ML20206P413
| ML20206P413 | |
| Person / Time | |
|---|---|
| Site: | 07105059 |
| Issue date: | 01/06/1999 |
| From: | Osgood N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Chappell C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9901110358 | |
| Download: ML20206P413 (14) | |
Text
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& UNITED STATES
{n j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 3088H001
%,,,,,/ * $0.5 January 6, 1999 MEMORANDUM TO: Cass R. Chappell, Chief I Package Certification Section, SFPO, NMSS FROM:
4W '
ancy L. Osgood, Senior Project Manager Package Certification Section, SFPO, NMSS i
SUBJECT:
MEETING
SUMMARY
REGARDING TRANSPORTATION REGULATIONS FOR ENRICHED URANIUM Attendees HBG Nuclear Fuel Services Ross Chappell Tom Baer Earl Easton Kenneth Hensley Wayne Hodges Neil Newman Neil Jensen William F. Kane Public Nancy Osgood Sidney Crawford David Tiktinsky
[
Introduction A meeting was held on December 17,1998, in Rockville, Maryland, at the request of l Nuclear Fuel Services (NFS). The meeting was held to discuss the use of the " unlimited" A 2value (10 CFR Part 71, Appendix A, Table A-1) for reprocessed uranium. In particular, NFS has proposed transporting reprocessed material for the Tennessee Valley Authority l (TVA) in the NFS Uranyl Nitrate Tank Trailer package (Certificate of Compliance No. 5059).
The package contents are limited to a Type A quantity of radioactivity.
Discussion NFS provided a proposed agenda for the meeting (Attachment 1). At the meeting NFS provided three additional handouts: "TVA Uranyl Nitrate Transportation" (Attachment 2),
I " White Paper on the impact on the Nuclear Fuel Production Industry of Restricting the Use of the ' Unlimited' A 2Valve [ sic] for Enriched Uranium Shipment" (Attachment 3), and the j
" Tank Trailer SAR Revision" schedule (Attachment 4).
A j
NFS stated that they believed that the TVA irradiated and reprocessed uranium material
'. AD can be transported with an unlimited A value. The material meets the definition of p unirradiated uranium that is currently in Department of Transportation regulations. NFS stated that if the A value 2 for enriched uranium is calculated based on all radionuclides present, that all shipments of uranium throughout the U.S. and Europe would be impacted, not just the shipment of TVA materialin the NFS package.
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, January 6, 1999 1 .
C. Chappell .
NRC staff stated that they believe that the transport of TVA irradiated and reprocessed material in the NFS Uranyl Nitrate Tank Trailer (Certificate of Compliance No. 5059) is outside the bounds of authorized contents for the package. NRC staff believes that for i irradiated and reprocessed materials that the A2 value is calculated based on all radionuclides present. However, staff recognizes that the regulations are not clear
)
regarding when the " unlimited" A2 value may be used.
1 NRC staff indicated that they are considering issuing an Information Notice describing how A2should bo determined for uranium. This would ensure a consistent interpretation throughout the fuel production industry. Prior to issuing the Information Notice, staff intends to present the information to the NRC Committee for Review of Generic !
Requirements (CRGR). NFS requested that they be allowed to provide their information to i CRGR. It was agreed that NFS would submit a document that will be included as '
background information for CRGR. Notwithstanding the staff's position, NFS was informed that they may request an exemption to 10 CFR Part 71 based on risk.
NFS stated they intend to respond to NRC's request for additionalinformation concerning NFS's application for renewal of the certificate for the NFS Uranyl Nitrate Tank Trailer package. A schedule was provided. l Docket No. 71-5059 Attachments: 1. Proposed Agenda for NRC/NFS Transportation Meeting
- 2. TVA Uranyl Nitrate Transportation
- 3. White Paper on the Impact on the Nuclear Fuel ProdJction Industry of Restricting the Use of the " Unlimited" A2Valve [ sic] for Enriched Uranium Shipment
- 4. Tank Trailer SAR Revision Distribution (with attachments): PUBLIC - Docket File 71-5059 Distribution (w/out attachments): Meeting Attendees Meeting Notebook SFPO r/f NMSS r/f "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFC NMSS/SFPO E NMSS/SFPO hl NMSS/SFPO G NAME YNLOsgood ERZiegler6&3 CRChell DATE l1/1S/98 of/04/99 /0/4/98 OFFICIAL RECORD COPY i
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.- +
C. Chappell . -
NRC staff stated that they believe that the transport of TVA irradiated and reprocessed material in the NFS Uranyl Nitrate Tank Trailer (Certificate of Compliance No. 5059) is .
