ML20217N021
| ML20217N021 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 03/26/1998 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC |
| References | |
| RTR-NUREG-1609 GDP-98-0018, GDP-98-18, NUDOCS 9804080300 | |
| Download: ML20217N021 (4) | |
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d USEC A Global Energy Company March 26,1998 ODP 98-0018 i
V Chief, Rules and Directives Branch Division of Administrative Services Mail Stop T-6 D59 U. S. Nuclear Regulatory Commission I
Washington, DC 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Portsmouth Gaseous Diffusion Plant (PORTS)
Docket Nos. 70-7001 & 70-7002 USEC Comments on Draft NUREG-1609,62 Fed. Reg. 65825 (December 16,1997)
Dear Sir:
Enclosed are the United States Enrichment Corporation's (USEC's) comments on Draft NUREG-1609, " Standard Review Plan for Transportation Packages for Radioactive Material." USEC believes that the plan is helpful in describing how the NRC stafT plans to conduct reviews of an application for packaging certification. Further, it is useful in that it clarifies some NRC staff i
positions with respect to their interpretation of 10 CFR Part 71. There were some areas where further clarification would be helpful, as indicated in the enclosure.
i If there are questions concerning these comments, please contact Dr. Beth Darrough at (301) 564-3422 or Lisa Jarriel of my stafTat (301) 564-3247. There are no new commitments contained in this f/
submittal.
//
- Sincerely,
/1 s.A.
IJ p
Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager 9804080300 980326 Enclosure PDR ADOCK 07007001 C
PDR cc: NRC Resident Inspector-PGDP ro NRC Resident Inspector-PORTS x ' M' ' " ~
NRC Special Projects Branch, NMSS 6903 Rockledge Drive, Bethesda, MD 20817-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC j
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Enclosure GDP 98-0018 Page 1 of 3 USEC Comments on Draft NUREG-1609 Standard Review Plan for Transportation Packages for Radioactive Material Section Comment general Chrification would be helpful in the use of the words, " adequate" and " appropriate."
These words were used in the document in describing the extent of an applicant's rigor in evaluation or analysis. While there are many instances where a case-specific evaluation is needed, there may be other instances where clarification could be developed as to how adequacy and appropriateness are defined. Such a clarification would improve the review process for both the applicant and the reviewer.
1.4 Clarification on the amount ofinformation necessary to include on the engineering d
drawings submitted with the application would be helpful.
1.5.1.2 The establishment of categories based on risk within the broader category of Type B packaging, although not in 10 CFR 71, is helpful. However, ifit is i
to be implemented, an applicant should have a single source (e.g., a generic j
Reg Guide) to precisely identify the structural, thermal, nuclear, QA, fabrication, testing, and use requirements and/or criteria. Having a single source would be preferable to searching through several NUREG documents.
Additionally, Table 1.1 defines the categories in terms of an A2 multiplier and a
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curie quantity for Categories II and III but the table specifies the multiplier or a curie quantity for Category I. For radioactive material such'as enriched UF which has an 6
unlimited A2 value, this presents a categorization dilemma. USEC recommends that the table be modified by changing the and to or for Categories II and III.
I 2.5.3 See comment on section 1.4.
2.5.5 The document references RG 7.8 for guidance. This could create confusion because the approved RG 7.8 is applicable only to irradiated fuel packagings and NUREG-1609 excludes such packagings. If NUREG-1609 is using the L
draft RG 7.8 (dated March 1989) as guidance for all Type B packagings, it would be helpful to state that fact.
2.5.5.1 In reference to the 4th bulle. on page 2-8, clarification or examples are needed as to how margin of safety is evaluated for those cases where qualification-by-testing is employed.
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l Enclosure GDP 98-0018 Page 2 of 3 3.5.2.1 The text asks for properties of fire combustion gases (among others). Such data is not generally available. Further, the composition of combustion gases is widely variable. In the absence of data on such gases, air at elevated temperature is usually assumed. The document would be strengthened ifit I
addressed NRC's thoughts on the acceptability of a substitution for combustion gases, and the justification that would be required for its acceptance.
4.5.3.1-If the packaging is designed to be " leak tight" under Normal and Accident Conditions per ANSI N14.5, is there a need to define the releasable source term? Will the NRC recognize other leakage evaluation methods which may not be contained in N14.5 but are technicallyjustifiable?
4.5.4.1 See comment on 4.5.3.1.
4.5.3.2 Clarification would be useful on what additional data the NRC reviewer would need to supplement the model test, if scale model package leakage testing is " applicable" but not "necessarily sufficient."
6.5.1.3 This section speaks for the first time of the N value for calculation of the i
transport index. The section would be strengthened ifit referenced 10 CFR 71.59 for the determination of the N value.
6.5.3.2 There are some material forms for which a greater than 75% neutron poison concentration would be effective. The NRC has in recent times accepted greater than 75% if the applicant justifies the greater value. It would be helpful if this philosophy were incorporated into NUREG-1609.
7.5.1 Handling and loading procedures have safety-related aspects to them.
However, there are times when the sequence of operations is not as important as the operations themselves. USEC suggests that some sequence latitude be l
given, as long as the critical operations are contained in the SAR.
7.5.1.2 The 4th bullet asks for a procedural step which assures that any neutron absorber is "present" and in " proper condition." Many packagings have these components encased or clad and their access on a routine basis (i.e., during loading) is not feasible. Users rely on annual inspections and other "off-line" processes to assure the presence of these components, not necessarily j
inspections at the time of loading. It would be helpful if the document j
included an alternative method, such as a verification that the package is current in its annual inspection which includes a check on the presence and condition of any neutron absorbers.
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Enclosure GDP 98-0018 h
Page 3 of 3 I
7.5.1.3 The 3rd bullet discusses temperature measurements which verify that the package surface temperature limit is not exceeded. The ambient temperature 8
of 100 F and solar insolation are not likely to be present at the. time of measurement, and the package may not have reached thermal equilibrium at the time of shipping. Shippers rely on the SAR analysis and the verification that the heat load of the contents is in compliance with the Certificate. For example, a UF. package has essentially no heat load and thus a verification l
measurement is not performed. USEC suggests that the document modify the reqmrement by stating "if applicabic."
L 7.5.3 If an applicant does not or cannot comply with the sampling of the package cavity for internal contamination limits, then there is an option of having as Authorized Contents in the Certificate. a category called' " residual contamination." It would be helpfll if NUREG-1609 mentioned this option.
It is in the maintenance program where the presence and condition of any 8.3.2 l
neutron absorbers is determined. It would be helpful if the maintenance program were referenced in the package loading process (see comment on 7.5.1.2).
~8.5.2.4 For high heat load packages which have design features that might degrade l
with time, a periodic test makes sense. However, periodic testing seems unnecessary for intermediate and low heat load packages. Further, due to internal contamination, the original thermal test may not be feasible without i
extraordinary efforts. USEC suggests that periodic testing be package-specific, based on heat load and/or thermal design and that alternative periodic thermal performance assessment methods be acknowledged in the document.
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