ML21236A083
| ML21236A083 | |
| Person / Time | |
|---|---|
| Site: | 07109362 |
| Issue date: | 09/15/2021 |
| From: | John Mckirgan Storage and Transportation Licensing Branch |
| To: | Hilbert F Daher Nuclear Technologies GmbH |
| P SAVEROT NRC/NMSS/DFM/STLB 3014157505 | |
| Shared Package | |
| ML21236A080 | List: |
| References | |
| Download: ML21236A083 (3) | |
Text
SAFETY EVALUATION REPORT Model No. DN30 Package Certificate of Compliance No. 9362 Revision No. 3
SUMMARY
By letter dated July 8, 2021, Daher Nuclear Technologies, GmbH, (DNT, or the applicant) submitted an amendment request for Certificate of Compliance (C oC) No. 9362 for the Model No. DN30 package (ADAMS Accession No. ML21189A184)
The applicant proposed to reduce the number of dose rate measur ement points for commercial grade UF6 because dose rate distribution is well known by exper ience after decades of transports and would therefore reduce personnel exposure.
The applicant also proposed to include, in the procedures, test radiation sources to calibrate the contamination measuring instrument s other than Am-241 for -emi tters and Cs-137 or Sr/Y-90 for -emitters because not every site uses those sources and to exchange one thermal plug on each half shell of the PSP by a t hermal pressure relief valve i n order to avoid a pressure increase inside the half shells.
The applicant revised (i) the Parts List 0023-STL-1000-000 to R evision 7 and (ii) the test instructions 0023-PA-2015-017 to Revision 3.
Based on the statements and representations in the application, and the conditions listed in the CoC, the staff concludes that the package meets the requirement s of 10 CFR Part 71.
EVALUATION
The applicant proposed the following three changes:
- 1. Acceptance of test radiation sources to calibrate the conta mination measuring instruments other than Am-241 for -emitters and Cs-137 or Sr/Y-90 for -em itters.
- 2. Reduction of the number of dose rate measurement points at the surface of the DN30 package to respect ALARA.
- 3. Possibility to exchange one thermal plug on each half shell by a thermal pressure relief valve in order to avoid a pressu re increase inside the half she lls.
The staff reviewed the proposed changes to verify that the pack age continues to meet regulatory requirements for shielding performance and complies with regulatory dose rate limits.
There is no change to the contents of the package or the shield ing material.
In the operating procedures in Chapter 1.7 of the application, as referenced by the CoC, the applicant references the report Contamination and Dose Rate Me asurement at the DN30 2
Package, Test Instruction No. 0023 PA-2015-017. This report p rovides a description and the basis for the first two proposed changes.
Regarding proposed change 1., the applicant updated the test in struction and has identified DIN ISO 7503 Part 3 Measurement of Radioactivity - Measurement and evaluation of surface contamination - Part 3: Apparatus Calibra tion or an equivalent standard to qualify test radiation sources. The staff found th is standard, based on NUREG 1507 Rev.1, acceptable for calibration and as such has re asonable assurance that calibration sources different from Am-124, Cs-137 or Sr/Y-90 will not adversely affect the radiation protection as it relates to the package.
Regarding proposed change 2., the applicant updated the test in struction with a reduced number of measurement points, based on the type of contents loa ded.
For contents where there is data available on dose rates at var ious measurement points, the applicant reduced the number of measurement points.
For contents where there is no data available on the dose rates, the applicant did not change the number of measurement points.
For contents where there is limited data available, the applica nt will measure at all locations at the beginning of transportation and reduce the num ber of measurement points if it is determined that shielding safety will be mainta ined.
The staff found this approach reasonable for determining the nu mber of measurement points for the Type A(F) DN30 package and, therefore, acceptabl e.
The staff has therefore determined that the updated test instru ction, with proposed changes 1 and 2, continues to demonstrate that a user of the package woul d meet the requirements of 10 CFR 71.0(d)(3) and 71.81, which requires any licensee transport ing licensed material to comply with operating control requirements to measure radiation and co ntamination level, as stated in 10 CFR 71.87(i) and (j).
Regarding proposed change 3, the staff reviewed the revised Par t List No. 0023-STL-1000-000, Rev. 7 and determined that shielding is effectively the same as the previously approved cask, and therefore the staff has reasonable assurance that, with the proposed change, the package will continue to meet the regulatory dose requirements in 10 CF R 71.47 and 10 CFR 71.51(2)(2).
Based on these determinations, the staff concludes that the app licants proposed changes will not impact the shielding capability of the package and therefor e continues to meet dose and radiation protection requirements of 10 CFR Part 71.
3
CONDITIONS
The following changes were made to the CoC:
Item No. 3(b) identifies the application as supplemented.
Condition No. 5(a)(3) has been modified to include the new revi sion of the Parts List 0023-STL-1000-000.
Condition No. 11 has been modified to extend the previous revis ion of the certificate for approximately one year.
The expiration date of the certificate was not modified.
The References section of the certificate was updated to refere nce the supplemental information provided for this amendment request.
CONCLUSION
Based on the statements and representations in the application, the staff finds that these changes do not affect the ability of the package to meet the re quirements of 10 CFR Part 71.
Issued with Certificate of Compliance No. 9362, Revision No. 3.