- outside the bounds of authorized contents for the package. NRC staff believes that for irradiated and reprocessed materials that the A2 value is calculated based on all radionuclides present. - However, staff recognizes that the regulations are not clear 1, regarding when the " unlimited" A2 value may be used.
NRC staff indicated that they are considering issuing an Information Notice describing how A, should be determined for uranium. This would ensure a consistent interpretation throughout the fuel production industry. Prior to issuing the Information Notice, staff intends to present the information to the NRC Committee for Review of Generic Requirements (CRGR). NFS requested that they be allowed to provide their information to CRGR. It was agreed that NFS would submit a document that will be included as background information for CRGR. Notwithstanding the staff's position, NFS was informed that they may request an exemption to 10 CFR Part 71 based on risk.
NFS stated they intend to respond to NRC's request for additional information concerning NFS's application for renewal of the certificate for the NFS Uranyl Nitrate Tank Trailer package. A schedule was provided.
Docket No. 71-5059 Attachments: 1. Proposed Agenda for NRC/NFS Transportation Meeting i
- 2. TVA Uranyl Nitrate Transportation ;
- 3. White Paper on the Impact on the Nuclear Fuel Production industry of l Restricting the Use of the " Unlimited" A2Valve [ sic] for Enriched Uranium Shipment
- 4. Tank Trailer SAR Revision i
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! Proposed Agenda for NRC/NFS Transportation Meeting December 17,1998 l
l . Brief summary ofNFS Presentation (Sept. 9,1998) regarding the
- application of NRC regulation for shipment unirradiated (recycled)
! uranium solution.
. Reviews of NRC position on the use of" unlimited" as the A2
- values for enriched inadiated uranium shipments.
. Status of NRC plans and schedule for revising 10 CFR Part 71
., regarding compatibility with IAEA standards.
- Review NFS proposed schedule for providing information requested in NRC letter of October 1,1998.
.Y
. TVA Uranyl Xitrate Transportation
! TVA Project Background ;
i TVA has a MOL with DOE for the use of 33.3 MT of surplus HEL~
! TVA plans to downblend the HEL to LEE for nuclear fuel for its power reactors TVA issued a request for proposal (RFP) in January 1998 to prepare fuel assemblies NFS part of a consortium that has developed a proposal to TVA's .
RFP g
g DOE to prepare the LEU as uranyl nitrate at SRS. In our
} consortium's proposal, NFS to transport the uranyl nitrate to its p _
Erwin, TN site a
N
TVA Uranyl Nitrate Transportation '
Uranium Description .
The DOE surplus HEL~ is irradiated reactor fuel that has been reprocessed to remove fission and decay products and minimize transuranic isotopes Natural uranium will be used to downblend the HEL to LEL~ (4.95% L~-235) .
The activity level of the LEL~ allows the gs*
material to be categorized as unirradiated e per DOT definition,49 CFR 173.403
i TVA Uranyl Xitrate Transportation Uranium Description ;
DOE to prepare the LEL' as 90 gm L'/ liter uranyl nitrate (UX) at SRS -
- TVA's contractor to transport the LX to its site for conversion
. The LEEN is normal form radioactive material .
Expecting to transport 475 MTU (~400 shipments in XFS EN Tank Trailer) over 50 months j
x.y TVA Uranyl Nitrate Transportation Type A Quantity Determinatio11 Per Table A-1 in Part 71 the Type A quantity (A2 value) for enriched uranium 5% U-235 or less is unlimited ~
- SFS contends that the TVA LEUS~, fo:
determining A values will be a single radionuclide (enriched uranium), so, an unlimited quantity of the LEUX can be shipped in a Type A package -
subject to the limits of the package's certificate of compliance
TVA Uranyl Nitrate Transportation Type A Quantity Determination XRC staff contends that since the LEEK for: ;
the TVA Project will be derived from j irradiated uravinu the Type A quantity must be calculated from the analyzed .
activity of each radionuclide and the A2 value listed in Table A-1 of Part 71 for each . I radionuclide
1 q
TVA Uranyl Nitrate Transportation Type A Quantity Determination;
. To establish that the LX Tank Trailer will be the shipping package for transporting the LEUN from SRS to XFS' site, XFS requested the difference between the two positions be resolved l
. Resolution of the difference is requested in .
a timely manner to remove doubt as to the ability of Type A fissile shipping packages to meet the mission of TVA's program
White Paper on the !
