ML22158A275
| ML22158A275 | |
| Person / Time | |
|---|---|
| Site: | 07109330 |
| Issue date: | 05/31/2022 |
| From: | US Dept of Energy (DOE) |
| To: | Storage and Transportation Licensing Branch |
| P SAVEROT NMSS/DFM/FFLB 3014157505 | |
| Shared Package | |
| ML22158A270 | List: |
| References | |
| Download: ML22158A275 (83) | |
Text
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-274 Figure 6.14 ATR LEU Package Array, NCT and HAC Figure 6.14 MURR LEU Package Array, NCT and HAC
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-275 Figure 6.14 MIT LEU Package Array, NCT and HAC Figure 6.14 NBSR LEU Package Array, NCT and HAC
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-276 Table 6.14 ATR LEU NCT Package Array Results Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Neoprene Location Polyethylene Location ksafe Series 1: Water Density Adjustment 1
1 0.73325 1
0.6 0.77863 1
0.5 0.78777 1
0.4 0.79087 1
0.3 0.78649 1
0.2 0.77086 0.9 0.4 0.77122 0.8 0.4 0.75160 Series 2: Homogenized Material Location 1
0.4 Bag 0.76999 1
0.4 Bag 0.79360 1
0.4 Bag Bag 0.77255 1
0.3 Inner Tube 0.78973 1
0.4 Inner Tube 0.79329 1
0.5 Inner Tube 0.78871 1
0.3 Inner Tube 0.78831 1
0.4 Inner Tube 0.79074 1
0.5 Inner Tube 0.78645 1
0.3 Inner Tube Inner Tube 0.79052 1
0.4 Inner Tube Inner Tube 0.79166 1
0.5 Inner Tube Inner Tube 0.78751 1
0.2 Inner Tube Bag 0.78099 1
0.3 Inner Tube Bag 0.79375 1
0.4 Inner Tube Bag 0.79344 1
0.5 Inner Tube Bag 0.79097
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-277 Table 6.14 MURR LEU NCT Package Array Results Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Neoprene Location Polyethylene Location ksafe Series 1: Water Density Adjustment 1
1 0.83341 1
0.8 0.84791 1
0.7 0.85406 1
0.6 0.85798 1
0.5 0.85697 1
0.4 0.85219 0.9 0.6 0.83604 0.8 0.6 0.81421 Series 2: Homogenized Material Location 1
0.6 Bag 0.84759 1
0.6 Bag 0.85992 1
0.6 Bag Bag 0.85000 1
0.4 Inner Tube 0.85465 1
0.5 Inner Tube 0.85904 1
0.6 Inner Tube 0.85672 1
0.7 Inner Tube 0.85569 1
0.4 Inner Tube 0.85380 1
0.5 Inner Tube 0.85809 1
0.6 Inner Tube 0.85663 1
0.7 Inner Tube 0.85332 1
0.4 Inner Tube Inner Tube 0.85631 1
0.5 Inner Tube Inner Tube 0.85806 1
0.6 Inner Tube Inner Tube 0.85791 1
0.7 Inner Tube Inner Tube 0.85291 1
0.4 Inner Tube Bag 0.85749 1
0.5 Inner Tube Bag 0.86146 1
0.6 Inner Tube Bag 0.86127
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-278 Table 6.14 MIT LEU NCT Package Array Results Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Neoprene Location Polyethylene Location ksafe Series 1: Water Density Adjustment 1
1 0.65761 1
0.8 0.67282 1
0.7 0.67735 1
0.6 0.68189 1
0.5 0.68170 1
0.4 0.67448 0.9 0.6 0.66814 0.8 0.6 0.65564 Series 2: Homogenized Material Location 1
0.6 Bag 0.66801 1
0.6 Bag 0.68549 1
0.6 Bag Bag 0.67260 1
0.4 Inner Tube 0.67691 1
0.5 Inner Tube 0.68206 1
0.6 Inner Tube 0.68140 1
0.7 Inner Tube 0.67777 1
0.4 Inner Tube 0.67604 1
0.5 Inner Tube 0.68150 1
0.6 Inner Tube 0.68124 1
0.7 Inner Tube 0.67652 1
0.4 Inner Tube Inner Tube 0.67843 1
0.5 Inner Tube Inner Tube 0.68258 1
0.6 Inner Tube Inner Tube 0.68096 1
0.7 Inner Tube Inner Tube 0.67788 1
0.4 Inner Tube Bag 0.68211 1
0.5 Inner Tube Bag 0.68563 1
0.6 Inner Tube Bag 0.68613 1
0.7 Inner Tube Bag 0.68210
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-279 Table 6.14 NBSR LEU NCT Package Array Results Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Polyethylene Location ksafe Series 1: Water Density Adjustment 1
1 0.63207 1
0.8 0.64205 1
0.7 0.64650 1
0.6 0.65053 1
0.5 0.65048 1
0.4 0.64692 0.9 0.6 0.63072 0.8 0.6 0.61406 Series 2: Homogenized Material Location 1
0.6 Bag 0.65257 1
0.7 Inner Tube 0.64567 1
0.6 Inner Tube 0.64911 1
0.5 Inner Tube 0.65005 1
0.4 Inner Tube 0.64878 1
0.3 Inner Tube 0.64213
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-280 6.14.4.3 HAC Single Package Evaluation 6.14.4.3.1 Configuration The HAC single package baseline configuration is the fuel plates centered in the cavity with full density pure water in the fuel plate bag, inner tube, and outer shell and normal spacing between plates. In the first series of cases, the spacing between fuel plates is adjusted to determine the optimal spacing. In the second series of cases, the water density in each region is lowered to confirm that maximum moderation and reflection are most conservative. In the third series of cases, the two regions of water in the package cavity are homogenized with neoprene and/or polyethylene (as applicable) to determine the most reactive locations for those materials.
For ATR LEU, the first series of cases is skipped as the fuel plates are maintained in a fixed spacing under HAC.
For MIT LEU, the fuel plates are horizontally aligned (rather than diagonally offset) and become only slightly offset as necessary to stay within the FHE envelope (see Figure 6.14-3).
For NBSR LEU, additional series of cases are performed to evaluate changes to the axial spacing between the two sets of 17 fuel plates. First, the axial spacing between the two sets of plates in reduced to determine the optimal spacing. Second, a single case is performed in which the two sets are allowed to perfectly overlap, resulting in a compressed assembly with smaller channel gaps.
6.14.4.3.2 Results HAC single package results are shown in Table 6.14-30 through Table 6.14-36. As expected based on the NCT single package results, the fuel plates are under-moderated and ksafe increases as the distance between fuel plates increases. For NBSR LEU, ksafe is maximized with minimum axial spacing (without overlapping) and maximum transverse spacing (i.e. maximum channel thicknesses). For water density, the most conservative configuration is maximum density water in all locations. With respect to neoprene and polyethylene, ksafe is maximized when only polyethylene is credited.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-281 Table 6.14 ATR LEU HAC Single Package Results (Fixed Spacing)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Outer Shell Water Density (g/cm3)
Neoprene Location Polyethylene Location ksafe Series 1: Water Density Adjustment 1
1 1
0.45162 0.9 1
1 0.43523 0.8 1
1 0.41866 1
0.9 1
0.43554 1
0.8 1
0.41964 1
1 0.9 0.44808 1
1 0.8 0.44618 Series 2: Homogenized Material Location 1
1 1
Bag 0.43353 1
1 1
Bag 0.45393 1
1 1
Bag Bag 0.43521 1
1 1
Inner Tube 0.44791 1
1 1
Inner Tube 0.45052 1
1 1
Inner Tube Inner Tube 0.44864
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-282 Table 6.14 MURR LEU HAC Single Package Results (No Additional Materials)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Outer Shell Water Density (g/cm3)
Additional Fuel Plate Spacing (cm) ksafe Series 1: Fuel Plate Spacing 1
1 1
0.000 0.53856 1
1 1
-0.100 0.47550 1
1 1
0.025 0.55215 1
1 1
0.050 0.56541 1
1 1
0.075 0.57805 1
1 1
0.081 0.58197 Series 2: Water Density Adjustment 1
1 1
0.081 0.58197 0.9 1
1 0.081 0.55333 0.8 1
1 0.081 0.52335 1
0.9 1
0.081 0.56998 1
0.8 1
0.081 0.55795 1
1 0.9 0.081 0.57875 1
1 0.8 0.081 0.57471 Table 6.14 MURR LEU HAC Single Package Results (Constant Spacing)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Outer Shell Water Density (g/cm3)
Neoprene Location Polyethylene Location ksafe Series 3: Homogenized Material Location (0.081 cm spacing) 1 1
1 Bag 0.57057 1
1 1
Bag 0.58572 1
1 1
Bag Bag 0.57448 1
1 1
Inner Tube 0.57999 1
1 1
Inner Tube 0.58157 1
1 1
Inner Tube Inner Tube 0.58069
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-283 Table 6.14 MIT LEU HAC Single Package Results (No Additional Materials)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Outer Shell Water Density (g/cm3)
Additional Fuel Plate Spacing (cm) ksafe Series 1: Fuel Plate Spacing 1
1 1
0.00 0.44515 1
1 1
-0.05 0.41808 1
1 1
0.05 0.46905 1
1 1
0.10 0.49110 1
1 1
0.15 0.51203 1
1 1
0.16 0.51582 Series 2: Water Density Adjustment 1
1 1
0.16 0.51582 0.9 1
1 0.16 0.49164 0.8 1
1 0.16 0.46852 1
0.9 1
0.16 0.50219 1
0.8 1
0.16 0.48752 1
1 0.9 0.16 0.51320 1
1 0.8 0.16 0.51086 Table 6.14 MIT LEU HAC Single Package Results (Constant Spacing)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Outer Shell Water Density (g/cm3)
Neoprene Location Polyethylene Location ksafe Series 3: Homogenized Material Location (0.16 cm spacing) 1 1
1 Bag 0.50429 1
1 1
Bag 0.52045 1
1 1
Bag Bag 0.50864 1
1 1
Inner Tube 0.51554 1
1 1
Inner Tube 0.51619 1
1 1
Inner Tube Inner Tube 0.51461
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-284 Table 6.14 NBSR LEU HAC Single Package Results (No Additional Materials)
Additional Fuel Plate Spacing (cm)
Axial Gap Reduction (cm) ksafe Series 1: Fuel Plate Spacing 0.00 0
0.41491
-0.10 0
0.37573 0.10 0
0.44508 0.20 0
0.46574 0.30 0
0.48013 0.35 0
0.48391 Series 1.a: Axial Gap Reduction 0.35 0.0 0.48391 0.35
-1.0 0.48216 0.35 1.0 0.48720 0.35 2.0 0.49136 0.35 3.0 0.49496 0.35 4.0 0.50060 0.35 5.0 0.50674 Series 1.b: Overlapping Plate Sets 0.49491
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-285 Table 6.14 NBSR LEU HAC Single Package Results (Constant Spacing)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Outer Shell Water Density (g/cm3)
Polyethylene Location ksafe Series 4: Water Density Adjustment (Maximum Transverse Spacing, Minimum Axial Gap) 1 1
1 0.50674 0.9 1
1 0.47818 0.8 1
1 0.45045 1
0.9 1
0.49769 1
0.8 1
0.48948 1
1 0.9 0.50263 1
1 0.8 0.49941 Series 5: Homogenized Material Location (Maximum Transverse Spacing, Minimum Axial Gap) 1 1
1 Bag 0.50968 1
1 1
Inner Tube 0.50820
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-286 6.14.4.4 HAC Package Array Evaluation 6.14.4.4.1 Configuration The HAC package array baseline configuration is an array of packages, with fuel plates in each package angled towards the center of the array and full density pure water in the fuel plate bag, inner tube, and outer shell regions. Based on the HAC single package results, fuel plates are maximally spaced. For NBSR LEU, fuel plates are maximally spaced with the minimum axial gap. In the first series of cases, the water densities in the outer shell and inner tube are lowered to find the optimal level of moderation between packages. Then, the water density in the fuel plate bag is lowered to confirm that the individual fuel elements are under-moderated and thus maximum density moderator is most reactive. In the second series of cases, the two regions of water in the package cavity are homogenized with neoprene and/or polyethylene (as applicable) to determine the most reactive locations for those materials. Inner tube water density is adjusted after homogenization to verify the optimal density is being used.
The size of the HAC array is 5x5x1 for ATR LEU, MURR LEU, MIT LEU, and NBSR LEU.
6.14.4.4.2 Results HAC package array results are shown in Table 6.14-37 through Table 6.14-44. A significant reduction in inner tube and outer shell water density is required to optimize moderation. A significantly higher ksafe results from first reducing outer shell water density to zero and then reducing inner tube water density rather than the reverse. Like the HAC single package configuration, a reduction in fuel plate bag water density decreases ksafe showing that the individual fuel elements are under-moderated. With respect to neoprene and polyethylene, ksafe is maximized when these materials are homogenized with water within the package (though the effect is relatively small).
