ML20206K777
| ML20206K777 | |
| Person / Time | |
|---|---|
| Site: | 07109019 |
| Issue date: | 05/06/1999 |
| From: | Kobetz T NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Shankman S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| TAC-L22865, NUDOCS 9905130282 | |
| Download: ML20206K777 (11) | |
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- MEMORANDUM TO: Susan F. Shankman, Deputy Director Licensing and Inspection Directorate Spent Fuel Project Office, NMSS FROM: Timothy J. Kobetz, Project Manager ORIGINALSlaTDBY/s/
Spent Fuel Licensing Section Licensing and Inspection Directorate Spent Fuel Project Office, NMSS
SUBJECT:
SUMMARY
OF THE APRIL 7,1999, MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND BWX TECHNOLOGIES, INC. CONCERNING THE USE OF THE BU-7 SHIPPING PACKAGE (L22865)
On April 7,1999, a meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and BWX Technolcgies, Inc., (BWXT) to discuss issues pertaining to a potential, one time shipment of low-enriched uranium powder and pellets in approximately 1100 BU 7 shipping packages. An attendance list is included as Attachment 1. This meeting was noticed on March 24,1999, and open to public observation.
BWXT initially met with NRC on March 18,1999, to discuss corrosion problems associated with the BU-7 transportation package. Specifically, BWXT plans to seek an exemption from certain NRC requirements to allow it to ship the BU-7 package with minor corrosion on the package container. At the April 7,1999, meeting, BWXT presented an overview of how the BU-7 package would be refurbished and tested to demonstrate that, notwithstanding the corrosion, the package would still meet the 10 CFR Part 71 requirements for normal conditions of transportation and hypothetical accident conditions. The material presented by BWXT during this meeting is included as Attachment 2.
BWXT is still evaluating its options with regards to requesting an exemption or selecting an alternate package to ship the low-enriched uranium powder and pellets.
No decisions or ccmmitments were requested of or made by the staff. Please contact me if you wish to discuss these issues.
Docket No.: 71-9019 Attachments: 1. Attendance List o I
- 2. BWX Technologies, Inc., Handouts OD s DISTRIBUTION:
Docket PUBLIC NRC File Center NMSS R/F SFPO R/F PEng EEaston LKokajko SGagner, OPA EWBrach ELeeds NRC Attendees SShankman NOsgood G:\BWXT\BWXT0407.wpd Proofed by JPH 5/4/99
' ' OFC: SFPO SFPO E SFPO M NAME: k % ,.,, RCh DATE: 5/(,/99 5/ @/99 5/h9
, FICIAL RECORD COPY 4 '. i Ng'
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9905130282 990506 A 071
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1 Attachment 1 Attendance List 1
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ATTENDANCE LIST April 7,1999, Meeting between Nuclear Regulatory Commission Staff l and BWX Technologies, Inc.
Name Affiliation Wayne Hodges NRC/NMSS/SFPO Ross Chappell NRC/NMSS/SFPO Tim Kobetz NRC/NMSS/SFPO Kim Gruss NRC/NMSS/SFPO l Bernie White NRC/NMSS/SFPO
- Chris Brown NRC/NMSS/SFPO l
Al Thompson BWX Technologies, Inc.
Preston Foster BWX Technologies, Inc.
l Jim Creasey BWX Technologies, Inc.
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Attachment 2 BWX Technologies, Inc. Handouts
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. EXEMPTION REQUEST TO PERMIT A ONE TIME USE TO SHIP, WITHIN EIGHT l MONTHS,762 BU-7 SHIPPING CONTAINERS CONTAINING 4%UNH PRODUCT TO )
A DOMESTIC CUSTOMER l
l NEED BWX Technologies, Inc. (BWXT) currently has 762 BU-7 shipping containers loaded with 4%
UNH product and stored under IAEA safeguards. USEC, the owner of the 4% product, notified the BWXT a domestic customer has been identified and the customer would like to start receiving the 4% product soon. Shipments to the customer will be via exclusive use tansportation, which minimi= the amount of time the shipment is in mute.
