ML20207P085
| ML20207P085 | |
| Person / Time | |
|---|---|
| Site: | 07109019 |
| Issue date: | 12/22/1986 |
| From: | Winslow T GENERAL ELECTRIC CO. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20207P087 | List: |
| References | |
| 27713, NUDOCS 8701150035 | |
| Download: ML20207P085 (9) | |
Text
'7/- ?dl9 RETUPR TO 396-5S GENERALh ELECTRIC p
NUCLEAR FUEL & COMPONENTS MANUFACTURING GENERAL ELECTRIC COMPANY
- P.b. BOX 780
- WILMINGTON. NORTH CAROUNA 28402 December 22, 1986 e
g ow RECEIVED g
Al DEC 2 91986 p/7 Mr. Charles E. MacDonald, Chief u.s.tscrEM Rtcuutayd Transportation Certification Branch NWsti Division of Fuel Cycle & Material Safety U. S. Nuclear Regulatory Commission j, udk b
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Washington, D. C.
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Dear Mr. MacDonald:
Subject:
NRC Certificate of Compliance USA /9019/AF
References:
- 4) Letter, TP Winslow to CE MacDonald, 7/11/86 On January 6, 1986, General Electric Company Nuclear Fuel &
Components Manufacturing submitted a Consolidated Application p
(Revision 0) for the BU-7 shipping package.
This package is d
authorized under the subject Certificate.
The application was prepared to demonstrate that the package meets requirements of 10 CFR 71 and, therefore, the package should be identified as complying with the " Safety Series No. 6, IAEA Safety Standards Regulations for the Safe Transport of Radioactive Materials, 1973 Revised Edition (As Amended)".
In response to a request from your office, on 2/7/86 GE supplied an analysis which demonstrates pellet criticality safety for bulk density greater than 4.2 grams UO /ce, for both normal and 2
accident conditions.
On 6/18/86, the NRC requested additional information.
This is included in Attachment 1 to this letter.
To facilitate NRC review, Consolidated Application, Revision 1, is enclosed.
The Consolidated Application has been revised as described in Attachment 2 to incorporate References 1 and 2 above, NRC requested changes, and GE revisions, including:
(1) Requested wording for authorized contents to be used in Paragraph 5(b), " Contents", of-tge Certificate of 14Q Compliance 0
tecmro (2) A new BU-7 drawing.
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O Mr. Charles E. MacDonald December 22, 1986 Page 2 A separate request referencing this submittal will be made to the Department of Transportation since it will be the IAEA Competent Authority Certification that reflects approval of this package to 1973 IAEA requirements.
General Electric personnel would be pleased to discuss this matter with you and your staff as you may deem necessary.
Very truly yours, GENERAL ELECTRIC COMPANY T. Preston Winslow, Manager Licensing & Nuclear Materials Management O
M/C J88 TPW/RHDF:bsd Attachments O
Mr. Chr E. MneDonald Daccabar 2, 1986 - Page 1 ATTACHMENT 1 GE-NFECM RESPONSE TU HIE TBYRTIFIED ITEMS, 6/18/86 NRC IDENTIFIED ITEMS, 6/18/86 GE-NFECM RESPONSE DRAWING 1.
General Electric Company The drawing has been revised in location D-6 by removing the Drawing No. 112D1592 should be "or equivalent" wording and replacing it with a Rule 40 steel revised to specifically list drum callout.
alternatives to the DOT Specification 17H steel drum.
The "or equivalent" specification should be deleted from the drawing.
2.
The identification plate on the The drawing has been revised in location C-4 to remove this package should be specified optional stainless steel plate callout.
such that the Model No.,
Identification No., and attachment will survive the fire test.
STRUCTURAL 1.
The Model No. BU-7 shipping Note 97 on the drawing identifies NRC requirement 10 CPR package does not incorporate a 71.43(b) for a tamperproof feature.
Cross reference to this tamperproof feature [10 CFR note is made in drawing location B-6/7.
Together they show a 571.43(b)).
tampersafe seal is used in conjunction with the 5/8" diameter bolt and nut that secures the closure ring.