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-287 Table 6.14 ATR LEU HAC Package Array Results (No Additional Materials)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Outer Shell Water Density (g/cm3) ksafe Series 1: Water Density Adjustment (no additional spacing) 1 1
1 0.55409 1
0.5 1
0.53926 1
0 1
0.54163 1
0 0.5 0.60786 1
0 0.4 0.61965 1
0 0.3 0.62539 1
0 0.2 0.62352 1
0 0.1 0.60317 1
0 0
0.55048 1
1 0
0.71451 1
0.9 0
0.71905 1
0.8 0
0.72219 1
0.7 0
0.72334 1
0.6 0
0.72108 1
0.5 0
0.71500 0.9 0.7 0
0.70561 0.8 0.7 0
0.68797
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-288 Table 6.14 ATR LEU HAC Package Array Results (Void in Outer Shell)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Neoprene Location Polyethylene Location ksafe Series 2: Homogenized Material Location (no additional spacing) 1 0.7 Bag 0.70483 1
0.7 Bag 0.72503 1
0.7 Bag Bag 0.70738 1
0.6 Inner Tube 0.72223 1
0.7 Inner Tube 0.72468 1
0.8 Inner Tube 0.72260 1
0.6 Inner Tube 0.72200 1
0.7 Inner Tube 0.72357 1
0.8 Inner Tube 0.72077 1
0.6 Inner Tube Inner Tube 0.72296 1
0.7 Inner Tube Inner Tube 0.72402 1
0.8 Inner Tube Inner Tube 0.72218 1
0.6 Inner Tube Bag 0.72506 1
0.7 Inner Tube Bag 0.72607 1
0.8 Inner Tube Bag 0.72555
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-289 Table 6.14 MURR LEU HAC Package Array Results (No Additional Materials)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Outer Shell Water Density (g/cm3) ksafe Series 1: Water Density Adjustment (0.081 cm spacing) 1 1
1 0.69387 1
0.5 1
0.68303 1
0 1
0.70321 1
0 0.5 0.77612 1
0 0.3 0.79783 1
0 0.2 0.79887 1
0 0.1 0.78621 1
0 0
0.75823 1
1 0
0.85815 1
0.9 0
0.86123 1
0.8 0
0.86222 1
0.7 0
0.86123 1
0.6 0
0.85913 0.9 0.8 0
0.83494 0.8 0.8 0
0.81087
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-290 Table 6.14 MURR LEU HAC Package Array Results (Void in Outer Shell)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Neoprene Location Polyethylene Location ksafe Series 2: Homogenized Material Location (0.081 cm spacing) 1 0.8 Bag 0.85277 1
0.8 Bag 0.86412 1
0.8 Bag Bag 0.85625 1
0.6 Inner Tube 0.85909 1
0.7 Inner Tube 0.86102 1
0.8 Inner Tube 0.86181 1
0.9 Inner Tube 0.86113 1
1 Inner Tube 0.86038 1
0.6 Inner Tube 0.86038 1
0.7 Inner Tube 0.86159 1
0.8 Inner Tube 0.86171 1
0.9 Inner Tube 0.85956 1
1 Inner Tube 0.85777 1
0.6 Inner Tube Inner Tube 0.86025 1
0.7 Inner Tube Inner Tube 0.86322 1
0.8 Inner Tube Inner Tube 0.86236 1
0.9 Inner Tube Inner Tube 0.86153 1
1 Inner Tube Inner Tube 0.85890 1
0.7 Inner Tube Bag 0.86481 1
0.8 Inner Tube Bag 0.86625 1
0.9 Inner Tube Bag 0.86565
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-291 Table 6.14 MIT LEU HAC Package Array Results (No Additional Materials)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Outer Shell Water Density (g/cm3) ksafe Series 1: Water Density Adjustment (0.16 cm spacing) 1 1
1 0.59418 1
0.5 1
0.56734 1
0 1
0.57223 1
0 0.5 0.62684 1
0 0.4 0.63504 1
0 0.3 0.64180 1
0 0.2 0.63851 1
0 0.1 0.62576 1
1 0
0.71703 1
0.9 0
0.72087 1
0.8 0
0.72086 1
0.7 0
0.72276 1
0.6 0
0.71887 1
0.5 0
0.71277 0.9 0.7 0
0.69897 0.8 0.7 0
0.67818
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-292 Table 6.14 MIT LEU HAC Package Array Results (Void in Outer Shell)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Neoprene Location Polyethylene Location ksafe Series 2: Homogenized Material Location (0.16 cm spacing) 1 0.7 Bag 0.71042 1
0.7 Bag 0.72449 1
0.7 Bag Bag 0.71468 1
0.5 Inner Tube 0.71423 1
0.6 Inner Tube 0.71903 1
0.7 Inner Tube 0.72189 1
0.8 Inner Tube 0.72216 1
0.9 Inner Tube 0.72228 1
1 Inner Tube 0.71873 1
0.5 Inner Tube 0.71410 1
0.6 Inner Tube 0.71825 1
0.7 Inner Tube 0.72301 1
0.8 Inner Tube 0.72222 1
0.9 Inner Tube 0.72156 1
1 Inner Tube 0.71655 1
0.5 Inner Tube Inner Tube 0.71487 1
0.6 Inner Tube Inner Tube 0.71970 1
0.7 Inner Tube Inner Tube 0.72231 1
0.8 Inner Tube Inner Tube 0.72289 1
0.9 Inner Tube Inner Tube 0.72117 1
1 Inner Tube Inner Tube 0.71900 1
0.7 Inner Tube Bag 0.72656 1
0.8 Inner Tube Bag 0.72735 1
0.9 Inner Tube Bag 0.72551 1
1 Inner Tube Bag 0.72280
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-293 Table 6.14 NBSR LEU HAC Package Array Results (No Additional Materials)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Outer Shell Water Density (g/cm3) ksafe Series 1: Water Density Adjustment (Maximum Transverse Spacing, Minimum Axial Gap) 1 1
1 0.61401 1
0.5 1
0.60045 1
0 0
0.66893 1
0 0.5 0.64935 1
0 0.4 0.66184 1
0 0.3 0.67187 1
0 0.2 0.67958 1
0 0.1 0.67985 1
0 0
0.66893 1
1 0.1 0.64668 1
1 0
0.74301 1
0.9 0
0.74621 1
0.8 0
0.74596 1
0.7 0
0.74612 1
0.6 0
0.74448 1
0.5 0
0.74017 0.9 0.9 0
0.72321 0.8 0.9 0
0.69974 Table 6.14 NBSR LEU HAC Package Array Results (Void in Outer Shell)
Bag Water Density (g/cm3)
Inner Tube Water Density (g/cm3)
Polyethylene Location ksafe Series 2: Homogenized Material Location (Maximum Transverse Spacing, Minimum Axial Gap) 1 0.9 Bag 0.74795 1
1 Inner Tube 0.74325 1
0.9 Inner Tube 0.74599 1
0.8 Inner Tube 0.74897 1
0.7 Inner Tube 0.74840 1
0.6 Inner Tube 0.74569
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-294 6.14.5 Fissile Material Packages for Air Transport To demonstrate compliance with the requirements for air transport of fissile material in 10 CFR 71.55(f), a separate analysis is performed in which any structural integrity of the package is not credited. The fissile material from a single package is modeled as a sphere that is moderated solely by package materials and may be reflected by other package materials and water. This methodology is consistent with the air transport analysis in Section 6.7. This analysis uses conservative material quantities to bound ATR, MURR, MIT, and NBSR LEU fuel elements and/or DDEs.
6.14.5.1 Configuration The air transport configuration is a sphere of fissile material surrounded by 20 cm of water. For air transport analysis, the fissile sphere may be moderated by package materials but it is assumed that there is no water inleakage [8]. To optimally moderate the fissile sphere, a bounding quantity of uranium fuel is mixed with increasing amounts of moderating material that may be present in the ATR FFSC. Moderating materials are neoprene, polyethylene, and wood. Wood represents cellulosic materials (such as cardboard dunnage). The wood density used (see Table 6.14-21) is for relatively dense wood and is higher than that for cellulosic materials. This is conservative as it results in a smaller fissile sphere volume for the same wood mass, minimizing neutron leakage. Only pure water is used as a reflector as there are no package structural materials which would function as a superior reflector.
Two series of cases are performed. In the first series, increasing amounts of moderating material are added to the fissile sphere to optimize moderation. In the second series, the fissile sphere is reconfigured to consist of two regions: a central fuel-moderator sphere and an outer fuel-only layer. The total mass of fuel is kept constant in the second series. The single-region configuration is shown in Figure 6.14-9, with the fuel-moderator region in red and the surrounding 20 cm of water in blue.
To bound any enrichment of U-235, the uranium fuel is modeled as U-235 only. The density of U-235 is set to 18.76 g/cm3, which is calculated based on the density of pure U-233 (18.60 g/cm3 per [9]) multiplied by the ratio of mass numbers. Material limits are 2000 g U-235, 1500 g neoprene, 200 g polyethylene, and 4000 g wood material. The neoprene mass limit represents real-world neoprene mass (i.e. neoprene without chlorine removed) while modeling uses conservative, reduced mass neoprene with chlorine removed.
6.14.5.2 Results Air transport results are shown in Table 6.14-45. It can be seen that the single region fissile sphere is under-moderated and thus ksafe increases as moderating materials are added to the sphere. For the two-region fissile sphere, moving U-235 to the outer region increases ksafe initially before eventually peaking at an even split of U-235.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-295 Figure 6.14 Air Transport Model, Single Region Table 6.14 Air Transport Results Inner Region U-235 Mass (g)
Outer Region U-235 Mass (g)
Neoprene Mass (g)
Polyethylene Mass (g)
Wood Mass (g) ksafe Series 1: Increasing Moderating Material 2000 0
0 0
0.52101 2000 0
100 0
0.52978 2000 0
200 0
0.56477 2000 500 200 0
0.57453 2000 1000 200 0
0.60509 2000 1500 200 0
0.63379 2000 1500 200 1000 0.63832 2000 1500 200 2000 0.65819 2000 1500 200 3000 0.67665 2000 1500 200 4000 0.69452 Series 2: Two Regions U-235 1900 100 1500 200 4000 0.69936 1500 500 1500 200 4000 0.70584 1200 800 1500 200 4000 0.70846 1100 900 1500 200 4000 0.70928 1000 1000 1500 200 4000 0.71171 900 1100 1500 200 4000 0.70911 800 1200 1500 200 4000 0.70790 500 1500 1500 200 4000 0.70398 100 1900 1500 200 4000 0.67082
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-296 6.14.6 Benchmark Evaluations Whisper-1.1 [7], a statistical analysis package distributed with MCNP6.2, is used for USL calculation. Whisper uses sensitivity profile data, as computed by MCNP, along with nuclear data covariance files to calculate USL for an input application. Sensitivity/uncertainty (S/U) techniques are used to guide the selection of benchmarks similar to the application.
Per [7], MCNP6-Whisper provides repeatable, quantitative, physics-based information to NCS analysts for determining USLs, replacing much of what used to be carried out based solely on expert judgment. Whisper-1.1 is maintained under the same SQA procedures as MCNP [10].
A detailed explanation of Whispers underlying theory is documented in [11].
The cases which result in the maximum ksafe for each fuel type are selected for evaluation with Whisper (worst-case NCT array for ATR LEU and worst-case HAC package array for MURR LEU, MITR LEU, and NBSR LEU). Additionally, since the air transport configuration is significantly different than ATR FFSC configurations, the air transport case which results in a maximum ksafe (two regions, maximum moderating materials, even split of U-235 between regions) is also evaluated. The cases are re-run in MCNP to generate sensitivity profiles, which are then input into Whisper for comparison to benchmark sensitivity profiles.
For MURR LEU, both the worst-case NCT package array and HAC package array cases are analyzed with Whisper since these cases have comparable ksafe values. It is determined that the NCT package array case results in a lower USL and thus instead serves as the basis for the MURR LEU USL.
6.14.6.1 Applicability of Benchmark Experiments Whisper-1.1 comes pre-packaged with 1,101 benchmarks, each with an MCNP input file and MCNP-generated sensitivity profile. The benchmarks based on experiments documented in the International Handbook of Evaluated Criticality Safety Benchmark Experiments [12] and are identified by experiment title and case number. The benchmarks inputs have been evaluated using the same ENDF/B-VII.1, 293.6 K continuous energy neutron cross-sections as were used for ATR FFSC criticality modeling. 113 benchmarks have been identified by the Whisper developers as statistical outliers and are excluded from comparisons.
