ML20216A494
| ML20216A494 | |
| Person / Time | |
|---|---|
| Site: | 07109218, 07109279 |
| Issue date: | 08/03/2020 |
| From: | Sellmer T Nuclear Waste Partnership |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML20216A493 | List: |
| References | |
| TS:20:03014, UFC:5822:00 | |
| Download: ML20216A494 (15) | |
Text
P.O. Box 2078 Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 Fax: (575) 234-7083 TS:20:03014 UFC:5822.00 August 3, 2020 ATTN: Document Control Desk Director, Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
REVISION 24 OF THE TRUPACT-II SHIPPING PACKAGE APPLICATION, DOCKET NO. 71-9218, AND REVISION 7 OF THE HalfPACT SHIPPING PACKAGE APPLICATION, DOCKET NO. 71-9279
Dear Sir or Madam:
Nuclear Waste Partnership LLC, on behalf of the U.S. Department of Energy (DOE), hereby submits Revision 24 of the application for a Certificate of Compliance (CoC) for the TRUPACT-II Packaging, U.S. Nuclear Regulatory Commission (NRC) Docket No. 71-9218, and Revision 7 to the application for a CoC for the HalfPACT Packaging, NRC Docket No. 71-9279.
The primary purpose of the application is to provide a path forward for the shipment of machine compacted waste in a criticality control overpack (CCO) provided that the amount of plastic per CCO is limited to a maximum of 2,000 grams. This extension of the previously approved CCO criticality analysis is needed for the shipment of over six metric tonnes of downblended surplus plutonium from the Savannah River Site (SRS). This is a program of high importance to the National Nuclear Security Administration (NNSA) and the DOE where an expedited approval of the application will support the near-term packaging of the waste form and future transport to and disposal of approximately 22,000 CCOs at WIPP.
In addition to the above, the following minor technical changes are also included in this application:
Consistent with the current criticality analysis, the pipe overpack criticality limits have been clarified to also accommodate machine compacted waste.
The CCO SAR drawing has been revised to incorporate minor fabrication enhancements that do not impact the safety basis of the packagings.
This letter includes a detailed summary of the technical changes discussed above in Attachment A - Summary of Revisions. Technical changes are indicated by rightbars in the margin of the submittal documents summarized below.
This submission contains files, one or more of which contains hyperlinks to other files or to Internet websites. These hyperlinks are either inoperable or are not essential to the use of the filing. Any material referenced by hyperlinks to Internet websites that was essential for use of this filing has been submitted as part of the filing. Any material referenced by a hyperlink to
Document Control Desk TS:20:03014 P.O. Box 2078 Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 Fax: (575) 234-7083 another file that was essential for the use of this filing has either been included by reference or submitted as part of this filing.
To facilitate implementation, it is requested that the current package CoCs be valid for use one year from the date of issuance of the revised CoCs.
If you have any questions regarding this submittal, please contact Kyle Moyant of my staff at (575) 234-7414.
Sincerely, T. E. Sellmer, Manager Packaging and Information Systems TES:clm cc: D. Standiford, CBFO J. A. Walker, CBFO K. Princen, CBFO J. Shuler, EM-4.24 J. Shenk, EM-4.24 L. F. Gelder, SRRC B. H. White, USNRC
Document Control Desk TS:20:03014 P.O. Box 2078 Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 Fax: (575) 234-7083 The following table summarizes the components of this submittal. No deviations occur from the NRC-prescribed PDF formatting for the submitted files. Please contact Ms. C. L. Morrison at (505) 878-1353 or cindy.morrison@wipp.ws to resolve any discrepancies in this submittal.
File Name File Size (MB)
Release Level Submittal Type 001 Transmittal Letter - August 2020.pdf 0.47 Publicly Available EIE 002 TRUPACT-II SAR R24 - August 2020.pdf 31.7 Publicly Available EIE 003 HalfPACT SAR R7 - August 2020.pdf 35.2 Publicly Available EIE 004 CH-TRAMPAC R5 - August 2020.pdf 5.44 Publicly Available EIE 005 CH-TRU Payload Appendices R4 - August 2020.pdf 24.0 Publicly Available EIE 006 CCO-CAL-0005 R0 - July 2020.pdf 0.26 Publicly Available EIE
ATTACHMENT A - Summary of Revisions August 2020 A-1 Summary Pg.