HISTORY BWX Technologies (formally Babcock & Wilcox, Naval Nuclear Fuel Division), under contact to USEC, purchased 1187 USA /9019/AF, Model BU-7, shipping containers. On 1/13/99, during an IAEA audit, it was discovered that the containers exhibited excessive conesion.10 CFR 71.43(d) states in part: "A package must be made of materials and construction that assure that there will be no significant chemical, galvanic, or other reactions among the packaging components, among package contents, or between the packaging components and the package contents..." The physical conditions of the packages indicate that these requirements were not met in that a chemical reaction did occur between package components. All containers opened to date have exhibited this condition. Containers from three different storage conditions have been inspected. They are: (1) in trailers (2) in ventilated SEALAND containers and (3) in a shipping area under environmentally controlid conditions.
Conditions noted are as follows:
- The bolts holding the lid on the inner container are heavily corroded.
- The inside of the outer container lid has a " salt like" residue that is white in color and crystalline in nature. Some of this material exhibits blistering.
- All DP-40/DP401 painted surfaces exhibit blistering and corrosion exc:pt the top plug. (This plugis made ofphenolic foam). 5 e One container was dissected to inspect the condition of the inner wall o f the outer container and the outer wall of the inner container. These metal surfaces, which were in direct contact with the foam, contained surface rust that did not appear to dminish the wall thickness.
- There was no conosion detected inside the inner container.
This contaner is a 55 gallon outer container with a 18 gallon inner container. The inner container is cented within the outer container and held in place by hardened phenolic foam that gives the fissile payload the proper geometry to prevent criticality. Five gallon buckets containing the radioactive material are placed in the inner container. This bucket has a closure ring installed.
Containment of the 18 gallon inner container is achieved with the use of a rubber gasket that is sandwiched between the flange and the lid. This is sealed by 8 bolts. The space between the
. HYPOTHETICAL ACCIDENT CONDITIONS 10 Clm 71.73 TEST B&W Method of Compliance COMMENTS l 10 CFR 71.73,(c)(1) !
FREE DROP -30 ft. BWXTproposes to drop a ,
container from 30 ft. onto the l
, bottom followed by the puncture !
! test. The angle will be over the ;
center of gravity. This is consistent {
With the original testing. le.two containers were used. Test results from the 1st drop willbe included in the report -
CRUSH TEST This test was not performed on the original g+"== It is BWXT's interpretation that all3 of the conditions in 10 CFR 71.71(c)(2) must be present before this is required (i.e. contents will not be >
1000 ^2 l l
PUNCTURE TEST Puncture test willbe performed subsequent to the 30 ft. drop test onto the bottom of the container.
THERMAL TEST Use original tesuesults.
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10 CFR 71.73,(c)(5&6)
IMMERSION TEST-FISSILE Water inleakage has been assumed MATERIAL in the criticality analysis. Original test results will be used..
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. NORMAL CONDITIONS OF TRANSPORT 10 CFR 71.71 l l
TEST B&W Method of Compliance COMMENTS !
10 CFR 71,71 (c)(1) i HEAT Temperature addressedin the 1980 submittal (130'F)is within normal range for materials of construction.
Observed conditions do not affect this conclusion. ,
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COLD Temperature of-40'F is within i normal operating range for I matenals of construction. Observed - i conditions do not affect this l conclusion l l
REDUCED EXTERNAL Original test results willbe used. l PRESSURE l l
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INCREASED EXTERNAL Original test results will be used.
PRESSURE j l
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10 CFR 71.71 (c)(5) i VIBRATION Containers of this type have !
withstood years of transport with no occurrences ofsignificant damage due to normal vibration. Observed conditions do not affect this '
conclusion. i I
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. NORMAL CONDITIONS OF TRANSPORT 10 CFR 71.71 TEST B&W Method of Compliance COMMENTS
WATER SPRAY Water inleakage has been assumed ;
in the criticality analysis. Original l test results will be used.
10 CFR 71.71 (c)(7) l FREE DROP TEST- 4 ft. ' Itis container with the condition has successfully survived s 30 ft drop test. This test is not needed. ,
CORNER DROP Not required since package weight exceeds 110 lbs.
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COMPRESSION TEST Original test results willbe used.
l 10 CFR 71,71 (c)(10)
PENETRATION 1EST BWXTproposes to perform this test.
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inner container lid & the outer container lid is occupied by a removable, hardened, phenolic foam plug. All metal parts are manufactured of mild steel. The bolts are zinc coated.
General Electric (Wilmington) was the owner of this certificate. GE, in a report to the NRC dated 2/10/99, requested the withdrawal of this Certificate of Compliance.