The benchmarks selected by Whisper for calculation of USL are shown in Table 6.14-46 through Table 6.14-50. The similarity of a benchmark to the application is characterized by the correlation coefficient, ck, which is calculated by Whisper. Whisper-calculated correlation coefficients can range between zero (no correlation or anticorrelation) and one (perfect linear correlation). Per [12], at least 15 to 20 very highly correlated systems (ck 0.90) or 25 to 40 moderately correlated systems (ck 0.80) should be included in benchmark evaluations. These thresholds are satisfied for all cases except the ATR LEU, which only satisfies the moderately correlated systems threshold.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-297 Table 6.14 Whisper-Selected Application Benchmarks for ATR LEU Benchmark ck Benchmark ck Benchmark ck ieu-comp-therm-002-003 0.9204 leu-comp-therm-028-007 0.8657 heu-sol-therm-025-015 0.7502 leu-comp-therm-028-016 0.8946 leu-comp-therm-024-002 0.8611 heu-sol-therm-025-018 0.7489 leu-comp-therm-028-015 0.8945 leu-comp-therm-028-001 0.8589 heu-sol-therm-025-014 0.7442 leu-comp-therm-028-014 0.8943 leu-comp-therm-028-005 0.8572 heu-sol-therm-025-017 0.7409 leu-comp-therm-025-003 0.8939 leu-comp-therm-022-002 0.8478 heu-sol-therm-025-013 0.7391 leu-comp-therm-028-019 0.8935 leu-comp-therm-022-003 0.8464 heu-sol-therm-038-009 0.7367 leu-comp-therm-028-013 0.8933 leu-comp-therm-028-006 0.8440 heu-sol-therm-025-011 0.7348 leu-comp-therm-028-012 0.8932 leu-comp-therm-022-004 0.8418 heu-sol-therm-025-009 0.7337 leu-comp-therm-025-002 0.8931 leu-comp-therm-022-005 0.8393 heu-sol-therm-025-012 0.7324 leu-comp-therm-028-011 0.8926 leu-comp-therm-022-006 0.8384 heu-sol-therm-025-016 0.7318 leu-comp-therm-028-020 0.8910 leu-comp-therm-022-007 0.8380 heu-sol-therm-025-010 0.7289 leu-comp-therm-028-018 0.8899 heu-sol-therm-038-002 0.8320 leu-comp-therm-010-009 0.7250 leu-comp-therm-025-004 0.8891 heu-sol-therm-038-022 0.8283 heu-sol-therm-038-008 0.7215 leu-comp-therm-028-010 0.8841 leu-comp-therm-022-001 0.8228 heu-sol-therm-038-007 0.7087 leu-comp-therm-028-017 0.8824 heu-sol-therm-038-006 0.8197 leu-comp-therm-010-010 0.7077 leu-comp-therm-025-001 0.8749 heu-sol-therm-038-023 0.8152 heu-sol-therm-038-003 0.7067 leu-comp-therm-028-008 0.8706 leu-comp-therm-024-001 0.8077 heu-sol-therm-038-010 0.7054 leu-comp-therm-028-002 0.8705 heu-sol-therm-038-021 0.8020 heu-sol-therm-038-028 0.6967 leu-comp-therm-028-009 0.8700 heu-sol-therm-025-006 0.7596 leu-comp-therm-010-011 0.6949 leu-comp-therm-028-004 0.8684 heu-sol-therm-025-008 0.7566 leu-comp-therm-028-003 0.8673 heu-sol-therm-025-007 0.7534 Table 6.14 Whisper-Selected Application Benchmarks for MURR LEU Benchmark ck Benchmark ck Benchmark ck leu-comp-therm-025-002 0.9602 leu-comp-therm-028-007 0.9281 heu-sol-therm-038-022 0.8988 leu-comp-therm-025-003 0.9579 leu-comp-therm-028-008 0.9280 leu-comp-therm-028-006 0.8942 ieu-comp-therm-002-003 0.9550 leu-comp-therm-022-004 0.9273 heu-sol-therm-038-006 0.8935 leu-comp-therm-024-002 0.9492 leu-comp-therm-028-001 0.9257 heu-sol-therm-038-023 0.8909 leu-comp-therm-025-004 0.9481 leu-comp-therm-028-003 0.9239 heu-sol-therm-038-021 0.8807 leu-comp-therm-028-013 0.9461 leu-comp-therm-028-009 0.9225 heu-sol-therm-025-018 0.8510 leu-comp-therm-028-011 0.9460 leu-comp-therm-022-001 0.9216 leu-comp-therm-010-009 0.8495 leu-comp-therm-028-010 0.9452 leu-comp-therm-022-005 0.9212 heu-sol-therm-025-015 0.8484 leu-comp-therm-022-002 0.9442 leu-comp-therm-028-020 0.9209 heu-sol-therm-025-006 0.8477 leu-comp-therm-025-001 0.9417 leu-comp-therm-028-018 0.9202 heu-sol-therm-025-008 0.8469 leu-comp-therm-028-015 0.9399 leu-comp-therm-028-005 0.9192 heu-sol-therm-025-007 0.8451 leu-comp-therm-022-003 0.9379 leu-comp-therm-028-004 0.9187 heu-sol-therm-025-017 0.8449 leu-comp-therm-028-014 0.9364 leu-comp-therm-022-006 0.9077 heu-sol-therm-025-014 0.8444 leu-comp-therm-028-012 0.9343 leu-comp-therm-022-007 0.9060 heu-sol-therm-038-009 0.8438 leu-comp-therm-028-016 0.9331 leu-comp-therm-024-001 0.9057 leu-comp-therm-010-010 0.8405 leu-comp-therm-028-002 0.9305 leu-comp-therm-028-017 0.9048 heu-sol-therm-025-016 0.8389 leu-comp-therm-028-019 0.9303 heu-sol-therm-038-002 0.9016 heu-sol-therm-025-013 0.8383
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-298 Table 6.14 Whisper-Selected Application Benchmarks for MIT LEU Benchmark ck Benchmark ck Benchmark ck leu-comp-therm-024-002 0.9849 heu-sol-therm-025-008 0.9292 leu-comp-therm-028-008 0.9032 leu-comp-therm-022-004 0.9829 heu-sol-therm-025-014 0.9279 heu-sol-therm-038-003 0.9024 leu-comp-therm-025-003 0.9828 heu-sol-therm-025-017 0.9276 heu-sol-therm-038-028 0.9018 leu-comp-therm-022-003 0.9828 leu-comp-therm-028-016 0.9270 leu-comp-therm-028-005 0.8991 leu-comp-therm-025-004 0.9816 heu-sol-therm-025-009 0.9254 leu-comp-therm-010-009 0.8984 leu-comp-therm-022-005 0.9798 heu-sol-therm-025-011 0.9236 leu-comp-therm-028-003 0.8969 leu-comp-therm-022-002 0.9642 heu-sol-therm-025-016 0.9234 leu-comp-therm-007-010 0.8964 ieu-comp-therm-002-003 0.9634 heu-sol-therm-025-010 0.9233 leu-comp-therm-010-010 0.8961 leu-comp-therm-025-002 0.9610 heu-sol-therm-038-009 0.9231 leu-comp-therm-007-007 0.8955 leu-comp-therm-022-006 0.9595 leu-comp-therm-028-019 0.9220 heu-sol-therm-025-003 0.8951 leu-comp-therm-022-007 0.9569 heu-sol-therm-025-012 0.9211 leu-comp-therm-010-011 0.8947 heu-sol-therm-038-002 0.9532 heu-sol-therm-025-013 0.9195 heu-sol-therm-025-002 0.8927 heu-sol-therm-038-022 0.9506 leu-comp-therm-025-001 0.9188 heu-sol-therm-025-001 0.8925 heu-sol-therm-038-006 0.9492 leu-comp-therm-028-014 0.9187 heu-sol-therm-038-027 0.8919 leu-comp-therm-028-010 0.9476 leu-comp-therm-022-001 0.9160 heu-sol-therm-025-005 0.8918 heu-sol-therm-038-023 0.9475 heu-sol-therm-038-008 0.9148 heu-sol-therm-025-004 0.8913 heu-sol-therm-038-021 0.9418 leu-comp-therm-028-012 0.9145 leu-comp-therm-028-009 0.8910 leu-comp-therm-028-015 0.9409 leu-comp-therm-028-001 0.9124 leu-comp-therm-024-001 0.8873 leu-comp-therm-028-013 0.9398 leu-comp-therm-028-002 0.9103 heu-sol-therm-038-005 0.8865 leu-comp-therm-028-011 0.9397 leu-comp-therm-028-007 0.9089 heu-sol-therm-038-018 0.8865 heu-sol-therm-025-018 0.9319 heu-sol-therm-038-007 0.9066 heu-sol-therm-038-025 0.8865 heu-sol-therm-025-006 0.9312 heu-sol-therm-038-010 0.9066 heu-sol-therm-038-026 0.8862 heu-sol-therm-025-007 0.9311 leu-comp-therm-028-020 0.9062 heu-sol-therm-025-015 0.9310 leu-comp-therm-028-018 0.9045
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-299 Table 6.14 Whisper-Selected Application Benchmarks for NBSR LEU Benchmark ck Benchmark ck Benchmark ck ieu-comp-therm-002-003 0.9754 heu-sol-therm-025-018 0.9211 heu-sol-therm-038-008 0.8871 leu-comp-therm-025-004 0.9751 leu-comp-therm-028-019 0.9207 heu-sol-therm-025-001 0.8846 leu-comp-therm-022-005 0.9662 heu-sol-therm-025-014 0.9206 heu-sol-therm-025-002 0.8844 leu-comp-therm-022-006 0.9660 heu-sol-therm-025-011 0.9199 heu-sol-therm-025-004 0.8824 leu-comp-therm-022-007 0.9647 heu-sol-therm-025-010 0.9179 heu-sol-therm-025-005 0.8795 leu-comp-therm-025-003 0.9602 heu-sol-therm-025-013 0.9159 heu-sol-therm-038-007 0.8784 leu-comp-therm-022-004 0.9599 leu-comp-therm-028-010 0.9156 heu-sol-therm-038-010 0.8765 heu-sol-therm-038-002 0.9444 heu-sol-therm-025-012 0.9151 heu-sol-therm-038-003 0.8754 leu-comp-therm-024-002 0.9440 heu-sol-therm-025-017 0.9151 heu-sol-therm-038-028 0.8707 leu-comp-therm-022-003 0.9423 leu-comp-therm-028-013 0.9149 leu-sol-therm-004-001 0.8655 heu-sol-therm-038-022 0.9400 leu-comp-therm-025-002 0.9147 heu-comp-therm-002-008 0.8624 heu-sol-therm-025-006 0.9398 leu-comp-therm-028-011 0.9140 heu-comp-therm-002-007 0.8615 heu-sol-therm-038-006 0.9382 leu-comp-therm-028-020 0.9115 leu-comp-therm-028-002 0.8608 heu-sol-therm-025-007 0.9361 leu-comp-therm-028-018 0.9081 leu-sol-therm-004-002 0.8595 heu-sol-therm-025-008 0.9356 heu-sol-therm-025-016 0.9069 heu-comp-therm-002-009 0.8592 heu-sol-therm-038-023 0.9347 leu-comp-therm-028-014 0.9022 heu-comp-therm-002-014 0.8591 leu-comp-therm-028-015 0.9336 leu-comp-therm-022-002 0.8991 heu-comp-therm-002-006 0.8588 heu-sol-therm-038-021 0.9277 leu-comp-therm-028-012 0.8983 heu-sol-therm-043-002 0.8582 heu-sol-therm-025-015 0.9252 heu-sol-therm-038-009 0.8966 leu-comp-therm-028-001 0.8571 leu-comp-therm-028-016 0.9249 leu-comp-therm-028-017 0.8917 leu-comp-therm-028-007 0.8568 heu-sol-therm-025-009 0.9243 heu-sol-therm-025-003 0.8888 Table 6.14 Whisper-Selected Application Benchmarks for Air Transport Benchmark ck Benchmark ck Benchmark ck heu-sol-therm-009-003 0.9956 heu-sol-therm-019-002 0.9844 heu-sol-therm-019-003 0.9776 heu-sol-therm-001-008 0.9937 heu-sol-therm-009-001 0.9836 heu-comp-therm-002-012 0.9765 heu-sol-therm-001-007 0.9936 heu-sol-therm-001-005 0.9826 heu-comp-therm-002-004 0.9755 heu-sol-therm-043-001 0.9933 heu-comp-therm-002-011 0.9819 heu-comp-therm-002-020 0.9745 heu-sol-therm-001-003 0.9933 heu-comp-therm-002-002 0.9816 heu-sol-therm-025-004 0.9713 heu-sol-therm-001-004 0.9931 heu-sol-therm-050-004 0.9812 heu-sol-therm-025-001 0.9711 heu-sol-therm-001-002 0.9931 heu-sol-therm-050-006 0.9810 heu-sol-therm-025-002 0.9709 heu-sol-therm-001-001 0.9931 heu-sol-therm-050-002 0.9808 heu-comp-therm-002-013 0.9692 heu-sol-therm-050-005 0.9925 heu-sol-therm-050-008 0.9802 heu-comp-therm-002-005 0.9687 heu-sol-therm-009-002 0.9914 heu-sol-therm-050-001 0.9799 heu-sol-therm-038-011 0.9687 heu-sol-therm-010-001 0.9906 heu-comp-therm-002-024 0.9795 heu-sol-therm-038-012 0.9684 heu-sol-therm-050-011 0.9903 heu-comp-therm-002-001 0.9792 heu-sol-therm-038-001 0.9683 heu-comp-therm-002-018 0.9886 heu-sol-therm-050-010 0.9791 heu-comp-therm-002-025 0.9683 heu-comp-therm-002-023 0.9885 heu-comp-therm-002-003 0.9789 heu-sol-therm-038-004 0.9669 heu-sol-therm-019-001 0.9880 heu-sol-therm-025-005 0.9785 heu-sol-therm-038-005 0.9667 heu-comp-therm-002-019 0.9854 heu-sol-therm-011-002 0.9785 heu-sol-therm-001-006 0.9848 heu-sol-therm-011-001 0.9778
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-300 6.14.6.2 Bias Determination The USL is calculated based on the calculational margin, CM, and margin of subcriticality, MOS.
= 1 The calculational margin and margin of subcriticality are calculated using the following equations:
= () + ( ) +
= + +
Bias represents the systematic difference between calculations and benchmark experiments.
Bias uncertainty relates to the uncertainties in the calculations and benchmark experiments.
non-coverage is a non-coverage penalty which may be applied to the calculational margin if all selected benchmarks are too dissimilar to the application.
MOSsoftware is additional margin to address the impact of possible MCNP software errors.
MOSdata is additional margin for uncertainties in nuclear cross-section data.
MOSapplication is additional margin, as set by the analyst using expert judgment, to address other uncertainties or sources of error.
The Bias, Bias uncertainty, non-coverage, and MOSdata are calculated by Whisper based on the selected benchmarks. The MOSsoftware has been set to 0.005 based on the expert opinion of the software developers [11]. The MOSapplication is set to 0.05, which is the administrative margin traditionally used for transportation package criticality analysis.
Whisper results are shown in Table 6.14-51.
Table 6.14 Whisper Results Parameter ATR LEU MURR LEU MIT LEU NBSR LEU Air Transport Bias 0.01373 0.01367 0.01123 0.01036 0.01399 Bias uncertainty 0.00782 0.00788 0.00902 0.00873 0.02042 non-coverage 0.00000 0.00000 0.00000 0.00000 0.00000 MOSsoftware 0.00500 0.00500 0.00500 0.00500 0.00500 MOSdata 0.00403 0.00274 0.00187 0.00243 0.00191 MOSapplication 0.05000 0.05000 0.05000 0.05000 0.05000 USL 0.91942 0.92071 0.92288 0.92348 0.90868
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-301 6.14.7 References
- 1. ASTM A269, Standard Specification for Seamless and Welded Austenitic Stainless Steel Tubing for General Service, ASTM International, Revision 2a
- 2. ASTM A554, Standard Specification for Welded Stainless Steel Mechanical Tubing, ASTM International, Revision 3
- 3. LA-UR-17-22234, The Intrinsic Source Constructor Package: Installation and Use, Los Alamos National Laboratory, March 2017
- 4. LA-UR-17-20709, Listing of Available ACE Data Tables, Los Alamos National Laboratory, October 2017
- 5. PNNL-15870, Compendium of Material Composition Data for Radiation Transport Modeling, Pacific Northwest National Laboratory, Revision 1, March 2011
- 6. LA-UR-17-29981, MCNP User's Manual: Code Version 6.2, Los Alamos National Laboratory, October 2017, RSICC Package ID C850MNYCP00
- 7. LA-UR-17-20567, User Manual for Whisper-1.1, Los Alamos National Laboratory, January 2017
- 8. Title 10, "Energy", Code of Federal Regulations, Part 71, Packaging and Transportation of Radioactive Material
- 9. RFP-936, Calculated Critical Radii of Spheres of Plutonium 239 and Uranium 233 with Various Spherical Reflectors, The Dow Chemical Company, June 1967
- 10. LA-UR-17-24260, Release of MCNP6.2 & Whisper-1.1 - Guidance for NCS Users, Los Alamos National Laboratory, May 2017
- 11. B.C. Kiedrowski, F.B. Brown, et al., Whisper: Sensitivity/Uncertainty-Based Computational Methods and Software for Determining Baseline Upper Subcritical Limits, Retrieved from MCNP Reference Collection (Document No. LA-UR-14-26558)
- 12. NEA/NSC/DOC(95)03, International Handbook of Evaluated Criticality Safety Benchmark Experiments, Nuclear Energy Agency
- 13. B. L. Broadhead et al., Sensitivity-and Uncertainty-Based Criticality Safety Validation Techniques, Nuclear Science and Engineering 146, pages 340-366, March 2004
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-302 6.14.8 Sample Input File The case which results in the maximum ksafe value, the worst-case ATR LEU NCT package array, is shown below.