TRUPACT-II SAR, Revision 24, August 2020 A-2 HalfPACT SAR, Revision 7, August 2020 A-4 TRUPACT-II SAR Drawing, 2077-500SNP, Revision Z A-6 HalfPACT SAR Drawing, 707-SAR, Revision 10 A-6 Standard Pipe Overpack SAR Drawing, 163-001, Revision 8 A-6 S100 Pipe Overpack SAR Drawing, 163-002, Revision 6 A-6 S200 Pipe Overpack SAR Drawing, 163-003, Revision 5 A-7 S300 Pipe Overpack SAR Drawing, 163-004, Revision 3 A-7 Compacted Puck Drum Spacers SAR Drawing, 163-006, Revision 2 A-7 Shielded Container SAR Drawing, 163-008, Revision 3 A-7 Criticality Control Overpack SAR Drawing, 163-009, Revision 1 A-8 CH-TRAMPAC, Revision 5, August 2020 A-11 CH-TRU Payload Appendices, Revision 4, August 2020 A-12
ATTACHMENT A - Summary of Revisions August 2020 A-2 TRUPACT-II SAR, Revision 24, August 2020 Section Page Change Description Justification General Revised header for revision and date.
Administrative change. No impact to safety basis.
6.0 6.1-1 Revised summary descriptions of Cases E and I to remove limitation on machine compacted waste.
Additionally, for Case I, specified that machine compacted waste in each criticality control overpack (CCO) is limited to a maximum of 2,000 grams of plastic. Added Cases E and I to the list of cases that are applicable to machine compacted waste.
While the existing Case E criticality analysis for the standard, S100, S200, and S300 pipe overpacks encompass machine compacted waste, it was not previously identified as an inventory need. Revisions clarify that machine compacted waste in pipe overpacks is allowed subject to the currently authorized 200 FGE limit per pipe overpack.
The existing Case I criticality analysis for CCO payload containers is limited to manually compacted waste (i.e., not machine compacted).
Because the SRS excess plutonium waste form to be packaged in CCOs is potentially machine compacted, the Case I analysis was reevaluated. CCO-CAL-00051 determines that the current manually compacted with less than or equal to 1% by weight Be/BeO criticality analysis may be extended to CCOs containing machine compacted waste when the amount of plastic in the waste is limited to a maximum of 2,000 grams per CCO.
6.2.5 6.2-5 Revised to delete limitation on machine compacted waste for Case E.
See Section 6.0 justification.
1 K. L. Moyant, Evaluation of the Criticality Safety Analysis for Criticality Control Overpacks Containing Machine Compacted Waste, CCO-CAL-0005, Rev. 0, Nuclear Waste Partnership LLC, Carlsbad, NM, July 2020
ATTACHMENT A - Summary of Revisions August 2020 A-3 TRUPACT-II SAR, Revision 24, August 2020 Section Page Change Description Justification 6.2.7 6.2-5 Revised to delete limitation on machine compacted waste for Case I and add requirement that machine compacted waste in each CCO is limited to a maximum of 2,000 grams of plastic.
See Section 6.0 justification.
6.4.3.4 6.4-8 and 6.4-9 Revised to add to the number of cases associated with machine compacted waste and add summaries of Cases E and I. Revised to add reference for evaluation deriving the 2,000 grams limit on plastic per CCO.
See Section 6.0 justification.
6.4.3.5 6.4-9 and 6.4-10 Revised to add Cases E and I as applicable to machine compacted waste payloads. Revised summary table to include FGE limits and relevant analysis cases for pipe overpacks and CCOs.
Revised to move Note 3 to clarify that it applies to drums containing machine compacted waste with controls and 1% by weight Be/BeO. Revised to add Note 4 to limit plastic content to a maximum of 2,000 grams in each CCO containing machine compacted waste with 1% by weight Be/BeO.
See Section 6.0 justification.
ATTACHMENT A - Summary of Revisions August 2020 A-4 HalfPACT SAR, Revision 7, August 2020 Section Page Change Description Justification General Revised header for revision and date.
Administrative change. No impact to safety basis.
6.0 6.1-1 Revised summary descriptions of Cases E and I to remove limitation on machine compacted waste.
Additionally, for Case I, specified that machine compacted waste in each CCO is limited to a maximum of 2,000 grams of plastic. Added Cases E and I to the list of cases that are applicable to machine compacted waste.
