999
From: Steven Baggett
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Clark G
PACKAGING TECHNOLOGY, INC.
References
TAC-L22770, NUDOCS 9906230105
Download: ML20196B165 (4)


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l' I. . *

, , June 16, 1999 a

i Mr. Gary L. Clark Fax # 253-922-1445 '

i - Vice President, Operations Packaging Technology, Inc.

l 4507-D Pacific Highway East Tacoma, Washington 98424-2633

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE STERIGENICS EAGLE TRANSPORTATION PACKAGE (TAC NO. L22770)

Dear Mr. Clark:

This refers to your application dated November 18,1998, requesting a Certificate of Compliance for the SteriGenics Eagle transportation package.

In connection with our review we need the information identified in the enclosure to this letter.

Please provided this information within 60 days of the date of this letter. The additional information requested by this letter should be in the form of revised pages. If you have any questions regarding this matter you may contact me at (301) 415-8584.

Sincerely, ORIGINAL SIGNED BY /s/

Steven Baggett, Senior Project Manager Licensing Section Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Docket No. 71-9287 cc En : Er c eers, SteriGenics Fax # 510-266-5566 l DISTRIBUTION:

NRC File Center Public Docket SFPO r/f NMSS r/f Electronic Dist:

SShankman ELeeds EEaston WHodges jl

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/1 File Name/ Location (G:\ G:\SFLS\ sib \9287RAl1.ltr) Secy initials /date kY OFC: SFPQj M SFPO C N l

SFPO SFPO SFPO /) 6 l NAME: SBaggett ERZieglek CBrown (h' BWhite hh LYan h DATE: IM/$9 SM99 5gf99 ggs ec)499 OFC: SFPO E SFPO f SFPO 6 NAME: C8ajwah ELeeds [ CRChappeld/O DATE: I/899 M99 (,//(/99 OFFICIAL RECORD COPY 9906230105 990616 7 PDR ADOCK 07109287' .o h C PDR2 .'

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Enclosure to Letter Dated: 06/16/1999 l DRAWINGS

1. Provide revised drawings to A. specify the dimensions and tolerances of the lead plates that may be used as an alternative to the cast lead in the lid and the base, B. clarify whether A 276, Type 304 stainless steelis an optional material for A-240, Type 304 stainless steel, C. Include the maximum weight of the package, and clarify the correct torque for the closure lid bolts. Drawing SAR 98003, Sheet 1, is inconsistent with the value on page 7.1-2 of the operating procedures.
2. Provide a drawing or sketch that depicts the personnel barrier described in Section 3.1.2.2 that includes the following: 1) all the necessary dimensions and specificctions;
2) how the barrier is attached to or set around the cask; and 3) material specifications for the barrier.

STRUCTURAL

1. Provide a summary of the maximum stress intensities of the cask body, cask lid and lower closure plate of the finite element analysis, under the accident drop conditions.

The summary should include loading conditions, maximum stress location, and stress intensity category. Provide tables which show the combined maximum stress per load combinations specified in Regulatory Guide 7.8. Show that the combined stresses are l within acceptable limits. '

2. Provide a summary comparison between impact limiter deformations from the dynamic test and the analytical results based on the finite element method.
3. Provide a summary evaluation of damage, including lead slump, to the cask body due to end, side, corner 30-foot drop and the 40-inch puncture tests; and show that the structural integrity of the cask is not impaired.
4. Justify the use of ASTM specification no. A-774 for the impact limiter. The ASTM specification A 774 considers tubular fittings with nominal thicknesses up to % -inch, but not 3/4-inch. Further, the specification does not include Type 304. stainless weel.
5. Provide an assessment of the potential for corrosion or sensitization of the stainless steel special form capsules and stainless steel basket under normal conditions of transport. (See NRC Information Notice 96-54," Vulnerability of Stainless Steel to Corrosion when Sensitized," dated October 17,1996.) A copy of the Information Notice can be found on NRC's vieb site (www.NRC Gov) in the reference library.

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, THERMAL

1. Figure 5.4-4, " Temperature Distribution within Cask for NCT," indicates that the model was done in ANSYS Version 5.4, whereas page 3.4-1 states that ANSYS Version 5.3 was used. Clarify this discrepancy.
2. Page 3.4-1, Section 3.4.1.1, states: "However, since the remaining 20% of the decay heat is distributed in significantly fewer capsules". This sentence is not complete.