c===== Configuration Details c Bag Water Density: 1.0 c Inner Tube Water Density: 0.3 c Outer Shell Water Density: -
c Neoprene Location: Inner Tube c Polyethylene Location: Bag c Fuel Plate Additional Spacing: 0 c
c *** Cell Cards ***
c===== Universe 1: Fuel Plates c Fuel Foils 1 1 -16.5 1 -2 12 -13 15 16 imp:n=1 u=1 2 1 -16.5 1 -2 22 -23 25 26 imp:n=1 u=1 3 1 -16.5 1 -2 32 -33 35 36 imp:n=1 u=1 4 1 -16.5 1 -2 42 -43 45 46 imp:n=1 u=1 5 1 -16.5 1 -2 52 -53 55 56 imp:n=1 u=1 6 1 -16.5 1 -2 62 -63 65 66 imp:n=1 u=1 7 1 -16.5 1 -2 72 -73 75 76 imp:n=1 u=1 8 1 -16.5 1 -2 82 -83 85 86 imp:n=1 u=1 9 1 -16.5 1 -2 92 -93 95 96 imp:n=1 u=1 10 1 -16.5 1 -2 102 -103 105 106 imp:n=1 u=1 11 1 -16.5 1 -2 112 -113 115 116 imp:n=1 u=1 12 1 -16.5 1 -2 122 -123 125 126 imp:n=1 u=1 13 1 -16.5 1 -2 132 -133 135 136 imp:n=1 u=1 14 1 -16.5 1 -2 142 -143 145 146 imp:n=1 u=1 15 1 -16.5 1 -2 152 -153 155 156 imp:n=1 u=1 16 1 -16.5 1 -2 162 -163 165 166 imp:n=1 u=1 17 1 -16.5 1 -2 172 -173 175 176 imp:n=1 u=1 18 1 -16.5 1 -2 182 -183 185 186 imp:n=1 u=1 19 1 -16.5 1 -2 192 -193 195 196 imp:n=1 u=1 c
c Cladding 101 2 -2.7 11 -14 17 18 (-1:2:-12 :13 :-15 :-16) imp:n=1 u=1 102 2 -2.7 21 -24 27 28 (-1:2:-22 :23 :-25 :-26) imp:n=1 u=1 103 2 -2.7 31 -34 37 38 (-1:2:-32 :33 :-35 :-36) imp:n=1 u=1 104 2 -2.7 41 -44 47 48 (-1:2:-42 :43 :-45 :-46) imp:n=1 u=1 105 2 -2.7 51 -54 57 58 (-1:2:-52 :53 :-55 :-56) imp:n=1 u=1 106 2 -2.7 61 -64 67 68 (-1:2:-62 :63 :-65 :-66) imp:n=1 u=1 107 2 -2.7 71 -74 77 78 (-1:2:-72 :73 :-75 :-76) imp:n=1 u=1 108 2 -2.7 81 -84 87 88 (-1:2:-82 :83 :-85 :-86) imp:n=1 u=1 109 2 -2.7 91 -94 97 98 (-1:2:-92 :93 :-95 :-96) imp:n=1 u=1 110 2 -2.7 101 -104 107 108 (-1:2:-102:103:-105:-106) imp:n=1 u=1 111 2 -2.7 111 -114 117 118 (-1:2:-112:113:-115:-116) imp:n=1 u=1 112 2 -2.7 121 -124 127 128 (-1:2:-122:123:-125:-126) imp:n=1 u=1 113 2 -2.7 131 -134 137 138 (-1:2:-132:133:-135:-136) imp:n=1 u=1 114 2 -2.7 141 -144 147 148 (-1:2:-142:143:-145:-146) imp:n=1 u=1 115 2 -2.7 151 -154 157 158 (-1:2:-152:153:-155:-156) imp:n=1 u=1 116 2 -2.7 161 -164 167 168 (-1:2:-162:163:-165:-166) imp:n=1 u=1 117 2 -2.7 171 -174 177 178 (-1:2:-172:173:-175:-176) imp:n=1 u=1 118 2 -2.7 181 -184 187 188 (-1:2:-182:183:-185:-186) imp:n=1 u=1 119 2 -2.7 191 -194 197 198 (-1:2:-192:193:-195:-196) imp:n=1 u=1 c
c Volume between Fuel Plates (i.e. inside bag) 191 6 -0.996 (-11 :14 :-17 :-18) (-21 :24 :-27 :-28) (-31 :34 :-37 :-38)
(-41 :44 :-47 :-48) (-51 :54 :-57 :-58) (-61 :64 :-67 :-68)
(-71 :74 :-77 :-78) (-81 :84 :-87 :-88) (-91 :94 :-97 :-98)
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-303
(-101:104:-107:-108) (-111:114:-117:-118) (-121:124:-127:-128)
(-131:134:-137:-138) (-141:144:-147:-148) (-151:154:-157:-158)
(-161:164:-167:-168) (-171:174:-177:-178) (-181:184:-187:-188)
(-191:194:-197:-198)
((27 28 14 -21):(37 38 24 -31):(47 48 34 -41):(57 58 44 -51):
(67 68 54 -61):(77 78 64 -71):(87 88 74 -81):(97 98 84 -91):
(107 108 94 -101):(117 118 104 -111):(127 128 114 -121):
(137 138 124 -131):(147 148 134 -141):(157 158 144 -151):
(167 168 154 -161):(177 178 164 -171):(187 188 174 -181):
(197 198 184 -191)) imp:n=1 u=1 c
c Volume around Fuel Plates 192 7 -0.329 -11:(11 -14 (-17:-18)):(14 -24 (-27:-28)):(24 -34 (-37:-38)):
(34 -44 (-47:-48)):(44 -54 (-57:-58)):(54 -64 (-67:-68)):
(64 -74 (-77:-78)):(74 -84 (-87:-88)):(84 -94 (-97:-98)):
(94 -104 (-107:-108)):(104 -114 (-117:-118)):(114 -124 (-127:-128)):
(124 -134 (-137:-138)):(134 -144 (-147:-148)):(144 -154 (-157:-158)):
(154 -164 (-167:-168)):(164 -174 (-177:-178)):(174 -184 (-187:-188)):
(184 -194 (-197:-198)):194 imp:n=1 u=1 c
c===== Container c== Universe 20/30: Fuel Plates Centered in Container 201 0 -201 fill=1 (100) imp:n=1 u=20 202 4 -8.0 -202 201 imp:n=1 u=20 203 5 -0.096 -203 202 -204.1 -204.2 -204.3 -204.4 imp:n=1 u=20 204 0 203 -204.1 -204.2 -204.3 -204.4 imp:n=1 u=20 205 4 -8.0 204.1: 204.2: 204.3: 204.4 imp:n=1 u=20 306 4 -8.0 -205 fill=20 imp:n=1 u=30 307 3 -1.0 -206 205 imp:n=1 u=30 308 0 206 imp:n=0 u=30 c
c== Universe 21: Fuel Plates Straight-Shifted in Container 211 like 201 but fill=1 (101) u=21 212 like 202 but u=21 213 like 203 but u=21 214 like 204 but u=21 215 like 205 but u=21 c
c== Universe 22: Fuel Plates Diagonally-Shifted in Container 221 like 201 but fill=1 (102) u=22 222 like 202 but u=22 223 like 203 but u=22 224 like 204 but u=22 225 like 205 but u=22 c
c== Universe 31: Fuel Plates Straight-Shifted in Container, 0 deg Rotation 316 like 306 but fill=21 u=31 317 like 307 but u=31 318 like 308 but u=31 c
c== Universe 32: Fuel Plates Straight-Shifted in Container, 90 deg Rotation 326 like 306 but fill=21 (201) u=32 327 like 307 but u=32 328 like 308 but u=32 c
c== Universe 33: Fuel Plates Straight-Shifted in Container, 180 deg Rotation 336 like 306 but fill=21 (202) u=33 337 like 307 but u=33 338 like 308 but u=33 c
c== Universe 34: Fuel Plates Straight-Shifted in Container, 270 deg Rotation 346 like 306 but fill=21 (203) u=34 347 like 307 but u=34
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-304 348 like 308 but u=34 c
c== Universe 35: Fuel Plates Diagonally-Shifted in Container, 0 deg Rotation 356 like 306 but fill=22 u=35 357 like 307 but u=35 358 like 308 but u=35 c
c== Universe 36: Fuel Plates Diagonally-Shifted in Container, 90 deg Rotation 366 like 306 but fill=22 (201) u=36 367 like 307 but u=36 368 like 308 but u=36 c
c== Universe 37: Fuel Plates Diagonally-Shifted in Container, 180 deg Rotation 376 like 306 but fill=22 (202) u=37 377 like 307 but u=37 378 like 308 but u=37 c
c== Universe 38: Fuel Plates Diagonally-Shifted in Container, 270 deg Rotation 386 like 306 but fill=22 (203) u=38 387 like 307 but u=38 388 like 308 but u=38 c
c===== Array 1001 0 -301 imp:n=1 u=4 lat=1 fill=-3:4 -3:4 0:0 38 38 38 31 31 35 35 35 38 38 38 31 31 35 35 35 38 38 38 31 31 35 35 35 34 34 34 38 35 32 32 32 34 34 34 37 36 32 32 32 37 37 37 33 33 36 36 36 37 37 37 33 33 36 36 36 37 37 37 33 33 36 36 36 1002 0 -302 fill=4 imp:n=1 1003 3 -1.0 -303 302 imp:n=1 1004 0 303 imp:n=0 c
c===== Visualization Universes c All materials defined in unused universes for consistent c VisEd material color map between models 9991 1 1 imp:n=1 u=91 9992 2 1 imp:n=1 u=92 9993 3 1 imp:n=1 u=93 9994 4 1 imp:n=1 u=94 9995 5 1 imp:n=1 u=95 9996 6 1 imp:n=1 u=96 9997 7 1 imp:n=1 u=97 c *** Surface Cards ***
c===== Fuel Plates 1 pz -61.2775 $ Bottom of fuel meat 2 pz 61.2775 $ Top of fuel meat c
c Fuel Plate Inner Radius 11 1 cz 7.6441 21 2 cz 8.0480 31 3 cz 8.3731 41 4 cz 8.6957 51 5 cz 9.0208 61 6 cz 9.3459 71 7 cz 9.6711 81 8 cz 9.9962 91 9 cz 10.3213
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-305 101 10 cz 10.6464 111 11 cz 10.9715 121 12 cz 11.2967 131 13 cz 11.6218 141 14 cz 11.9444 151 15 cz 12.2695 161 16 cz 12.5946 171 17 cz 12.9197 181 18 cz 13.2448 191 19 cz 13.5674 c
c Fuel Foil Inner Radius 12 1 cz 7.7343 22 2 cz 8.0937 32 3 cz 8.4188 42 4 cz 8.7376 52 5 cz 9.0627 62 6 cz 9.3878 72 7 cz 9.7130 82 8 cz 10.0381 92 9 cz 10.3632 102 10 cz 10.6883 112 11 cz 11.0134 122 12 cz 11.3386 132 13 cz 11.6637 142 14 cz 11.9863 152 15 cz 12.3114 162 16 cz 12.6403 172 17 cz 12.9718 182 18 cz 13.2969 192 19 cz 13.6830 c
c Fuel Foil Outer Radius 13 1 cz 7.7546 23 2 cz 8.1267 33 3 cz 8.4519 43 4 cz 8.7782 53 5 cz 9.1034 63 6 cz 9.4285 73 7 cz 9.7536 83 8 cz 10.0787 93 9 cz 10.4038 103 10 cz 10.7290 113 11 cz 11.0541 123 12 cz 11.3792 133 13 cz 11.7043 143 14 cz 12.0269 153 15 cz 12.3520 163 16 cz 12.6733 173 17 cz 12.9921 183 18 cz 13.3172 193 19 cz 13.7033 c
c Fuel Plate Outer Radius 14 1 cz 7.8448 24 2 cz 8.1724 34 3 cz 8.4976 44 4 cz 8.8201 54 5 cz 9.1453 64 6 cz 9.4704 74 7 cz 9.7955 84 8 cz 10.1206 94 9 cz 10.4458
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-306 104 10 cz 10.7709 114 11 cz 11.0960 124 12 cz 11.4211 134 13 cz 11.7462 144 14 cz 12.0688 154 15 cz 12.3939 164 16 cz 12.7190 174 17 cz 13.0442 184 18 cz 13.3693 194 19 cz 13.8189 c
c Fuel Foil Arcs 15 1 p 0 0 0 0 0 1 0.2983 0.9545 0 16 1 p 0 0 0 0 0 1 -0.2983 0.9545 0 25 2 p 0 0 0 0 0 1 0.3021 0.9533 0 26 2 p 0 0 0 0 0 1 -0.3021 0.9533 0 35 3 p 0 0 0 0 0 1 0.3052 0.9523 0 36 3 p 0 0 0 0 0 1 -0.3052 0.9523 0 45 4 p 0 0 0 0 0 1 0.3081 0.9513 0 46 4 p 0 0 0 0 0 1 -0.3081 0.9513 0 55 5 p 0 0 0 0 0 1 0.3109 0.9504 0 56 5 p 0 0 0 0 0 1 -0.3109 0.9504 0 65 6 p 0 0 0 0 0 1 0.3133 0.9496 0 66 6 p 0 0 0 0 0 1 -0.3133 0.9496 0 75 7 p 0 0 0 0 0 1 0.3157 0.9488 0 76 7 p 0 0 0 0 0 1 -0.3157 0.9488 0 85 8 p 0 0 0 0 0 1 0.3179 0.9481 0 86 8 p 0 0 0 0 0 1 -0.3179 0.9481 0 95 9 p 0 0 0 0 0 1 0.3200 0.9474 0 96 9 p 0 0 0 0 0 1 -0.3200 0.9474 0 105 10 p 0 0 0 0 0 1 0.3218 0.9468 0 106 10 p 0 0 0 0 0 1 -0.3218 0.9468 0 115 11 p 0 0 0 0 0 1 0.3236 0.9462 0 116 11 p 0 0 0 0 0 1 -0.3236 0.9462 0 125 12 p 0 0 0 0 0 1 0.3254 0.9456 0 126 12 p 0 0 0 0 0 1 -0.3254 0.9456 0 135 13 p 0 0 0 0 0 1 0.3270 0.9450 0 136 13 p 0 0 0 0 0 1 -0.3270 0.9450 0 145 14 p 0 0 0 0 0 1 0.3286 0.9445 0 146 14 p 0 0 0 0 0 1 -0.3286 0.9445 0 155 15 p 0 0 0 0 0 1 0.3300 0.9440 0 156 15 p 0 0 0 0 0 1 -0.3300 0.9440 0 165 16 p 0 0 0 0 0 1 0.3314 0.9435 0 166 16 p 0 0 0 0 0 1 -0.3314 0.9435 0 175 17 p 0 0 0 0 0 1 0.3326 0.9431 0 176 17 p 0 0 0 0 0 1 -0.3326 0.9431 0 185 18 p 0 0 0 0 0 1 0.3339 0.9426 0 186 18 p 0 0 0 0 0 1 -0.3339 0.9426 0 195 19 p 0 0 0 0 0 1 0.3352 0.9421 0 196 19 p 0 0 0 0 0 1 -0.3352 0.9421 0 c
c Fuel Plate Arcs 17 1 p 0 0 0 0 0 1 0.3418 0.9398 0 18 1 p 0 0 0 0 0 1 -0.3418 0.9398 0 27 2 p 0 0 0 0 0 1 0.3348 0.9423 0 28 2 p 0 0 0 0 0 1 -0.3348 0.9423 0 37 3 p 0 0 0 0 0 1 0.3366 0.9417 0 38 3 p 0 0 0 0 0 1 -0.3366 0.9417 0 47 4 p 0 0 0 0 0 1 0.3383 0.9410 0 48 4 p 0 0 0 0 0 1 -0.3383 0.9410 0 57 5 p 0 0 0 0 0 1 0.3400 0.9404 0 58 5 p 0 0 0 0 0 1 -0.3400 0.9404 0 67 6 p 0 0 0 0 0 1 0.3414 0.9399 0
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-307 68 6 p 0 0 0 0 0 1 -0.3414 0.9399 0 77 7 p 0 0 0 0 0 1 0.3428 0.9394 0 78 7 p 0 0 0 0 0 1 -0.3428 0.9394 0 87 8 p 0 0 0 0 0 1 0.3441 0.9389 0 88 8 p 0 0 0 0 0 1 -0.3441 0.9389 0 97 9 p 0 0 0 0 0 1 0.3454 0.9385 0 98 9 p 0 0 0 0 0 1 -0.3454 0.9385 0 107 10 p 0 0 0 0 0 1 0.3464 0.9381 0 108 10 p 0 0 0 0 0 1 -0.3464 0.9381 0 117 11 p 0 0 0 0 0 1 0.3475 0.9377 0 118 11 p 0 0 0 0 0 1 -0.3475 0.9377 0 127 12 p 0 0 0 0 0 1 0.3485 0.9373 0 128 12 p 0 0 0 0 0 1 -0.3485 0.9373 0 137 13 p 0 0 0 0 0 1 0.3495 0.9369 0 138 13 p 0 0 0 0 0 1 -0.3495 0.9369 0 147 14 p 0 0 0 0 0 1 0.3504 0.9366 0 148 14 p 0 0 0 0 0 1 -0.3504 0.9366 0 157 15 p 0 0 0 0 0 1 0.3513 0.9363 0 158 15 p 0 0 0 0 0 1 -0.3513 0.9363 0 167 16 p 0 0 0 0 0 1 0.3521 0.9360 0 168 16 p 0 0 0 0 0 1 -0.3521 0.9360 0 177 17 p 0 0 0 0 0 1 0.3528 0.9357 0 178 17 p 0 0 0 0 0 1 -0.3528 0.9357 0 187 18 p 0 0 0 0 0 1 0.3536 0.9354 0 188 18 p 0 0 0 0 0 1 -0.3536 0.9354 0 197 19 p 0 0 0 0 0 1 0.3596 0.9331 0 198 19 p 0 0 0 0 0 1 -0.3596 0.9331 0 c
c===== Container 201 cz 7.3838 $ IR pipe 202 cz 7.6581 $ OR pipe 203 cz 10.1981 $ 1" insulation 204 rpp -9.6032 9.6032 $ Square Tube Inner Surface
-9.6032 9.6032
-999 999 205 rpp -10.033 10.033 $ Square Tube Outer Surface
-10.033 10.033
-61.278 61.278 206 rpp -40.513 40.513 $ 12" Water Reflection
-40.513 40.513
-91.758 91.758 c
c===== Array 301 rpp -10.03 10.03 $ Array cell
-10.03 10.03
-61.277 61.277 302 rpp -70.209 90.269 $ 8x8 Array boundary
-70.209 90.269
-61.276 61.276 303 rpp -100.69 120.75 $ 12" Water Reflection
-100.69 120.75
-91.759 91.759 c *** Data Cards ***
c===== Transformations tr1 0 0 0 $ Fuel Plate 1 tr2 0 0 0 $ Fuel Plate 2 tr3 0 0 0 $ Fuel Plate 3 tr4 0 0 0 $ Fuel Plate 4 tr5 0 0 0 $ Fuel Plate 5 tr6 0 0 0 $ Fuel Plate 6 tr7 0 0 0 $ Fuel Plate 7 tr8 0 0 0 $ Fuel Plate 8
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-308 tr9 0 0 0 $ Fuel Plate 9 tr10 0 0 0 $ Fuel Plate 10 tr11 0 0 0 $ Fuel Plate 11 tr12 0 0 0 $ Fuel Plate 12 tr13 0 0 0 $ Fuel Plate 13 tr14 0 0 0 $ Fuel Plate 14 tr15 0 0 0 $ Fuel Plate 15 tr16 0 0 0 $ Fuel Plate 16 tr17 0 0 0 $ Fuel Plate 17 tr18 0 0 0 $ Fuel Plate 18 tr19 0 0 0 $ Fuel Plate 19 c
tr100 0 -10.70864 0 $ Fuel Plates Centered in Container tr101 0 -7.5 0 $ Fuel Plates Straight-Shifted in Container
- tr102 5.3033 -5.3033 0 $ Fuel Plates Diagonally-Shifted in Container 45 45 90 135 45 90 c
- tr201 0 0 0 90 0 90 180 90 90 $ 90 deg Rotation CCW
- tr202 0 0 0 180 90 90 -90 180 90 $ 180 deg Rotation CCW
- tr203 0 0 0 -90 180 90 0 -90 90 $ 270 deg Rotation CCW c===== Materials c===============================================
c U-10Mo Fuel c Density = 16.5 g/cm^3 c
Reference:
FOR-158 c===============================================
m1 42092 -1.273450e-02 42094 -8.131011e-03 42095 -1.415610e-02 42096 -1.500685e-02 42097 -8.690852e-03 42098 -2.221755e-02 42100 -9.063129e-03 92232 -1.820000e-09 92234 -2.366000e-03 92235 -1.815450e-01 92236 -4.186000e-03 92238 -7.219030e-01 c===============================================
c Aluminum 6061-O c Density = 2.7 g/cm^3 c
Reference:
PNNL-15870 Rev. 1 c===============================================
mt2 al27 m2 12024 -7.794921e-03 12025 -1.028000e-03 12026 -1.176980e-03 13027 -9.719903e-01 14028 -5.511934e-03 14029 -2.900148e-04 14030 -1.979911e-04 22046 -6.969614e-05 22047 -6.421984e-05 22048 -6.498300e-04 22049 -4.868279e-05 22050 -4.756247e-05 24050 -8.138607e-05 24052 -1.632121e-03 24053 -1.886331e-04 24054 -4.784012e-05 25055 -8.799912e-04 26054 -2.309010e-04 26056 -3.758735e-03
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-309 26057 -8.835819e-05 26058 -1.196495e-05 29063 -1.883159e-03 29065 -8.668135e-04 30064 -6.887649e-04 30066 -4.116611e-04 30067 -6.127886e-05 30068 -2.884319e-04 30070 -9.848649e-06 c===============================================
c Water, Liquid c Density = 1.0 g/cm^3 c
Reference:
PNNL-15870 Rev. 1 c===============================================
mt3 lwtr m3 1001 -1.118683E-01 1002 -2.571290E-05 8016 -8.877466E-01 8017 -3.593967E-04 c===============================================
c Steel, Stainless 304 c Density = 8.0 g/cm^3 c
Reference:
PNNL-15870 Rev. 1 c===============================================
mt4 fe56 m4 6000 -3.999960e-04 14028 -4.593278e-03 14029 -2.416790e-04 14030 -1.649926e-04 15031 -2.299977e-04 16032 -1.420716e-04 16033 -1.156799e-06 16034 -6.753296e-06 16036 -1.682534e-08 24050 -7.929925e-03 24052 -1.590272e-01 24053 -1.837963e-02 24054 -4.661345e-03 25055 -9.999900e-03 26054 -3.961618e-02 26056 -6.448942e-01 26057 -1.515980e-02 26058 -2.052851e-03 28058 -6.215726e-02 28060 -2.476752e-02 28061 -1.094596e-03 28062 -3.547175e-03 28064 -9.325298e-04 c===============================================
c Durablanket S c Density = 0.096 g/cm^3 c
Reference:
Assumed/defined in SAR c===============================================
m5 8016 -5.012956E-01 8017 -2.029452E-04 13027 -2.647353E-01 14028 -2.147528E-01 14029 -1.129939E-02 14030 -7.714015E-03 c===============================================
c Homogenized Moderator #1 c
Reference:
Python Notebook c===============================================
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 6-310 mt6 lwtr m6 1001 -3.802814e+02 1002 -8.740757e-02 6000 -1.712568e+02 8016 -2.789733e+03 8017 -1.129400e+00 c===============================================
c Homogenized Moderator #2 c
Reference:
Python Notebook c===============================================
mt7 lwtr m7 1001 -5.483401e+02 1002 -1.260358e-01 6000 -6.848088e+02 8016 -3.781528e+03 8017 -1.530920e+00 c
c===== Source and Run Setup mode n kcode 10000 1.0 50 250 sdef x=d1 y=d2 z=d3 si1 H -60 80 sp1 D 0 1 si2 H -60 80 sp2 D 0 1 si3 H -61.2775 61.2775 sp3 D 0 1 c
prdmp j 50 0 1 50
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 7-1 7.0 PACKAGE OPERATIONS This section provides general instructions for loading and unloading operations of the ATR FFSC. Due to the low specific activity of neutron and gamma emitting radionuclides, dose rates from the contents of the package are minimal. As a result of the low dose rates, there are no special handling requirements for radiation protection.
Package loading and unloading operations shall be performed using detailed written procedures.
The operating procedures developed by the user for the loading and unloading activities shall be performed in accordance with the procedural requirements identified in the following sections.
The closure handle must be rendered inoperable for lifting and tiedown during transport per 10 CFR §71.45. To satisfy this requirement either the closure handle may be removed or the cover installed. If the closure handle cover is utilized it may be stored with the closure assembly in the installed position. When stored with the closure assembly the cover must be removed prior to the package loading and unloading operations and may be reinstalled following installation of the closure. The installation of the closure handle cover is presented in Section 7.1.7, Preparation for Transport.
7.1 Package Loading 7.1.1 Preparation for Loading Prior to loading the ATR FFSC, the packaging is inspected to ensure that it is in unimpaired physical condition. The packaging is inspected for:
Damage to the closure locking mechanism including the spring. Inspect for missing hardware and verify the locking pins freely engage/disengage with the package body mating features.
Damage to the closure lugs and interfacing body lugs. Inspect lugs for damage that precludes free engagement of the closure with the body.
Deformation of the inner shell (payload cavity) that precludes free entry/removal of the payload.
Deformed threads or other damage to the fasteners or body of the loose fuel plate basket.
Damage to the spring plunger, or ball lock pins and end spacers, as applicable, or body of the fuel handling enclosure.
Acceptance criteria and detailed loading procedures derived from this section are specified in user written procedures. These user procedures are specific to the authorized content of the package and inspections ensure the packaging complies with Appendix 1.3.2, Packaging General Arrangement Drawings.
Defects that require repair shall be corrected prior to shipping in accordance with approved procedures consistent with the quality program in effect.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 7-2 7.1.2 Loading of Contents - ATR HEU or LEU Fuel Element Note: This section applies to the fuel handling enclosure depicted on SAR drawing 60501-30, as summarized in Table 7.1-1.
- 1. Remove the closure by depressing the spring-loaded pins and rotating the closure 45º to align the closure locking tabs with the mating cut-outs in the body. Remove the closure from the body.
- 2. Remove the fuel handling enclosure if present in the payload cavity.
- 3. Prior to loading, visually inspect the ATR fuel handling enclosure for damage, corrosion, and missing hardware to ensure compliance with Appendix 1.3.2, Packaging General Arrangement Drawings.
- 4. Open the ATR fuel handling enclosure lid and place a fuel element into the holder with the narrow end of the fuel element facing the bottom side of the fuel handling enclosure. As a property protection precaution, the fuel element may optionally be inserted into a polyethylene bag prior to placement in the fuel handling enclosure. Verify the total mass of polyethylene and any tape used to seal the bag is limited per Table 7.1-1.
- a. To open the fuel handling enclosure, release the lid by pulling on the spring plunger located at each end and rotate the lid about the hinged side.
- b. To close the fuel handling enclosure, rotate the lid to the closed position, pull the spring plunger located at each end to allow the lid to fully close, align then release the spring plungers with the receiving holes, gently lift the lid to confirm no movement and that the spring plungers are in the locked position.
- 5. Insert the fuel handling enclosure into the package.
- 6. Depress the package closure spring-loaded pins, insert closure onto package body by aligning the closure locking tabs with the mating cut-outs in the body, and rotate the closure to the locked position. Release the spring-loaded pins so that they engage with the mating holes in the package body. Observe the pins to ensure they are in the locked position as illustrated in Figure 7.1-1. The closure is fully locked when both locking pins are compressing the sleeve between the locking pin handle and the closure body.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 7-3 TID Optional TID Location With Closure Rotated 180° Locked Position Unlocked Position Contact Point When Disengaged Sleeve Compressed Between Locking Pin Handle And Closure Body When Engaged Sleeve Loose Figure 7.1 Closure Locking Positions 7.1.3 Loading of Contents - Loose ATR Fuel Plates
- 1. Remove the closure by depressing the spring-loaded pins and rotating the closure 45º to align the closure locking tabs with the mating cut-outs in the body. Remove the closure from the body.
- 2. Remove the fuel plate basket if present in the payload cavity. The fuel plate basket that pertains to this payload is depicted on SAR drawing 60501-20, as summarized in Table 7.1-1.
- 3. Prior to loading, visually inspect the loose fuel plate basket for damage, corrosion, and missing hardware/fastening devices to ensure compliance with Appendix 1.3.2, Packaging General Arrangement Drawings.
- 4. Open the loose fuel plate basket by removing the 8 wing nut fasteners securing each half of the basket.
- 5. Place the fuel plates into one half of the loose fuel plate basket
- a. Ensure the combined weight of the loose fuel plates and optional dunnage is 20 lbs or less. The loose fuel plates may only be ATR fuel plates.
- b. Ensure the combined fissile mass of the loose fuel plates does not exceed 600 g uranium-235.
- c. Flat and curved fuel plates may not be mixed in the same basket.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 7-4
- d. As a property protection precaution, the fuel plates may optionally be inserted into polyethylene bag(s) prior to placement in the fuel plate basket. Verify the total mass of polyethylene and any tape used to seal the bag is 100 g.
- e. Dunnage plates may also be included with the loose fuel plates to reduce any gaps with the basket cavity as a property protection precaution. The dunnage plates may be any aluminum alloy and any size deemed appropriate.
- 6. Close the fuel plate basket and verify the basket fasteners are installed and finger tight.
- a. With one half of the basket loaded, carefully place the second half over the fuel plates and match the fastener holes.
- b. Insert the 8 spade head screws through the holes and secure with corresponding wing nut (washer optional).
- c. Tighten the 8 wing nut fasteners finger tight.
- d. Visually check the 4 hex head screws located in the center of the basket to verify that they have not loosened. In the event the screws appear to be loose, tighten the fasteners to drawing requirements.
- 7. Insert the loose fuel plate basket into the package.
- 8. Depress the package closure spring-loaded pins, insert closure onto package body by aligning the closure locking tabs with the mating cut-outs in the body, and rotate the closure to the locked position. Release the spring-loaded pins so that they engage with the mating holes in the package body. Observe the pins to ensure they are in the locked position as illustrated in Figure 7.1-1. The closure is fully locked when both locking pins are compressing the sleeve between the locking pin handle and the closure body.
7.1.4 Loading of Contents - MIT HEU, LEU, & DDE; MURR HEU, LEU,
& DDE; RINSC, or Cobra Fuel Elements The loading of MIT, MURR, RINSC, and Cobra fuel elements is procedurally identical, except Cobra fuel has one additional step as shown below.
- 1. Remove the closure by depressing the spring-loaded pins and rotating the closure 45º to align the closure locking tabs with the mating cut-outs in the body. Remove the closure from the body.
- 2. Remove the fuel handling enclosure if present in the payload cavity.
- 3. Prior to loading, visually inspect the fuel handling enclosure for damage, corrosion, and missing hardware to ensure compliance with Appendix 1.3.2, Packaging General Arrangement Drawings.
- 4. Open (disassemble) the fuel handling enclosure and place a fuel element into one enclosure half. Ensure that the MIT, MURR, RINSC, or Cobra fuel element is only used with the corresponding MIT, MURR, RINSC, or Cobra fuel handling enclosure, as summarized in Table 7.1-1. As a property protection precaution, the fuel element may optionally be inserted into a polyethylene bag prior to placement in the fuel handling enclosure. Verify the total
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 7-5 mass of polyethylene and any tape used to seal the bag is limited to the amount shown in the third column of Table 7.1-1.
- a. To open the fuel handling enclosure, remove the two ball lock pins securing each end spacer. Slide each end spacer from the center enclosure halves allowing the enclosure halves to freely come apart.
- b. To close the fuel handling enclosure, with one enclosure half loaded, carefully place the second enclosure half over the fuel element and align the circular ends. Slide one end spacer over the circular end and insert the ball lock pin through the end spacer and enclosure halve alignment holes. Ensure the ball lock pin is in the locked position by observing the pin and locking mechanism protruding from the back side.
Repeat with the second end spacer and ensure it is locked in the same manner.
- 5. When loading Cobra fuel, verify that the alignment post in the Cobra FHE is inserted into one of the nominally 15-mm diameter holes in the end fittings of the Cobra fuel element.
- 6. Insert the fuel handling enclosure into the package.
- 7. Depress the package closure spring-loaded pins, insert closure onto package body by aligning the closure locking tabs with the mating cut-outs in the body, and rotate the closure to the locked position. Release the spring-loaded pins so that they engage with the mating holes in the package body. Observe the pins to ensure they are in the locked position as illustrated in Figure 7.1-1. The closure is fully locked when both locking pins are compressing the sleeve between the locking pin handle and the closure body.
7.1.5 Loading of Contents - Small Quantity Payloads (except RINSC)
The loading of small quantity payloads is procedurally identical.
- 1. Remove the closure by depressing the spring-loaded pins and rotating the closure 45º to align the closure locking tabs with the mating cut-outs in the body. Remove the closure from the body.
- 2. Remove the fuel handling enclosure if present in the payload cavity.
- 3. Prior to loading, visually inspect the fuel handling enclosure for damage, corrosion, and missing hardware to ensure compliance with Appendix 1.3.2, Packaging General Arrangement Drawings.
- 4. Open (disassemble) the small quantity fuel handling enclosure and place the payload into one enclosure half. The small quantity fuel handling enclosure is depicted on SAR drawing 60501-70, as summarized in Table 7.1-1.
- a. To open the fuel handling enclosure, remove the two ball lock pins securing each end spacer. Slide each end spacer from the center enclosure halves allowing the enclosure halves to freely come apart.
- b. To close the fuel handling enclosure, with one enclosure half loaded, carefully place the second enclosure half over the fuel element, loose fuel plates, or foils and align the circular ends. Slide one end spacer over the circular end and insert the ball lock pin through the end spacer and enclosure halve alignment holes. Ensure the ball lock pin is in the locked position by observing the pin and locking mechanism protruding
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 7-6 from the back side. Repeat with the second end spacer and ensure it is locked in the same manner.