2.
It is noted that the The identified inconsistency is due to (1) English system application uses both the callouts in US AEC Material & Equipment Specification SP-9 English System and the Metric for packaging and insulating weights and (2) Metric sy. stem System in the application.
callouts in NRC regulations for-reporting shipping data, as However, they are not used follows:
consistently throughout the l
Q Mr. Chc E. MacDonald t
t Dsc:cbor 22, 1986
. Attachment 1 - Page 2 l
i l
NRC IDENTIFIED ITEMS, 6/18/86 GE-NFECM RESPONSE l
l application, e.g.,
the gross o
SP-9 identifies component weight for the fire resistant weight of the package and the phenolic foam in terms of component weight per 100 lbsTof
- i density of the insulating media material.
I are given in the English System, whereas test weight of o NRC regulation 10 CFR 70.54 requires licensees to report the content is given in the shipments on the DOE /NRC Form-741 in grams.
Consequently-Metric System.
The units our in-house scales for determining the shipping weight j
should be consistent throughout for powders or pellets are in grams.
the structural section.
This inconsistency also exists in IAEA and NRC' certificates where the allowable gross weight of each package is expressed in pounds and the maximum quantity of material per package is expressed in kilograms.
Presumably, the expression of l
weights recorded in pounds on the container is for the benefit of domestic transporters who are most familiar with
)
this terminology and use it for determining safety limits i
when handling.
i j
3.
Table 4.1 indicates that the The chemical comp ~sition of the phenolic resin used in the o
density of the insulating media prototype testing is shown in Table 4.1 of the application.
l will be limited to i 1 lb/ft 3 The first footnote on this table shows the fabrication of 8 lb/ft 3; however, Table 4.1 callout of the density to be 8 1 1 lbs/ft 3
.This fabrication i
also indicates that the minimum requirement is also identified in Drawing No. 112D1592, permissible density can be as Section C-7, where the insulating media callout states that:
low as 4.8 lb/ft 3 This discrepancy should be
" Phenolic foam insulation (fire ret.) (7-9 lbs per addressed.
Furthermore, it is icu. ft.)
Phenolic foam shall be in accordance with not apparent what density of AEC Materials and Equipment Specification SP-9 or as the insulating media was used s modified by ORGDP Reports K/TL-729 and,K/P-6575.
in the' prototype testing program.
The density of the The second footnote on Table 4.1 identifies the minimum insulating media as used in permissible density of 4.8 lb/ft 3 from a criticality prototype testing should be evaluation standpoint;as shown on Table 6.10, Section A.
The
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Mr. Chcr E. MrcDonnld Dac:mb r 22, 1986 Attcchment 1 - Page 3 NRC IDENTIFIED ITEMS, 6/18/86 GE-NF&CM RESPONSE specified.
(Any deviation normal case K-effective with 60% of full density phenolic should be addressed.)
resin has been demonstrated by KENO IV calculations to be critically safe even if only 60% of the fabrication callout of 8 lbs is used (60% x 8 lbs = 4.8 lbs).
In summary, the density of foam in the container is 8
- 1 lb/ft 3 However, the criticality analysis shows the container would be safe if the density were as low as 4.8 lb/ft 3 4.
The application needs to assess If external pressure is reduced to 3.5 psia, a pressure the effects of external differential of 11.2 psi exists between the inside of the pressure reduced to 3.5 psia container and ambient conditions.
The BU-7 container is under normal conditions of tested to a 15 psig pressure differential per Note 1 of the transport.
drawing.
This testing thereby demonstrates compliance.
THERMAL Justify the adequacy of using four, Adequacy of the four 1/4 inch diameter vent holes was 1/4-inch diameter vent holes rather demonstrated in (Appendix 2) " Report of Package Evaluation than the 1/2-inch diameter vent Tests for the BU-7 Bulk Uranium Transport Package".
In this holes that had been previously test report, Section 1.2.1 identifies that the outer found acceptable for the DOT container of the BU-7s selected for testing contain four 1/4" Specification 6M package (49 CPR holes near the top of the container.