TECHNICAL CONSIDERATIONS BWXT has refurbished a container and performed a 30 ft. drop test followed by a puncture test.
Based on the initial results identified below and subsequent testit.g, as defined in this meeting, an exemption from 10 CFR 71.43 (d) is requested. Technical basis for exemption is as follows:
- Accelerated corrosion attack is isolated to the material with DP-40/DP401 epoxy. This is a superficial condition. Clean up verified this.
- Bolts are the first things to start corroding. BWXT will replace bolts
. Sidewall thickness was determined using a hand held ultrasonic (UT) gauge. The gauge of the material had not changed.
. Sidewalls cannot corrode further because no source of oxygen.
- Containers were observed with high chlorine foam and no paint for protection.
These containers reached a point of equilibrium.
- A 30 foot drop test wr3 performed followed by the 1 meter puncture drop. Both were successful. NOTE: the c ylinder was welded to the pad. Weight used in the drop test was ultra conservative.104.8 lbs. per inner wntainer vs. approximately 45 lbs. actual. Total weight of the drums was 15 lbs. more than any previously tested weight. .
SEE ATTACHMENTS TITLED " HYPOTHETICAL ACCIDENT CONDITIONS 10 CFR l 71.73" AND " NORMAL CONDITIONS OF TRANSPORT 10 CFR 71.71". j REGULATORY CONSIDERATIONS l
SEE ATTACHMENT TITLED "NRC EXEMPTIONS UNDER 10 CFR 71.8" 10 CFR 71.43(d) states: "A package must be made ofmaterials and construction that assure that there will be no significant chemical, galvanic, or other reactions among package contents, or between the packaging components and the package contents, including possible reaction resulting from in leakage of water, to the maximum credible extent. Account must be taken of the behavior ofmaterials under irradiation."
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BWXT proposes a one time exemption to the above regulation in order to ship 762 BU-7 containers. Shipment will be within 8 monds. The shipment will be exclusive use to a domestic destination. Immediately prior to shipment, BWXT will.
- Refurbish and repaint e Seal edges of outer and inner with water proof caulking
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- Replace existing bolts with stainless steel bolts & washers
- Check wall thickness on a random sample with " contact" UT unit ]
e NRC Resident observe (ifdesired) l I
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SUMMARY
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In conclusion, BWX Technologies, Inc. requests an exemption to the requirement of 10 CFR j 71.43 to allow the use of the 762 BU-7 shipping containers to be used to ship the 4% UNH l l product to a domestic customer. Based on the additional testing performed by the BWXT in i early March,1999, the refurbishment conditions proposed above, and the anticipated successful completion of the testing identified in this exemption, BWXT request the NRC approve a one time use of these BU-7 containers. BWXT requests this exemption be approved by May 1,1999, to support the anticipated need of USEC's customer.
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NRC EXEMPTIONS UNDER 10 CFR 71.8 Proposed Exemption (1) j Regulation j 10 CFR 71.43 " General standards for all packages (d) A package naast be made of materials and construction that assure that there will be no significant awe =1. galvanic, or other reaction among the packaging components, among ;
package contents, or between the packagmg components and the package contents, including possible reaction resultmg f! rom inleakage of water, to the mnimum credible extent. Account must be taken of the behavior of materials under irradiation."
,jaEE section3.1 Ibere are no components of the r Mia or its contents which are subject to chenucal or galvanic reaction during normal transportation."
.EABE Section 5.3.1 "The BU-7 outer drum and cover are !=,- ved to assure "
- Good adherence of paint ( NOTE: refurbishment will take care of this.)
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Discuss (1) l 10 CFR 71.12 General License: NRC Approved Package 71.12 (c) This general license applies to a licensee who- ,
(2) Complies with the terms and conditions of the heense, cernficate, or other l approval, as ... applicable ".........
(QUESTION) Is this exemption considered as "other approval" or is a specific license required?
(2) 10 CFR /71.87 " Routine determinations Before each shipment oflicensed material, the licensee shall ensure that the package with its contents satisfies the applicable requirements of this part and of the license. The licensee shall determme that-(b) The package is in unimpaired physical condition except for superficial defects such as marks or dents; (QUESTION) : Doesn't the refurbishment and the test performed in the process of acquirmg this exemptice prove the package is in i.n... -64 condition?
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