Complete this sentence.

3. Table 3.5-2 indicates that the Maximum Transient Temperature for the Cask Lid Seal is 475 *F, whereas on page 3.5-2 it states that "The peak seal temperature is 513*F."

Clarify this discrepancy.

4. Justify that 20% of the incident solar radiation is intercepted by the personnel barrier as stated in Section 3.4.1.1.2, if the personnel barrier is needed to meet the temperature limits for normal conditions of transport. As an alternative you may choose to omit the personnel barrier affects from the modeling.

SHIELDING

1. Provide a revised Section 5.3.1 of the application to show the detail of the model used to determine the dose rates due to streaming through the lid drain port, including the detector locations. Show that the dimensions used in the model maximize the gap between the lid drain port plug and the drain tube, (i.e., include the worst-case tolerances),
2. Provide a revised shielding evaluation for normal conditions of transport to show that there will not be any streaming paths through the lead plates, that may be used as an alternative to the to the cast lead, in the lid and the base. This should include minimum tolerances on the plates and maximum tolerances on the stainless steel shells of the lid and base. (See item No.1. A. under Drawings, above.)
3. Provide a revised Section 5.4.2 of the application to evaluate the dose rates that will occur as a result of the lead slump under the 30-foot drop test. This increase in radiation levels adjacent to the gap must be shown to meet the 1 Rem /hr limit at 1 meter in 10 CFR 71.51(a)(2).

OPERATING PROCEDURES

1. Provide a revised Section 7.1.1 regarding loading the SteriGenics Eagle Cask in a shielding pool. Specify a visualinspection of the package upon receipt and during removal of the personnel barrier and impact limiters. Provide a revised Section which includes procedures for thread lubrication and methods for inspection of the bolts, torque limits for the personnel barrier bolts, methods to verify package temperature limits, and proper placement of the O ring seals prior to shipment.

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. 2. Provide a revised Section 7.1.1 that expands the procedures regarding drying the cask cavity. The expanded procedures must allow the shipper to make a determination that the cask content is dry.

3. Section 7.1.2, item 6 appears to indicate that the vent port plug has a piug seal, yet  !

Section 7.1.1 did not contain an inspection requirement. Clarify this discrepancy.

Provide a revised Section which includes procedures for thread lubrication and methods for inspection of the bolts, torque limits for the personnel barrier bolts, methods to verify )

package temperature limits, and proper placement of the O-ring seals prior to shipment. )

4. Provide a revised Section 7.2 regarding procedures for unloading the package.

Specifically include procedure or special actions to be taken if the tamper indicating I device is not intact or surface contaminction or radiation survey levels are too high. The procedures shoutcl ttso ensure that the contents are completely removed from the package. The prou bre should call for a visualinspection of the package upon receipt and during removal of the personnel berrier and impact limiters.

5. Provide a revised Section 7.3 that provide sufficient detail to allow a user to properly prepare for transport of an empty package. This revised Section should specifically include procedures to: 1) ensure that the package meets internal and external contamination limits and levels,2) discuss properly labeling, and package assembly instructions including bolt torque specifications,3) verify that the package is empty, and )
4) any additional instructions you deem necessary. General references to appropriate requirements of 49 CFR are acceptable.

ACCEPTANCE TESTS Revise the Acceptance Tests ( Section 8.1) to include a thermal acceptance test that will be performed on each package before first use. Specify the details of the thermal acceptance test.

The test specifications should identify the heat load, the test duration, the test instrumentations, and the specific points for temperature measurement. Specify the numerical criteria for accepting or rejecting a packaging. Show that the acceptance crit:,ri: cre adequate to verify the thermal performance of the package and show how the criteria correlate to the thermal analysis in the application. Note that the criteria in paragraph 3.2.4 of NUREG/CR 3854 may be helpful.

MAINTENANCE PROCEDURES Section 8.2.3 addresses subsystem maintenance. Besed on this Section, provide revised Chapter 7 Operating Procedures to include inspection and replacement procedure for fasteners, seals areas and grooves, and impact limiter ball-lock pins.

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