Results of the thermal S178.104).
test, as described in Section 3.2.3 of the test report, demonstrated functional adequacy of the 1/4" vent holes.
Mr. Cha h E. MccDonald O
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Dact bar 22, 1986 - Page 4 i
1 NRC IDENTIFIED ITEMS, 6/18/86 GE-NFECM RESPONSE l
l CRITICALITY 10 CPR S71.55(b) requires that a single package be suberitical for:
l The application did not establish (1) The most reactive credible configuration the suberiticality of the single consistent with the chemical and physical form of package [10 CPR 571.55(b)] for 00 the material; 2
pellets with fuel densities between (2) Moderation by water to the most reactive credible 4.5 and 9.39 gm/cc.
extent; and l
(3) Close reflection by water on all sides.
i The BU-7 certificate currently limits the bulk density of UO2
)
pellets to 4.2 gm/cc.
The application dated 1/6/86 as supplemented 2/7/86 removes this limit based on an analysis of the normal and shipping accident conditions at theoretical l
UO density (10.96 gn/cc) and at intermediate densities.
No 2
j demonstration of single package safety is provided for the amendment since optimum moderation occurs at a bulk density i
l of 4.5 gm/cc or less.
The single package safety is currently 1
i based on limiting the package to a quantity of UO 2 pellets not greater than 90% of the minimum critical mass for a j
specified U 235 enrichment.
This ensures subcriticality of the single package at optimum moderation and full water i
I reflection independent of the bulk density of the pellets.
No change is made to this limit in the above application and supplement.
p In the Consolidated Application, Section 2.7, " Package Description - Contents" has been changed to delete the bulk i
density limi,ts on pellet shipments and to clarify the wording of moderation limits for both powder and pellets.
Also, the i
i container mass limits have been changed to be consistent with analyses and testing as described in Appendices B-and C of the Consolidated Application.
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Q Mr. Cha E. MccDonald Decarber 2,
1986 - Page 5 i
NRC IDENTIFIED ITEMS, 6/18/86 GE-NFECM RESPONSE I
OPERATING PROCEDURES, ACCEPTANCE TERMING, AND MAINTENANCE PROGRAM i'
The application is incomplete in Chapter 5.0,
" Procedural Controls", of_the Consolidated that specific sections addressing Application has been retitled " Testing, Operating and detailed operating procedures, Maintenance" and has been expanded to include a more detailed acceptance testing, and maintenance description of these activities.
program have not been included in the consolidated application.
f DISCLAIMER 1
! C (NEDO-11277) contains NEDO-11277 has been deleted from the 12/22/86 Consolidated j
a Disclaimer of Responsibility on Application.
Criticality safety for the BU-7 is demonstrated i
the part of the General Electric by:
j Company and the author of the nuclear criticality safety analysis
- 1) Appendix C,
" Criticality Safety Analysis of BU-7 Shipping for the shipment of uranium oxide Container for UO Powder", 3/6/80, WC Peters.
2 pellets.
Contents and analysis for which the General Electric lompany
- 2) Appendix D,
" Criticality Safety Analysis - BU-7, does not assume responsibility will Theoretical Density", 1/24/86, JT Taylor.
be deleted from the application.
- 3) Appendix E, Table 4.4, Safe Batch Limits for UO and
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from NRC License SNM-1097, Condition 9, Part I.
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3 1
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GENER AL $ ELECTRIC Mr. Charles E. MacDonald g
December 22, 1986 ATTACHMENT 2 DESCRIPTION OF REVISIONS TO CONSOLIDATED APPLICATION Description General Throughout the application, cross references have been changed to correspond with Appendices A through E.
Pag e 11 Added a Table of Contents 3-5 Revised wording for authorized contents
()
5 Added paragraph for UO 2 powder with additives 15 - 16 Revised Chapter 5 to reflect testing, operating and maintenance of containers Appendix A
Added revised BU-7 drawing B&C Formerly Enclosures 1A and 1B, respectively, of Consolidated Application, Revision 0, dated 1/06/86 D
Submitted as supplemental information, 2/07/86 E
Added UO and H O Safe Baleh Limits table 2
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