IMPACT ON THE i
NUCLEAR FUEL i i
PRODUCTION INDUSTRY OF RESTRICTING THE USE OF THE " UNLIMITED" A2 VALVE FOR ENRICHED URANIUM SHIPMENT l
i i December 16,1998
. . _ . . . _ krT Aca MEhjT 3
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Solid and ' liquid low enriched uranium (LEU) has been shipped by the industry as fissile material in various Type A packages using the 2 A value of " unlimited" for enrichments up to 5%. Individual U isotopes have not been considered in the determination of the A 2 value. The material typically meets the DOT definition of "unitradiated uranium" because of the insignificant amounts of Pu and fission products.
Braeh Position NRC Spent Fuel Project Office (Transportation Branch) has recently said that " irradiated, recycled uranium" cannot be shipped using the A 2 value of " unlimited" for U enriched te 5%
or less. They have further stated that the presence of U2 u and U2 x in other than natural abuMaea requires shippers to use the " sum of the fractions" method for calculating the 2A value for shipping. They implied in a meeting that the " unlimited" 2A value could only be used when the material was the result of enrichment of " pure virgin natural U."
Discussion Uu2 and U x 2 are present in essentially all shipments of commercial LEU for reactor fuel in higher quantities than the natural abuMmea. The ASTM specification allows 2 U , and2 U x abnMaw*s substantially above natural abnMmeas.
Using the above stated Branch Position, (i.e., using the " sum of the fractions" method), most of the shipments of commerci31 fuel will be impacted, and d of the surplus HEU shipments, and d of the shipments of downblended material resulting from the surplus HEU, would be impacted Table 1 shows some selected Type A fissile packages and the maximum quantity of U (not U2u) that they could contain per the regulations or the Certificate of Compliance, and the maximum quantity that they could contain if the Branch Position were adopted.
Table 1 (kgs U)
Package BU7 5059 30 B UF. MCC3 '
Cylinder Maximum quantity with " unlimited" A2 value 1,543 36.6 1,424 837.3
" Sum of the fractions" quantity for ASTM spec limits 6.3 6.3 6.3 6.3 Sum of the fractions" quantity for typical commercial 6.9 6.9 6.9 6.9 fuel
As can be seen from the table, use of the Branch Position essentially eliminates efficient use of typical shipping containers for LEU and will dramatically increase shipping costs and the cost of fuel, t
Table 2 is a comparison of the weight percents of U isotopes in typical commercial LEU fuel, j the ASTM specification, and typical LEU resulting from downblended surplus HEU.
t Table 2 (wt % U)
! Fuel Type / Isotope i
Um Um Um Um l Natural Uranium .005 .715 .000 l 99.280 l Typical commercial fuel (5% enriched) .049 5 .013 94.939 i
l ASTM Specification limits (5% enriched) .055 5 .050 94.895 l LEU (5 % enriched) from downblended HEU .097 5 2 92.903 Table 3 is a comparison of the A2 values in curies and the number of curies of Um and Um that would be in selected authorized packages if 5% enriched materik! were at the ASTM spec l limits for these isotopes.
Table 3 i
Package / ASTM Spec Limits (Ci)
U Isotope A2(Ci) 30 B BU7 MCC3 5059 234 .027 5.26 .125 2.86 4.86 235 Unlimhed - - - -
236 .027 .050 .0012 .027 .046
! 238 Unlimited - - - -
1 It is important to note that the downblended surplus HEU does meet the DOT defm' ition of 4
"unirradiated" (i.e., not more than 10 grams Pu per gram of U-235 and not more than 0.24 millicuries of fission products per gram of U-235). The application of the " sum of the fractions" method for determining A 2essentially shuts down transportation of downblended
[ surplus HEU material in Type A pekages. There are not sufficient numbers of Type B
' packages available to transport the material. The dramatic increase in transportation cost calls into question the economics of usir.g "any" surplus material for reactor fuel. It does j
irreparable harm to competition and puts commercial recovery of surplus HEU out of business.
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