- 5. Dunnage shall be used as necessary to reduce the free space between the small quantity payload face and the SQFHE cavity to a maximum of 1/4 inches or less. The dunnage shall be made from sheets or shapes of aluminum, including steel or aluminum fasteners if required, or may be made from cellulosic material such as cardboard. Neoprene rub strips, nominally 1/8 inch thick, may also be used as a property protection precaution. Neoprene rub strips may be used between the SQFHE and the small quantity payloads and/or between the dunnage and the small quantity payloads. The 1/8 inch neoprene rub strips shall not be stacked in more than two layers between the small quantity payload and any interior face of the SQFHE. Kraft paper and polyethylene sheeting may also be used as property protection.
The sum of the mass of all polyethylene and any other plastic materials such as adhesive tape shall not exceed 100g. The sum of the mass of all cellulosic materials (e.g., paper and cardboard) and neoprene shall not exceed 4 kg.
- 6. Verify that the total weight of the loaded SQFHE is 50 lb or less.
- 7. Insert the fuel handling enclosure into the package.
- 8. Depress the package closure spring-loaded pins, insert closure onto package body by aligning the closure locking tabs with the mating cut-outs in the body, and rotate the closure to the locked position. Release the spring-loaded pins so that they engage with the mating holes in the package body. Observe the pins to ensure they are in the locked position as illustrated in Figure 7.1-1. The closure is fully locked when both locking pins are compressing the sleeve between the locking pin handle and the closure body.
7.1.6 Loading of Contents - NBSR DDE
- 1. The NBSR DDE does not have a fuel handling enclosure. Prior to loading, protect the NBSR DDE using disposable packing such as cardboard blocking.
- 2. As a property protection measure, the NBSR DDE may optionally be enclosed in a polyethylene bag prior to the addition of packing materials. Verify the total mass of polyethylene, any tape used to seal the bag, and any polymeric material used to hold the packing material together is less than or equal to 200 g, as shown in Table 7.1-1.
- 3. Prepare end blocking so that the NBSR DDE is located approximately in the package cavity center. The maximum mass of all packing/blocking material is 4 kg (8.8 lb).
- 4. Verify that the total weight of the NBSR DDE and packing/blocking is 50 lb or less.
- 5. Remove the package closure by depressing the spring-loaded pins and rotating the closure 45º to align the closure locking tabs with the mating cut-outs in the body. Remove the closure from the body.
- 6. Insert the payload into the package.
- 7. Depress the package closure spring-loaded pins, insert closure onto package body by aligning the closure locking tabs with the mating cut-outs in the body, and rotate the closure to the locked position. Release the spring-loaded pins so that they engage with the mating holes in the package body. Observe the pins to ensure they are in the locked position as illustrated in
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 7-7 Figure 7.1-1. The closure is fully locked when both locking pins are compressing the sleeve between the locking pin handle and the closure body.
7.1.7 Preparation for Transport
- 1. Install the closure handle cover by aligning the cover against the handle and insert the fastener through the holes in the cover and behind the handle as illustrated in Figure 7.1-2.
Once installed, the cover renders the handle inoperable for lifting or tiedown during transport. Option: In lieu of installing the cover, the closure handle may be removed as a method of rendering the handle inoperable for lifting or tiedown during transport.
- 2. Install the tamper indicating device between the posts on the package closure and body.
- 3. Perform a survey of the dose rates and levels of non-fixed (removable) radioactive contamination per 49CFR §173.441 and 49CFR §173.443, respectively. The contamination measurements shall be taken in the most appropriate locations to yield a representative assessment of the non-fixed contamination levels.
- 4. Complete the necessary shipping papers in accordance with Subpart C of 49 CFR §172.
- 5. Ensure that the package markings are in accordance with 10 CFR §71.85(c) and Subpart D of 49 CFR §172. Package labeling shall be in accordance with Subpart E of 49CFR §172.
Package placarding, for either single package transport or the racked configuration, shall be in accordance with Subpart F of 49 CFR §172.
- 6. Transfer the package to the conveyance and secure the package(s).
Figure 7.1 Closure Handle Cover Installation
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 7-8 Table 7.1 Fuel Handling Enclosure Usage Summary Fuel Element Section No.
FHE SAR Drawing No.
Maximum mass of poly and tape, g ATR HEU 7.1.2 60501-30 100 ATR Loose Plates 7.1.3 60501-20 100 MIT HEU 7.1.4 60501-40 100 MIT LEU & DDE 7.1.4 60501-40 200 MURR HEU 7.1.4 60501-50 100 MURR LEU & DDE 7.1.4 60501-50 200 RINSC 7.1.4 60501-60 100 Cobra HEU & LEU 7.1.4 60501-90 100 Small Quantity 7.1.5 60501-70 100 ATR LEU 7.1.2 60501-30 200 NBSR DDE 7.1.6 NA 200 7.2 Package Unloading 7.2.1 Receipt of Package from Conveyance Radiation and contamination surveys shall be performed upon receipt of the package and the package shall be inspected for damage as required by and in accordance with the users personnel protection or ALARA program. In addition, the tamper indicating device (TID) shall be inspected. A missing TID or indication of damage to a TID is a Safeguards and Security concern. Disposition of such an incident is beyond the scope of this SAR.
7.2.2 Removal of Contents
- 1. Remove tamper indicating device.
- 2. Remove the package closure by depressing the spring-loaded pins and rotating the closure 45º to align the closure locking tabs with the mating cut-outs in the body. Remove the closure from the body.
- 3. Remove the payload container.
- 4. Open the payload container (fuel handling enclosure or loose fuel plate basket) and remove the contents.
- a. Open the ATR fuel handling enclosure by releasing the spring plunger located at each end and rotate the lid about the hinged side.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 7-9
- b. Open the loose fuel plate basket by removing the 8 wing nut fasteners securing each half of the basket.
- c. Open the MIT, MURR, RINSC, Cobra, or small quantity payload fuel handling enclosure by removing the two ball lock pins and sliding the end spacers from each end of the enclosure halves.
- 5. Close the fuel handling enclosure lid or loose fuel plate basket as appropriate. If required, return the empty payload container to the package.
- a. To close the ATR fuel handling enclosure, rotate the lid to the closed position, pull the spring plunger located at each end to allow the lid to fully close, align then release the spring plungers with the receiving holes, gently lift the lid to confirm no movement and that the spring plungers are in the locked position.
- b. To close the loose fuel plate basket, place each half of the basket together and align the fastener holes. Insert the 8 spade head screws through the holes and secure with corresponding wing nut (washer optional). Tighten each wing nut finger tight.
- c. To close the MIT, MURR, RINSC, Cobra, or small quantity payload fuel handling enclosure, place each enclosure half together and align the circular ends. Slide one end spacer over the circular end and insert the ball lock pin through the end spacer and enclosure halve alignment holes. Ensure the ball lock pin is in the locked position by observing the pin and locking mechanism protruding from the back side.
Repeat with the second end spacer and ensure it is locked in the same manner.
- 6. Depress the package closure spring-loaded pins, insert closure onto package body by aligning the closure locking tabs with the mating cut-outs in the body, and rotate the closure to the locked position. Release the spring-loaded pins so that they engage with the mating holes in the package body. Observe the pins to ensure they are in the locked position as illustrated in Figure 7.1-1. The closure is fully locked when both locking pins are compressing the sleeve between the locking pin handle and the closure body.
7.3 Preparation of Empty Package for Transport Empty packages are prepared and transported per the guidelines of 49 CFR §173.428. The packaging is inspected to ensure that it is in an unimpaired condition and is securely closed.
Any labels previously applied in conformance with subpart E of 49CFR §172 are removed, obliterated, or covered and the Empty label prescribed in 49 CFR §172.450 is affixed to the packaging.
7.4 Other Operations This section does not apply.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 7-10 This page left intentionally blank.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 8-1 8.0 ACCEPTANCE TESTS AND MAINTENANCE PROGRAM 8.1 Acceptance Tests Per the requirements of 10 CFR §71.85, the inspections and tests to be performed prior to first use of the package are described in this section.
8.1.1 Visual Inspections and Measurements All packaging dimensions, tolerances, general notes, materials of construction, and assembly shall be examined in accordance with the requirements delineated on the drawings in Appendix 1.3.2, Packaging General Arrangement Drawings. Source inspections and final release of the packaging will be performed, verifying the quality characteristics were inspected and that the packaging is acceptable. Any characteristic that is out of specification shall be reported and dispositioned in accordance with the quality assurance program in effect.
8.1.1.1 Compression Spring The compression spring is a component of the closure locking system that maintains the locking pin in the closed position. The compression spring shall be procured to Stock Precision Engineered Components (SPEC) catalog number C0360-035-1120 specification, or equivalent, which includes the following:
Material shall be approximately 0.035 inch diameter stainless steel wire.
The nominal outside diameter of the spring shall be approximately 0.36 inches.
The free length of the spring shall be approximately 1.12 inches.
The solid height of the spring shall be approximately 0.33 inches.
The spring shall have a 4.77 (-.1, +.5) lb load at a load length of approximately 0.55 inches.
The spring rate shall be 8.33 (-.1, +.5) lbs/in.
8.1.1.2 Roll Pin The roll pin is a component of the closure locking system that maintains the locking pin in the closed position. The roll pin shall be procured to Stock Drive Products/Sterling Instrument (SDP/SI) catalog number A9Y35-0324 specification, or equivalent, which includes the following:
Material shall be stainless steel.
The free diameter of the roll pin shall be between 0.099 to 0.103 inches.
The length of the roll pin shall be approximately 0.75 inches
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 8-2 8.1.1.3 Insulating Blanket The ceramic fiber insulating blanket is a component of the body and closure assemblies used to reduce heat transfer during thermal events. The insulating blanket shall be procured to Unifrax Durablanket S 6 lb/ft3 specification, or equivalent, which includes the following:
The material shall be comprised of inorganic ceramic fibers.
The nominal thickness shall be 0.5 (-0, +.2) inches.
The nominal density shall be 6 (-15%, +30%) lb/ft3.
The specific heat shall be 0.25 Btu/lbm-°F minimum.
The thermal conductivity shall be 0.145 Btu/hr-ft-°F or less at 1200°F.
8.1.2 Weld Examinations All welds shall be examined in accordance with the requirements delineated on the drawings in Appendix 1.3.2, Packaging General Arrangement Drawings. Visual examinations are performed in accordance with AWS D1.61, Section 6 for stainless steel, AWS D1.22, for aluminum, and penetrant examinations are performed under procedures written to ASTM E165-02, Standard Test Method for Liquid Penetrant Examination.
8.1.3 Structural and Pressure Tests The packaging does not retain pressure and no pressure testing is required prior to use.
8.1.4 Leakage Tests The packaging contains no seals or containment boundaries that require leakage rate testing.
8.1.5 Component and Material Tests No component or material tests are required for this packaging.
8.1.6 Shielding Tests The packaging does not contain any biological shielding. Shielding tests are not required.
8.1.7 Thermal Tests The material thermal properties utilized in Chapter 3.0, Thermal are nominal. However, the thermal analyses in which these values are used are consistently conservative for the Normal Conditions of Transport (NCT) and Hypothetical Accident Condition (HAC). Therefore, specific acceptance tests for material thermal properties are not required or performed.
1 ANSI/AWS D1.6:1999, Structural Welding Code - Stainless Steel, American Welding Society (AWS).
2 ANSI/AWS D1.2:2003, Structural Welding Code - Aluminum, American Welding Society.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 8-3 8.1.8 Miscellaneous Tests No other acceptance tests are necessary for the packaging.
8.2 Maintenance Program This section describes the maintenance program used to ensure continued performance of the packaging. The packaging is maintained consistent with a 10 CFR 71 subpart H QA program.
Packagings that do not conform to the license drawings are removed from service until they are brought back into compliance. Repairs are performed in accordance with approved procedures and consistent with the quality assurance program in effect.
8.2.1 Structural and Pressure Tests There are no structural or pressure tests that are necessary to ensure continued performance of the packaging.
8.2.2 Leakage Rate Tests No leakage rate tests are necessary to ensure continued performance of the packaging.
8.2.3 Component and Material Tests There is no predetermined replacement schedule for any packaging components and there are no items that would be expected to wear or become damaged during normal usage. The items identified in this section are routinely used during operations and shall be visually inspected prior to each use. Damaged components shall be repaired or replaced prior to further use.
8.2.3.1 Packaging Body and Closure The closure assembly locking pin spring shall be visually inspected and replaced if it becomes damaged or otherwise fails to function properly (Drawing 60501-10, Item 20, of Appendix 1.3.2, Packaging General Arrangement Drawings).
The index lug screws and corresponding tap, or optional wire insert, shall be visually inspected for deformed or stripped threads prior to installation of the screws (Drawing 60501-10, Items 3 and 16).
8.2.3.2 ATR Fuel Handling Enclosure The spring plunger shall be visually inspected and replaced if it becomes damaged or otherwise fails to function properly (Drawing 60501-30, Item 6, of Appendix 1.3.2, Packaging General Arrangement Drawings).
8.2.3.3 Loose Fuel Plate Basket All threaded components shall be visually inspected as they are installed for deformed or stripped threads (Drawing 60501-20, Items 2, 3, 4, and 5 of Appendix 1.3.2, Packaging General Arrangement Drawings).
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 8-4 8.2.3.4 Fuel Handling Enclosure The ball lock pin used with the MIT, MURR, RINSC, Small Quantity, and Cobra FHE shall be visually inspected and replaced if it becomes damaged or otherwise fails to function properly, according to the drawings of Appendix 1.3.2, Packaging General Arrangement Drawings:
MIT FHE, Drawing 60501-40, Item 4 MURR FHE, Drawing 60501-50, Item 4 RINSC FHE, Drawing 60501-60, Item 5 Small Quantity FHE, Drawing 60501-70, Item 4 Cobra FHE, Drawing 60501-90, Item 4 8.2.4 Thermal Tests No thermal tests are necessary to ensure continued performance of the packaging.
8.2.5 Miscellaneous Tests No miscellaneous tests are required to ensure continued performance of the packaging.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-1 9.0 QUALITY ASSURANCE The Advanced Test Reactor Fresh Fuel Shipping Container (ATR FFSC) is anticipated to be used by both U.S. Department of Energy (DOE) and U.S. Nuclear Regulatory Commission (NRC) licensed users. 10 CFR §71.101, Quality assurance requirements, requires each licensees quality assurance program to be approved by the Commission before any use of the package for shipments.
NRC licensed users shall follow their NRC approved quality assurance program and be identified by the Commission as an authorized user. For DOE and its subcontractors, this chapter defines the approved Quality Assurance (QA) requirements and methods of compliance applicable to the ATR FFSC package.
The ATR FFSC package described in this SAR is used to transport unirradiated single fuel elements. The QA requirements for packagings are described in Subpart H of 10 CFR Part 71 (10 CFR 71). Subpart H is an 18-criteria QA program based on ANSI/ASME NQA-1. Guidance for QA programs for packaging is provided by NRC Regulatory Guide 7.101. The DOE QA requirements for the use of 10CFR71 certified packagings are described in DOE Order 460.1B2.
The ATR FFSC packaging is designed and built for Idaho National Laboratory (INL).
Procurement, design, fabrication, assembly, testing, maintenance, repair, modification, and use of the ATR FFSC package are all done under QA programs that meet all applicable NRC and DOE QA requirements.
The DOE Idaho Operations Office approved QA program is implemented for all Nuclear Safety activities. Compliance with NRC and DOT packaging and transportation requirements is mandated by DOE Order 460.1B.
This document establishes the programmatic requirements for site-wide implementation and serves as the basis for INL quality assurance program acceptability. It is designed such that implementation of the full scope of requirements as stated in DOE Orders 414.1C, Quality Assurance and 460.1B Packaging and Transport Safety, constitutes compliance to nuclear safety quality assurance criteria required by 10 CFR 830, Subpart A, Nuclear Safety Management Quality Assurance Requirements.
