ML22109A099
| ML22109A099 | |
| Person / Time | |
|---|---|
| Site: | 07109320 |
| Issue date: | 04/21/2022 |
| From: | Storage and Transportation Licensing Branch |
| To: | EnergySolutions |
| Pierre Saverot NMSS/DFM/STL 301-415-7505 | |
| Shared Package | |
| ML22109A096 | List: |
| References | |
| EPID L-2022-LLA-0039 | |
| Download: ML22109A099 (3) | |
Text
SAFETY EVALUATION REPORT Docket No. 71-9320 Model No. MIDUS Certificate of Compliance No. 9320 Revision No. 6
SUMMARY
By letter dated March 23, 2022 (Agencywide Documents Access and Management System Accession No ML22083A117), EnergySolutions (or the applicant) r equested an amendment to Certificate of Compliance (CoC) No. 9320 for the MIDUS packagin g.
The applicant identified opportunities for improvement of the l eak rate test procedures within the MIDUS package Safety Analysis Report (SAR) by removing prescrip tive language that does not provide any flexibility to follow the latest techniques in leak rate testing. The applicant did not change any acceptance criteria or reduce leak rate testing comm itments for this package and the proposed changes, while consistent with all applicable requ irements and guidance documents, do provide flexibility during performance of these l eak rate tests.
The staff reviewed the application and determined that the chan ges do not affect the ability of the package to meet the requirements of Title 10 of the Code of Federal Regulations (10 CFR)
Part 71. The certificate has been updated to Revision No. 6.
EVALUATION
The applicant provided the following background for the request :
During the development and qualification of procedures for peri odic/maintenance and pre-shipment leakage rate testing for MIDUS packaging per latest NR C Regulatory Guide 7.4, Leakage Tests on Packages for Shipment of Radioactive Material, (endorsing ANSI N14.5-2014), opportunities for improvement of leakage rate test proce dures within the MIDUS package application were identified. Prescriptive language in the curr ent SAR revision for leakage rate tests does not provide any flexibility to follow the current/la test techniques in leakage rate testing. Therefore, a revision of the MIDUS package applicatio n became critical for EnergySolutions and MIDUS pack aging users (domestically and int ernationally).
According to the applicant, the requested changes do not chang e any acceptance criteria or reduce leakage rate testing commitments. In fact, proposed chan ges are consistent with applicable latest requirements/guidance documents while providi ng needed flexibility during performance of these leakage rate tests. The requested change s do not alter the confinement boundary or affect the containment performance of the package.
The applicant edited for consistency several sections of the ap plication and clarified requirements for testing applicability: leaktight criteria are defined as equivalent to 1 x 10 -7 ref-
Enclosure cm3/s (air) as required by ANSI N14.5-2014. The applicant commit ted to ANSI N14.5-2014 throughout the application. A new reference (written practice for NDT - SNT-TC-1A-2006 edition or later) was added and the requirements for packagings fabricated before or after January 1, 2022, were revised.
1 Containment Boundary
There have been no changes to the containment boundary of the p ackage; therefore, the staffs previous findings still apply.
2 Summary of Proposed Changes
The applicant has proposed changes to the text of the SAR in Ch apters 4, 7, and 8, all related to the leakage rate testing of the MIDUS package, in line with the provisions of ANSI N14.5 2014. The changes proposed by the applicant are summarized, in detail, in Attachment 1 of the applicants letter to the NRC (ESCD/NRC 22-002), dated March 23, 2022. The applicant describes the changes as being necessary to provide additional flexibility to the users of the MIDUS package, specifically in the leakage rate testing of the package.
The applicant has not proposed any changes to the design or fab rication of the MIDUS package.
2.1 Changes to SAR Chapter 4, Containment.
The applicant modified the text in Sections 4.1, 4.2.2, 4.3.2, 4.4.1, 4.4.2, 4.4.3, 4.4.4, and 4.5 of the SAR. The changes included clarifying pre-shipment leakage rate testing options, clarifying the leaktight criteria for leakage testing as provided in ANS I N14.5-2014, committing to ANSI N14.5 2014, as well as some editorial corrections.
2.2 Changes to SAR Chapter 7, Package Operations.
The applicant modified the text in Sections 7.1.1, 7.1.2, 7.1.3, 7.4, 7.4.1, and 7.5 of the SAR.
These changes were primarily focused on the actual steps involv ed in preparing a package for transportation and included several editorial corrections, chan ges to provide consistency with other Sections of the SAR, highlighting the applicants commitm ent to the new edition of ANSI N14.5 (2014), and speaking to specific requirements of ANSI N14.5 2014 related to the pre-shipment leakage rate testing and non-destructive testing (NDT) practices.
2.3 Changes to SAR Chapter 8, Acceptance Tests and Maintenance Program.
The applicant modified the text in Sections 8.1.4, 8.2.2, 8.3.1, and Table 8-1 of the SAR. The applicant added specific requirements for packages fabricated b efore and after January 1, 2022, defined periodic and maintenance leakage rate tests in ANSI N14.5-2014, made an editorial correction to Table 8-1 of the SAR, and reiterated the applican ts commitment to the new edition of ANSI N14.5 (2014) and spoke to specific requirements of ANSI N14.5 2014 and NDT practices.
3 Review of Proposed Changes
The changes proposed by the applicant are primarily focused on introducing additional flexibility for operators of the MIDUS package in conducting leakage rate t esting of the package prior to
2 Enclosure shipment. Detailed procedures for leakage rate testing are dev eloped by the operators of the package, and these procedures will be developed in accordance w ith the provisions in ANSI N14.5-2014, as committed to by the applicant in the SAR.
NRC staff does not generally review detailed procedures as part of its review of the design, fabrication, and/or operation of a transportation package; howe ver, as part of NRCs oversight role, inspections or audits may be carried out, in this case sp ecifically in order to review detailed procedures developed for leakage rate testing of the MIDUS pack age, if the staff felt it was necessary. This regulatory approach, which considers risk insi ghts in its application, generally allows for less operational detail, such as those included in d etailed procedures, to be provided in the SAR, offering additional flex ibility to operators, without having an impact on the safe operation of the package.
4 Evaluation Findings
Based on the staffs review of the containment and other relate d sections of the application, the staff finds that the nature of the changes proposed do not have any effect on the overall safety of the MIDUS package design and the staff agrees with the appli cants conclusion that the MIDUS package continues to meet the containment requirements fo r normal conditions of transport and hypothetical accident conditions found in 10 CFR 71.71 and 71.73, respectively.
The staff also agrees that those proposed changes do not affect any acceptance criteria nor do they reduce leakrate testing commitments.
The staff reviewed the applicants requested changes to the Cer tificate of Compliance and determined that the applicants proposed changes to the CoC wou ld not affect the ability of the Model No. MIDUS package to meet all the requirements of 10 CFR Part 71.
CONDITIONS
The following changes were made to the certificate of complianc e:
Item No. 3(b) identifies the latest application dated March 23, 2022.
Condition No. 8 has been modified to extend the previous revisi on of the certificate for approximately one year.
The expiration date of the certificate (Condition No. 9) was no t modified.
The References section of the certificate was updated to includ e the application dated March 23, 2022.
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. 9320, Revision No. 6.
3 Enclosure