ML20210F320
| ML20210F320 | |
| Person / Time | |
|---|---|
| Site: | 07105942 |
| Issue date: | 01/10/1987 |
| From: | Audin L AFFILIATION NOT ASSIGNED |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20210F325 | List: |
| References | |
| 2.206, NUDOCS 8702110053 | |
| Download: ML20210F320 (3) | |
Text
10 January 1987 Director of Nuclear Material Safety and Safeguards U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Re:
Certification of.
Compliance No. 5942 Dear Sir; Pursuant to 10CFR2.206, I request a review of the Safety Analysis Report (SAR) for the GE-700 container (CoC #5942) with regard to evaluation of its puncture test analysis.
I believe the analysis of the cask with its extension may be deficient.
I therefore request that the cask be used only in its non-extended mode until it can be shown that the extended mode complies with all aspects of 10CFR71.
My concerns are based on a review of the Safety Analysis Report (SAR) for the GE-700 cask as developed in 1980 and the GE-100 cask as developed in 1968 If there are more recent SAR's that address my concerns, I would appreciate receipt of a copy of the relevant sections with your response to this letter.
I have three concerns related to the puncture test analysis.
1.
The GE-700 is a scaled up version of the much smaller GE-100.
The GE-100 was drop tested on the standard plug and (according to its SAR) "the protective jacket yielded on impact but no major fracture occurred.
No damage occurred to.the cask."
The GE-700 SAR utilizes this result as a scale model verification of its ability to withstand the puncture test.
The extended version of the GE-700, however, offers a potentially vulnerable point (i.e.,
the juncture between the extension and the main cask body) not present in the GE-100.
I therefore believe that the GE-100 puncture test cannot be used as proof that the extended version of the GE-700 has been tested in the most severe orientation for puncture.
2.
Use of the GE-100 test automatically takes credit for the lead shielding behind the cask's outer wall.
Most casks certified by NRC in the last 12 years have not taken credit for the puncture recistance of the lead.
I think this is a wise policy since recent findings (i.e.,
NUREG/CR-0930, 1980) indicate that casks with lead shielding are more readily punctured when their lead is softened or melted in a fire.
While I realize the testing standard assumes the puncture stress occurs before the thermal stress, reality could easily reverse the order of these events (e.g.,
a rail car collapsing in a fire tips over onto adjacent railroad tracks or reinforced protrusions).
I therefore believe the GE-700 puncture analysis should be re-evaluated for both the extended and non-extended versions.
M N
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- - 3.
NUREG/CR-0930 also found that the empirical analyses of past punctures were " crude and unreliable" and failed to give accurate results when tested against real punctures.
Since the l
scaling up of the GE-100 is dependent upon such analyses, I believe a proper puncture analysis should utilize the NIKE2D or similarly sophisticated computer simulation to be certain of i
its accuracy (NIKE2D was utilized in the 0930 study).
1 Please respond to each of these concerns separately and send me a copy of any changed license or other documents resulting j
from my request.
Thank you for your continued efforts toward transportation safety.
]
Yours truly, f
Lindsay Audin One Everett Avenue Ossining, New York 10562 3
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DISTRIBUTION: ED024796AeTnt.).
M@N iDocket F1Je;71-5942i' g
JGDavis Delausshardt RECunningham CEMacDona1d CRChappell EPEaston CJenkins (EDO 2479)
BClausser JLieberman, OGC WCParler, OGC JPHurray, OGC SSchidakel, OGC NMSS R/F FCTC R/F i