A detailed discussion of the QA program which governs ATR FFSC packaging operations is presented on the following pages to demonstrate compliance with 10 CFR 71, Subpart H.
9.1 Organization 9.1.1 ATR FFSC Project Organization This section identifies the organizations involved and describes the responsibilities of and interactions between these organizations.
1 U.S. Nuclear Regulatory Commission, Regulatory Guide 7.10, Establishing Quality Assurance Programs for Packaging Used in transport of Radioactive Material, Revision 2, March 2005.
2 U.S. Department of Energy Order 460.1B, Packaging and Transportation Safety, 4-4-03.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-2 9.1.1.1 Idaho National Laboratory (INL)
INL Contractor Management has overall responsibility for successfully accomplishing activities.
Management provides the necessary planning, organization, direction, control, resources, and support to achieve their defined objectives. Management is responsible for planning, performing, assessing, and improving the work.
INL Contractor Management is responsible for establishing and implementing policies, plans, and procedures that control the quality of work, consistent with requirements.
INL Contractor Management responsibilities include:
Ensuring adequate technical and QA training is provided for personnel performing activities.
Ensuring compliance with all applicable regulations, DOE orders and requirements, and applicable federal, state, and local laws.
Ensuring personnel adhere to procedures for the generation, identification, control, and protection of QA records.
Exercising authority and responsibility to STOP unsatisfactory work such that cost and schedule do not override environmental, safety, or health considerations.
Developing, implementing, and maintaining plans, policies, and procedures that implement the Quality Assurance Program Description (QAPD).
Identifying, investigating, reporting, and correcting quality problems.
Achieving and maintaining quality in their respective areas. (Quality achievement is the responsibility of those performing the work. Quality achievement is verified by persons or organizations not directly responsible for performing the work.)
Empowering employees by delegating authority and decision making to the lowest appropriate level in the organization.
9.1.1.2 Members of the INL Contractor Workforce (at all levels)
Implement the organizations procedures to meet QA requirements.
Comply with administrative and technical work control requirements.
Identify and report issues to the responsible manager for resolution and continuous improvement for the work being performed.
Seek, identify, and recommend work methods or procedural changes that would improve quality and efficiency.
9.1.1.3 INL Contractor Quality Assurance Management The INL Contractor QA Management provides independent oversight of all quality related activities.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-3 9.2 Quality Assurance Program 9.2.1 General The INL Contractors QA Program defines and establishes requirements for programs, projects, and activities.
The INL Contractor QA program is developed and maintained through an ongoing process that selectively applies QA criteria as appropriate to the function or work activity being performed.
Applicable QA criteria consist of the following:
Title 10 CFR Subpart 71, Packaging and Transportation of Radioactive Material Title 10 CFR 830.120, Quality Assurance Requirements ASME NQA-1-2000, Quality Assurance Requirements for Nuclear Facility Application DOE O 414.1C, Quality Assurance DOE O 461.1B, Packaging and Transport Safety DOE G 414.1-1A, Management Assessment and Independent Assessment The INL Contractor QA Program is inclusive of applicable requirements from criteria noted above and addresses the following for this SAR:
Organization Records Quality Assurance Program Work Process Implementation of the QA Program Procurement Personnel Qualification and Training Inspection and Testing Quality Improvement Management Assessments Documents Independent Assessment The INL Contractor QA Director is responsible for ensuring implementation of requirements as defined within the QA program and requirements of this SAR, including design, procurement, fabrication, inspection, testing, maintenance, and modifications. Procurement documents are to reflect applicable requirements from 10 CFR 71, Subpart H, ASME NQA-1 and the QA program.
INL Contractor Quality Management assesses the adequacy and effectiveness of the QA program to ensure effective implementation inclusive of objective evidence and independent verification, where appropriate, to demonstrate that specific project and regulatory objectives are achieved.
All INL Contractor personnel and contractors are responsible for effective implementation of the QA program within the scope of their responsibilities. INL Contract packaging and quality engineers are responsible for inspection and testing and are to be qualified, as appropriate, through minimum education and/or experience, formal training, written examination and/or other demonstration of skill and proficiency. Objective evidence of qualifications and capabilities are to be maintained as required. As appropriate, the initial employee training should consist of the following:
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-4 General employee indoctrination Program indoctrination QA program training Applicable NRC and DOT requirements.
Note: Only packaging engineers and Quality Engineers with training and/or experience in applicable NRC and DOT requirements and Safety Analysis Reports (SARs) can plan or determine the application of internal INL processes to ensure compliance with Chapter 9 and this SAR.
9.2.2 ATR FFSC-Specific Program The ATR FFSC was designed and tested as described in Chapter 2, Structural Evaluation, of this SAR. QA requirements are invoked in the design, procurement, fabrication, assembly, testing, maintenance, and use of the packaging to ensure established standards are maintained. Items and activities to be controlled and documented are described in this chapter.
9.2.3 QA Levels Materials and components of the ATR FFSC are designed, procured, fabricated, assembled, and tested using a graded approach under a 10 CFR 71, Subpart H equivalent QA Program and Regulatory Guide (RG) 7.10. Under that program, the categories critical to safety are established for all ATR FFSC packaging components. These defined quality categories consider the impact to safety if the component were to fail or perform outside design parameters.
9.2.3.1 Graded Quality Category A Items:
These items and services are critical to safe operation and include structures, components, and systems whose failure could directly result in a condition adversely affecting public health and safety. The failure of a single item could cause loss of primary containment leading to a release of radioactive material beyond regulatory requirements, loss of shielding beyond regulatory requirements, or unsafe geometry compromising criticality control.
9.2.3.2 Graded Quality Category B Items:
These items and services have a major impact on safety and include structures, components, and systems whose failure or malfunction could indirectly result in a condition adversely affecting public health and safety. The failure of a Category B item, in conjunction with the failure of an additional item, could result in an unsafe condition.
9.2.3.3 Graded Quality Category C Items:
These items and services have a minor impact on safety and include structures, components, and systems whose failure or malfunction would not significantly reduce the packaging effectiveness and would not be likely to create a situation adversely affecting public health and safety.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-5 9.2.3.4 Application of Quality Categories The design effort and requirements for a QA program are interrelated and are developed simultaneously. To ensure the development of a QA program in which the application of QA requirements is commensurate with their safety significance, engineering personnel perform a systematic analysis of each component, structure, and system to assess the consequences to the health and safety of the public and the environment that would result from malfunction or failure of such items. This engineering assessment is initiated during the design process and performed in accordance with approved procedures. Establishment of the engineering basis during the design process enables a uniform, consistent application of QA requirements during fabrication, use, and maintenance of packaging.
A logical sequence is established to identifying realistic QA requirements would involve (1) classifying each structure, system, and component (2) grouping items classified as important to safety into quality categories; and (3) specifying the applicable level of QA effort for each category.
The Design Authority (DA) identifies the critical characteristics when they identify design attributes necessary to preserve the safety support function. As necessary, the DA also ensures critical characteristics are included in this SAR by the identification of SSCs and their QA Category designations. Additionally, this SAR includes the safety function, design, and operational attributes necessary for reliable performance. The DA applies design criteria to the design, operation, and maintenance of each critical SSC including recommended codes and standards, as required by RG 7.10. QA requirements shall be applied as necessary to assure the SSCs can perform their function.
The package-specific safety documents identify systems, structures, and components (SSCs) that are important to the safety functions for transportation. As appropriate, the hazard analysis and accident scenarios in the safety basis documents help identify SSCs that must function in order to prevent or mitigate these events. These SSCs are then identified using the classification system found in the NRC QA Category system provided in NRC Regulatory Guide (RG) 7.10. The categories as defined in RG 7.10, and listed below, are analogous to Safety Class, Safety Significant, and General Service that are identified for facility SSCs.
Upon custodianship of the ATR FFSC packages by INL, functional classifications will be used for site operations and activities related to the ATR FFSC. The method of classification is documented as follows.
Quality Category A:
Critical impact on safety and associated functional requirements - items or components whose single failure or malfunction could directly result in an unacceptable condition of containment, shielding, or nuclear criticality control. This is functionally equivalent to safety class designation used for nuclear facility safety.
Quality Category B:
Impact on safety and associated functional requirement - components whose failure or malfunction in conjunction with one other independent failure or malfunction could result in an unacceptable condition of containment, shielding, or nuclear criticality control. This is functionally equivalent to safety significant designation used for nuclear facility safety.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-6 Quality Category C:
Minor impact on safety and associated functional requirements - components whose failure or malfunction would not result in an unacceptable condition of containment, shielding, or nuclear criticality control regardless of other single failures. This is functionally equivalent to designations given to components that do not meet safety class or safety significant criteria used for nuclear facility safety.
The tabulation of this classification process is provided in Tables 9.2-1 and 9.2-2.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-7 Table 9.2 QA Categories for Design and Procurement of ATR FFSC Subcomponents Component Subcomponent Category Body Assembly Outer Square Tube A
Inner Round Tube A
Bottom End Plate A
Closure End Plate A
Stiffening Ribs A
Thermal Shield Sheet B
Insulation B
Tamper Indicating Device Dowel Pin C
Index Lug Screw B
Weld Wire A
Closure Assembly Outer Plate, Closure A
Inner Plate (Insulation Pocket)
B Closure Locking Hardware (Pin, Handle, Spring, etc.)
B Insulation B
Tamper Indicating Device Dowel Pin C
Weld Wire A
Loose Fuel Plate Basket (Drawing No. 60501-20) and Fuel Handling Enclosures Drawing Nos. 60501-40 and 60501-50 Machined Aluminum Body A
All Other Components*
C Fuel Handling Enclosures Drawing Nos. 60501-30, 60501-60, 60501-70 and 60501-90 All Components*
C
- Note: neoprene in all fuel handling enclosures is categorized as not important to safety (NITS).
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-8 Table 9.2 Level of Quality Assurance Effort per QA Element 10CFR71 Subpart H QA Element Level of QA Effort QA Category A
B C
1 (71.103)
QA Organization (¶9.1)
Organizational structure and authorities defined Responsibilities defined Reporting levels established Management endorsement X
X X
X X
X X
X 2
(71.105)
QA Program (¶9.2)
Implementing procedures in place Trained personnel Activities controlled X
X X
X X
X 3
(71.107)
Design (¶9.3)
Control of design process and inputs Control of design input Software validated and verified Design verification controlled Quality category assessment performed X
X X
X X
X X
X X
X X
X 4
(71.109)
Procurement Document Control (¶9.4)
Complete traceability Qualified suppliers list Commercial grade dedicated items acceptable Off-the-shelf item X
X X
X X
X X
5 (71.111)
Instructions, Procedures, and Drawings (¶9.5)
Must be written and controlled Qualitative or quantitative acceptance criteria X
X X
X 6
(71.113)
Document Control (¶9.6)
Controlled issuance Controlled changes Procurement documents X
X X
X X
X X
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-9 10CFR71 Subpart H QA Element Level of QA Effort QA Category A
B C
7 (71.115)
Control of Purchased Material, Equipment, and Services (¶9.7)
Source evaluation and selection plans Evidence of QA at supplier Inspections at supplier, as applicable Receiving inspection Objective proof that all specifications are met Audits/surveillances at supplier facility, as applicable Incoming inspection for damage only X
X X
X X
X X
X X
X X
X X
8 (71.117)
Identification and Control of Material, Parts, and Components (¶9.8)
Positive identification and traceability of each item Identification and traceable to heats, lots, or other groupings Identification to end use drawings, etc.
X X
X X
X 9
(71.119)
Control of Special Processes (¶9.9)
All welding, heat treating, and nondestructive testing done by qualified personnel Qualification records and training of personnel No special processes X
X X
X X
10 (71.131)
Inspection (¶9.10)
Documented inspection to all specifications required Examination, measurement, or test of material or processed product to assure quality Process monitoring if quality requires it Inspectors must be independent of those performing operations Qualified inspectors only Receiving inspection X
X X
X X
X X
X X
X X
X X
X X
11 (71.123)
Test Control (¶9.11)
Written test program Written test procedures for requirements in the package approval Documentation of all testing and evaluation Representative of buyer observes all supplier acceptance tests if specified in procurement documents No physical tests required X
X X
X X
X X
X
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-10 10CFR71 Subpart H QA Element Level of QA Effort QA Category A
B C
12 (71.125)
Control of Measuring and Test Equipment (¶9.12)
Tools, gauges, and instruments to be in a formal calibration program Only qualified inspectors No test required X
X X
X X
13 (71.127)
Handling, Storage, and Shipping (¶9.13)
Written plans and procedures required Routine handling X
X X
14 (71.129)
Inspection, Test, and Operating Status (¶9.14)
Individual items identified as to status or condition Stamps, tags, labels, etc., must clearly show status Visual examination only X
X X
X X
X 15 (71.131)
Nonconforming Materials, Parts, or Components (¶9.15)
Written program to prevent inadvertent use Nonconformance to be documented and closed Disposal without records X
X X
X X
X X
16 (71.133)
Corrective Action (¶9.16)
Objective evidence of closure for conditions adverse to quality X
X X
17 (71.135)
QA Records (¶9.17)
Design and use records Results of reviews, inspections, test, audits, surveillance, and materials analysis Personnel qualifications Records of fabrication, acceptance, and maintenance retained throughout the life of package Record of package use kept for three years after shipment All records managed by written plans for retention and disposal Procurement records X
X X
X X
X X
X X
X X
X X
X X
X 18 (71.137)
Audits (¶9.18)
Written plan of periodic audits Lead auditor certified X
X X
X
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-11 9.3 Package Design Control As required by the INL Contractors Quality Program, design processes shall be established and implemented to satisfy the requirements of the QAPD. These requirements are to be in accordance with:
10 CFR 830.122(f), Criterion 6 - Performance/Design3 DOE Order 414C, CRD, Attachment 1, 2.b.(2), Criterion 6 - Design.
Requirements are implemented to ensure processes and procedures are in place to ensure design features of packaging systems are appropriately translated into specifications, drawings, procedures, and instructions. Design control measures are established for criticality, shielding, thermal, and structural analyses under both normal and accident condition analyses as defined in NRC regulations.
The INL Contractor is responsible for maintaining the package and this SAR. The design documents (e.g., drawings and specifications) are controlled by incorporation into this SAR, which will be reviewed and approved by the NRC.
The design of the ATR FFSC was performed under an NRC-approved QA Program as required by INL. Design inputs consist of an INL statement of work, applicable DOE orders, national standards, specifications, and drawings.
Procedures control design activities to ensure the following occur:
Design activities are planned, controlled, and documented.
Regulatory requirements, design requirements, and appropriate quality standards are correctly translated into specifications, drawings, and procedures.
Competent engineering personnel, independent of design activities, perform design verification. Verification may include design reviews, alternate calculations, or qualification testing. Qualification tests are conducted in accordance with approved test programs or procedures.
Design interface controls are established and adequate.
Design, specification, and procedure changes are reviewed and approved in the same manner as the original issue. In a case where a proposed design change potentially affects licensed conditions, the Quality Assurance Program shall provide for ensuring that licensing considerations have been reviewed and are complied with or otherwise reconciled by amending the license.
Design errors and deficiencies are documented, corrected and corrective action to prevent recurrence is taken.
Design organization(s) and their responsibilities and authorities are delineated and controlled through written procedures.
3 DOE, Code of Federal Regulations, 10 CFR 830.122, Quality Assurance Criteria, U.S. Department of Energy, Washington, D.C., 2006.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-12 Materials, parts, equipment, and processes essential to the function of items that are important to safety are selected and reviewed for suitability of application.