While the existing Case E criticality analysis for the standard, S100, S200, and S300 pipe overpacks encompass machine compacted waste, it was not previously identified as an inventory need. Revisions clarify that machine compacted waste in pipe overpacks is allowed subject to the currently authorized 200 FGE limit per pipe overpack.
The existing Case I criticality analysis for CCO payload containers is limited to manually compacted waste (i.e., not machine compacted).
Because the SRS excess plutonium waste form to be packaged in CCOs is potentially machine compacted, the Case I analysis was reevaluated. CCO-CAL-00051 determines that the current manually compacted with less than or equal to 1% by weight Be/BeO criticality analysis may be extended to CCOs containing machine compacted waste when the amount of plastic in the waste is limited to a maximum of 2,000 grams per CCO.
6.2.5 6.2-5 Revised to delete limitation on machine compacted waste for Case E.
See Section 6.0 justification.
ATTACHMENT A - Summary of Revisions August 2020 A-5 HalfPACT SAR, Revision 7, August 2020 Section Page Change Description Justification 6.2.9 6.2-6 Revised to delete limitation on machine compacted waste for Case I and add requirement that machine compacted waste in each CCO is limited to a maximum of 2,000 grams of plastic.
See Section 6.0 justification.
6.4.3.4 6.4-8 and 6.4-9 Revised to add to the number of cases associated with machine compacted waste and add summaries of Cases E and I. Revised to add reference for evaluation deriving the 2,000 grams limit on plastic per CCO.
See Section 6.0 justification.
6.4.3.5 6.4-9 and 6.4-10 Revised to add Cases E and I as applicable to machine compacted waste payloads. Revised summary table to include FGE limits and relevant analysis cases for pipe overpacks and CCOs.
Revised to move Note 3 to clarify that it applies to drums containing machine compacted waste with controls and 1% by weight Be/BeO. Revised to add Note 4 to limit plastic content to a maximum of 2,000 grams in each CCO containing machine compacted waste with 1% by weight Be/BeO.
See Section 6.0 justification.
ATTACHMENT A - Summary of Revisions August 2020 A-6 TRUPACT-II SAR Drawing, 2077-500SNP, Revision Z Sheet Zone Change Description Justification General Revised title block.
Administrative change. No impact to safety basis.
HalfPACT SAR Drawing, 707-SAR, Revision 10 Sheet Zone Change Description Justification General Revised title block.
Administrative change. No impact to safety basis.
Standard Pipe Overpack SAR Drawing, 163-001, Revision 8 Sheet Zone Change Description Justification General Revised title block.
Administrative change. No impact to safety basis.
S100 Pipe Overpack SAR Drawing, 163-002, Revision 6 Sheet Zone Change Description Justification General Revised title block.
Administrative change. No impact to safety basis.
ATTACHMENT A - Summary of Revisions August 2020 A-7 S200 Pipe Overpack SAR Drawing, 163-003, Revision 5 Sheet Zone Change Description Justification General Revised title block.
Administrative change. No impact to safety basis.
S300 Pipe Overpack SAR Drawing, 163-004, Revision 3 Sheet Zone Change Description Justification General Revised title block.
Administrative change. No impact to safety basis.
Compacted Puck Drum Spacers SAR Drawing, 163-006, Revision 2 Sheet Zone Change Description Justification General Revised title block.
Administrative change. No impact to safety basis.
Shielded Container SAR Drawing, 163-008, Revision 3 Sheet Zone Change Description Justification General Revised title block.
Administrative change. No impact to safety basis.
ATTACHMENT A - Summary of Revisions August 2020 A-8 Criticality Control Overpack SAR Drawing, 163-009, Revision 1 Sheet Zone Change Description Justification General Revised title block.
Administrative change. No impact to safety basis.
2 D6/D7 Added "(OPTIONALLY RECESSED)" to description for upper dunnage folding lift handle.
Recess allows for additional clearance between inside surface of drum lid and lift handle. No impact to safety basis.
2 D5 Added "OR A240 TYPE 304/304L" as material option for blind flange (lid).
Option allows blind flange (lid) to be fabricated from plate material. Mechanical properties for A240 Type 304/304L are equivalent to mechanical properties for ASTM A182 Grade F304/F304L. No impact to safety basis.
2 D4 Added "OR A240 TYPE 304/304L" as material option for slip-on flange.
Option allows slip-on flange to be fabricated from plate material. Mechanical properties for A240 Type 304/304L are equivalent to mechanical properties for ASTM A182 Grade F304/F304L. No impact to safety basis.
2 C7 Moved "UPPER/LOWER DUNNAGE" from A7 to C7 and added "(LOWER DUNNAGE AS SHOWN)".
Editorial change to clarify that the lower dunnage is shown in this drawing view. No impact to safety basis.
2 B8 Added "MIN" to wood screw callout.
Allows a larger diameter screw to be used to avoid breakage during installation. Screws primarily facilitate clamping of the plywood sheets and proper curing of the glue during fabrication assembly. No impact to safety basis.
ATTACHMENT A - Summary of Revisions August 2020 A-9 Criticality Control Overpack SAR Drawing, 163-009, Revision 1 Sheet Zone Change Description Justification 2
B5 Revised filter port dimensions from vn2.00 x.25 to vn2.0 x.3 Change facilitates increased dimension default tolerances to aid in fabrication. No impact to safety basis.
2 A5 Revised lift attachment counterbore from x.25 MAX to x.3 MAX Change facilitates increased dimension default tolerances to aid in fabrication. No impact to safety basis.
2 B4 Revised pipe length from 26.50 to 26.5 Change facilitates increased dimension default tolerances to aid in fabrication. No impact to safety basis.
2 A7 Revised to add, "BOTTOM VIEW" Editorial change to clarify the view perspective.
No impact to safety basis.
2 A5 Revised lift attachment bail clearance counterbore from x.13 MAX to x.2 MAX Change facilitates increased dimension default tolerances to aid in fabrication. No impact to safety basis.
ATTACHMENT A - Summary of Revisions August 2020 A-10 Criticality Control Overpack SAR Drawing, 163-009, Revision 1 Sheet Zone Change Description Justification 2
A2 Added "OR A240 TYPE 304/304L (HOLES ARE OPTIONAL)" as option for blind flange (base).
Option allows blind flange (base) to be fabricated from plate material. The unused holes are optional. Mechanical properties for A240 Type 304/304L are equivalent to mechanical properties for ASTM A182 Grade F304/F304L. No impact to safety basis.
ATTACHMENT A - Summary of Revisions August 2020 A-11 CH-TRAMPAC, Revision 5, August 2020 Section Page Change Description Justification General Revised header for revision and date.
Administrative change. No impact to safety basis.
3.0 3.1-1 Removed introductory discussion.
Editorial change. Deletion of the unnecessary text simplifies the presentation of the nuclear properties requirements in this section. No impact to safety basis.
3.1.1 3.1-1 thru 3.1-3 Revised to remove text that duplicates the payload container specific FGE limits summarized in Table 3.1-1.
Revised Table 3.1-1 to specify the SAR Case E and Case I FGE limits for pipe overpacks and CCOs containing machine compacted waste. Revised to move detailed conditions for puck drums previously presented in the Section 3.1.1 text to Table 3.1-1 Note 3.
Revised to add new Table 3.1-1 Note 4 to specify the plastic content limit per CCO containing machine compacted waste.
The text deletions and table footnote revisions reflect the consolidated presentation of requirements in Table 3.1-1.
CH-TRAMPAC Section 3.1.1 establishes the results of TRUPACT-II and HalfPACT criticality analyses as payload requirements consistent with the revisions to Section 6.0 of the TRUPACT-II SAR and of the HalfPACT SAR to allow machine compacted waste in pipe overpacks and CCOs.
ATTACHMENT A - Summary of Revisions August 2020 A-12 CH-TRU Payload Appendices, Revision 4, August 2020 Appendix /
Section Page Change Description Justification General Revised header for revision and date.
Administrative change. No impact to safety basis.
4.6 / 4.6.6 4.6-31 Revised to detail the plastic content limit per CCO containing machine compacted waste. Revised to add reference to evaluation deriving the 2,000 grams limit on plastic per CCO and to renumber subsequent footnote.
Revised to delete limitation on machine compacted waste for Case I.
As documented in CCO-CAL-0005, the current TRUPACT-II and HalfPACT manually compacted with less than or equal to 1% by weight Be/BeO criticality analysis may be extended to CCOs containing machine compacted waste when the amount of plastic in the waste is limited to a maximum of 2,000 grams per CCO.
4.6 / 4.6.8 4.6-33 Revised to summarize that the reactivity limits are met for both manually compacted and machine compacted wastes for the CCO subject to applicable fissile and plastic content mass limits.
See Section 4.6.6. justification.