Computer programs used for design analysis or verification are controlled in accordance with approved procedures. These procedures provide for verification of the accuracy of computer results and for the assessment and resolution of reported computer program errors.
9.4 Procurement Document Control As required by the INL Contractor Quality Program, procurement/acquisition processes and related document control activities are established and implemented to satisfy requirements of the QAPD. Requirements are to be in accordance with:
10 CFR 830.122(d), Criterion 4 - Management/Documents and Records 10 CFR 830.122(g), Criterion 7 - Performance/Procurement DOE Order 414C, CRD, Attachment 1, 2.a.(4), Criterion 4 - Documents and Records DOE Order 414C, CRD, Attachment 1, 2.b.(3), Criterion 7 - Procurement DOE Guide 414.1-3, Suspect/Counterfeit Items.
Processes and procedures are in place to ensure appropriate levels of quality are achieved in procurement of material, equipment, and services. Quality Level and Quality Category designations assigned by the Design Authority grade the application of QA requirements for procurements based on radiological material at risk, mission importance, safety of workers, public, environment, and equipment, and other differentiating criteria. Implementing procedures provide the logic process for determining Quality Levels used in procurement of equipment and subcontracting of services. Procedures ensure processes address document preparation and document control, and records management to meet regulatory requirements. Procurement records are kept in a manner that satisfies regulatory requirements.
INL Contractor procurement actions for packaging and spare parts shall be controlled. Contracts and Purchase Orders for packaging and spare parts shall require the selected vendor to implement and maintain an NRC approved 10CFR71, Subpart H QA Program.
Implementing procedures ensure procurement documents are prepared to clearly define applicable technical and quality assurance requirements including codes, standards, regulatory requirements and commitments, and contractual requirements. These documents serve as the principal documents for procurement of structures, systems and components, and related services for use in design, fabrication, maintenance and operation, inspection and testing of storage and/or transportation systems. Procedures ensure purchased material, components, equipment, and services adhere to applicable requirements. Furthermore:
The assignment of quality requirements through procurement documents is administered and controlled.
Procurement activities are performed in accordance with approved procedures delineating requirements for preparation, review, approval, and control of procurement documents.
Revisions to procurement documents are reviewed and approved by the same cognizant groups as the original document.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-13 Quality requirements are included in quality-related purchase orders as applicable to the scope of the procurement referencing 10 CFR 71, Subpart H or other codes and standards, as appropriate.
INL Contractor procurement documents will require suppliers to convey appropriate quality assurance program requirements to sub-tier suppliers.
INL Contractor procurement documents will include provisions that suppliers either maintain or supply those QA records which provide evidence of conformance to the procurement documents. Additionally, procurement documents shall designate the supplier documents required for submittal to INL for review and/or approval.
INL shall maintain the right of access to supplier facilities and performance of source surveillance and/or audit activities, as applicable. A statement to this effect is to be included in procurement documents.
INL shall require the Supplier to warrant that all items furnished under the Contract are genuine (i.e., new, not refurbished, not counterfeit) and match the quality, test reports, markings and/or fitness for intended use as required by the Contract. Any materials furnished as part of the Contract which has been previously found to be suspect/counterfeit by the government or other duly recognized agency, shall not be used.
Procurement documents shall also address the applicability of the provisions of 10 CFR 21 for the Reporting of Defects and Noncompliances.
9.5 Instructions, Procedures, and Drawings As required by the INL Contractor Quality Program, instructions, procedures, and drawing work processes and applicable quality improvement activities shall be established and implemented to satisfy the requirements of the QAPD. These requirements are to be in accordance with:
10 CFR 830.122(c), Criterion 3 - Management/Quality Improvement 10 CFR 830.122(e), Criterion 5 - Performance/Work Processes DOE Order 414C, CRD, Attachment 1, 2.a.(3), Criterion 3 - Quality Improvement DOE Order 414C, CRD, Attachment 1, 2.b.(1), Criterion 5 - Work Processes.
Requirements are implemented to ensure processes and procedures are in place that achieve quality objectives and ensure appropriate levels of quality and safety are applied to critical components of packaging and transportation systems utilizing a graded approach. The program shall ensure processes and procedures in place to identify and correct problems associated with transportation and packaging activities.
Implementing procedures shall be established to ensure that methods for complying with each of the applicable criteria of 10 CFR 71, Subpart H, as applicable, for activities affecting quality during design, fabrication, inspection, testing, use and maintenance are specified in instructions, procedures, and/or drawings. In addition:
Instructions, procedures, and drawings shall be developed, reviewed, approved, utilized, and controlled in accordance with the requirements of approved procedures. These
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-14 instructions, procedures, and drawings shall include appropriate quantitative and qualitative acceptance criteria.
Changes to instructions, procedures and drawings, are developed, reviewed, approved, utilized and controlled using the same requirements and controls as applied to the original documents.
Compliance with these approved instructions, procedures and drawings is mandatory for INL personnel while performing activities affecting quality.
Specific activities by INL regarding preparation of packaging for use, repair, rework, maintenance, loading contents, unloading contents, and transport, must be accomplished in accordance with written and approved instructions, procedures, specifications, and/or drawings.
These documents must identify appropriate inspection and hold points and emphasize those characteristics that are important to safety and quality. Transportation package procedures are to be developed and reviewed by technical and quality staff and shall be approved by appropriate levels of management.
9.5.1 Preparation and Use Activities concerning loading and shipping are performed in accordance with written operating procedures developed by the user and approved by the package custodian. Packaging first-time usage tests, sequential loading and unloading operations, technical constraints, acceptance limits, and references are specified in the procedures. A pre-planned and documented inspection will be conducted to ensure that each loaded package is ready for delivery to the carrier.
9.5.2 Operating Procedure Changes Changes in operating procedures that affect the process must be approved at the same supervisory level as the initial issue.
9.5.3 Drawings Controlled drawings are shown in Appendix 1.3.2, Packaging General Arrangement Drawings, of this SAR. Implementation of design revisions is discussed in SAR Section 9.3, Package Design Control.
9.6 Document Control As required by the INL Contractor Quality Program, document control activities shall be established and implemented to satisfy the requirements of the QAPD. These requirements are to be in accordance with:
10 CFR 830.122(d), Criterion 4 - Management/Documents and Records DOE Order 414C, CRD, Attachment 1, 2.a.(4), Criterion 4 - Documents and Records.
Requirements are implemented to ensure processes and procedures are in place to address document, document control, and for the management of records. Records (engineering, test
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-15 reports, user instructions, etc.) must be maintained in a manner that conforms to regulatory requirements.
Document control activities related to the design, procurement, fabrication, and testing of ATR FFSC components; and SAR preparation shall be controlled.
Implementing procedures shall be established to control the issuance of documents that prescribe activities affecting quality and to assure adequate review, approval, release, distribution, use of documents and their revisions. Controlled documents may include, but are not limited to:
Design specifications Design and fabrication drawings Special process specifications and procedures QA Program Manuals/Plans, etc.
Implementing procedures Test procedures Operational test procedures and data.
Requirements shall ensure changes to documents, which prescribe activities affecting quality, are reviewed and approved by the same organization that performed the initial review and approval, or by qualified responsible organizations. Documents that prescribe activities affecting quality are to be reviewed and approved for technical adequacy and inclusion of appropriate quality requirements prior to approval and issuance. Measures are taken to ensure that only current documents are available at the locations where activities affecting quality are performed prior to commencing the work.
Package users are responsible for establishment, development, review, approval, distribution, revision, and retention of their documents. Documents requiring control, the level of control, and the personnel responsibilities and training requirements are to be identified.
Packaging documents to be controlled include as a minimum:
Operating procedures Maintenance procedures Inspection and test procedures Loading and unloading procedures Preparation for transport procedures Repair procedures Specifications Fabrication records Drawings of packaging and components SAR and occurring supplements.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-16 Revisions are handled in a like manner as the original issue. Only the latest revisions must be available for use.
Documentation received from the supplier for each package must be filed by package serial number. These documents are to be retained in the users facility.
9.7 Control Of Purchased Material, Equipment And Services As required by the INL Contractor Quality Program, the control of purchased material, equipment and services and applicable quality improvement activities shall be established and implemented to satisfy the requirements of the QAPD. These requirements are to be in accordance with:
10 CFR 830.122(c), Criterion 3 - Management/Quality Improvement 10 CFR 830.122(g), Criterion 7 - Performance/Procurement 10 CFR 830.122(h), Criterion 8 - Performance/Inspection and Acceptance Testing DOE Order 414C, CRD, Attachment 1, 2.b.(3), Criterion 3 - Quality Improvement DOE Order 414C, CRD, Attachment 1, 2.b.(3), Criterion 7 - Procurement DOE Order 414C, CRD, Attachment 1, 2.b.(4), Criterion 8 - Inspection and Acceptance Testing.
Requirements are implemented to ensure processes and procedures are in place to ensure appropriate inspections and tests are applied prior to acceptance or use of the packaging or component, and to identify the status of packaging items, components, etc. Requirements shall ensure processes and procedures are in place such that appropriate levels of quality are achieved in the procurement of material, equipment, and services. Quality Level and Quality Category designations by the Design Authority are used to grade the application of QA requirements of procurements based on radiological material at risk, mission importance, safety of workers, public, environment, and equipment, and other differentiating criteria. Requirements shall ensure processes and procedures in place to identify and correct problems associated with transportation and packaging activities.
Activities related to the control of purchased material, equipment and services shall be controlled. Control of purchased material, equipment, and services consist of the following elements:
Implementing procedures shall be established to assure that purchased material, equipment and services conform to procurement documents.
Procurement documents shall be reviewed and approved by authorized personnel for acceptability of proposed suppliers based on the quality requirements of the item/activity being purchased.
As required, audits and/or surveys are conducted to determine supplier acceptability.
These audits/surveys are based on one or all of the following criteria: the suppliers capability to comply with the requirements of 10 CFR 71, Subpart H that are applicable to the scope of work to be performed; a review of previous records to establish the past performance of the supplier; and/or a survey of the suppliers facilities and review of the
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-17 suppliers QA Program to assess adequacy and verify implementation of quality controls consistent with the requirements being invoked.
Qualified personnel shall conduct audits and surveys. Audit/survey results are to be documented and retained as Quality Assurance Records. Suppliers are re-audited and/or re-evaluated at planned intervals to verify that they continue to comply with quality requirements and to assess the continued effectiveness of their QA Program.
Additionally, interim periodic evaluations are to be performed of supplier quality activities to verify implementation of their QA Program.
Suppliers are required to provide objective evidence that items or services provided meet the requirements specified in procurement documents. Items are properly identified to appropriate records that are available to permit verification of conformance with procurement documents. Any procurement requirements not met by suppliers shall be reported to INL Contractor Quality Management for assessment of the condition. These conditions are reviewed by technical and quality personnel to assure that they have not compromised the quality or service of the item.
Periodic surveillance of supplier in-process activities is performed as necessary, to verify supplier compliance with the procurement documents. When deemed necessary, the need for surveillance is noted in approved quality or project planning documents.
Surveillances are to be performed and documented in accordance with approved procedures. Personnel performing surveillance of supplier activities are to be trained and qualified in accordance with approved procedures.
Quality planning for the performance of source surveillance, test, shipping and/or receiving inspection activities to verify compliance with approved design and licensing requirements, applicable 10 CFR 71 criteria, procurement document requirements, or contract specifications is to be performed in accordance with approved procedures.
For commercial off-the-shelf items, where specific quality controls appropriate for nuclear applications cannot be imposed in a practical manner, additional quality verification shall be performed to the extent necessary to verify the acceptability and conformance of an item to procurement document requirements. When dedication of a commercial grade item is required for use in a quality-related application, such dedication shall be performed in accordance with approved procedures.
To ensure compliance with procurement requirements, control measures shall include verification of supplier capability and verification of item or service quality. Procurements of ATR FFSC components are required to be placed with pre-qualified and selected vendors. The vendors QA Plan must address the requirements of 10 CFR 71, Subpart H and defined requirements. A graded approach is used based on the QA Levels established in Table 9.2-2.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-18 The approach used to control the procurement of items and services must include the following:
Source evaluation and selection Evaluation of objective evidence of quality furnished by the supplier Source inspection Audit Examination of items or services upon delivery or completion.
9.8 Identification And Control Of Material, Parts And Components As required by the INL Contractor Quality Program, activities concerning the identification and control of material, parts, and components shall be established and implemented to satisfy the requirements of QAPD. These requirements are to be in accordance with:
10 CFR 830.122(e), Criterion 5 - Performance/Work Processes 10 CFR 830.122(g), Criterion 7 - Performance/Procurement 10 CFR 830.122(h), Criterion 8 - Performance/Inspection and Acceptance Testing DOE Order 414C, CRD, Attachment 1, 2.b.(1), Criterion 5 - Work Processes DOE Order 414C, CRD, Attachment 1, 2.b.(3), Criterion 7 - Procurement DOE Order 414C, CRD, Attachment 1, 2.b.(4), Criterion 8 - Inspection and Acceptance Testing.
Requirements are implemented to ensure processes and procedures are in place that achieve quality objectives and ensure appropriate levels of quality and safety are applied to critical components of packaging and transportation systems utilizing a graded approach. The program also ensures processes and procedures are in place such that appropriate inspections and tests are applied prior to acceptance or use of the packaging or component, and to identify the status of packaging items, and components. The program shall ensure processes and procedures are in place to ensure appropriate levels of quality are achieved in the procurement of material, equipment, and services.
Activities related to the identification and control of material, parts and components shall be controlled. The requirements for identification and control of material, parts, and components consist of the following elements:
Implementing procedures are established to identify and control materials, parts, and components. These procedures assure identification of items by appropriate means during fabrication, installation, and use of the items and prevent the inadvertent use of incorrect or defective items.
Requirements for identification are established during the preparation of procedures and specifications.
Methods and location of identification are selected to not adversely affect the quality of the item(s) being identified.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-19 Items having limited shelf or operating life are controlled to prevent their inappropriate use.
Control and identification must be maintained either directly on the item or within documents traceable to the item to ensure that only correct and acceptable items are used. When physical identification is not practical, other appropriate means of control must be established such as bagging, physical separation, or procedural control. Each packaging unit shall be assigned a unique serial number after fabrication or purchase. All documentation associated with subsequent storage, use, maintenance, inspection, acceptance, etc., must refer to the assigned serial number. Verification of acceptance status is required prior to use. Items that are not acceptable must be controlled accordingly. Control of nonconforming items is addressed in Section 9.15, Nonconforming Parts, Materials, or Components.
Each ATR FFSC package will be conspicuously and durably marked with information identifying the package owner, model number, unique serial number, and package gross weight, in accordance with 10 CFR 71.85(c).
Replacement parts must be identified to ensure correct application. Minute items must be individually packaged with the package marked with the part identification and traceability information.
9.9 Control Of Special Processes As required by the INL Contractor Quality Program, activities for the control of special processes shall be established and implemented to satisfy the requirements of the QAPD. These requirements are to be in accordance with:
10 CRF 830.122(b), Criterion 2 - Management/Personnel Training and Qualifications 10 CFR 830.122(e), Criterion 5 - Performance/Work Processes 10 CFR 830.122(g), Criterion 7 - Performance/Procurement DOE Order 414C, CRD, Attachment 1, 2.a.(2), Criterion 2 - Personnel Training and Qualifications DOE Order 414C, CRD, Attachment 1, 2.b.(1), Criterion 5 - Work Processes DOE Order 414C, CRD, Attachment 1, 2.b.(3), Criterion 7 - Procurement.
Requirements will be implemented to ensure only trained and qualified personnel perform transportation and packaging activities. The program shall ensure processes and procedures are in place that achieve quality objectives and ensure appropriate levels of quality and safety are applied to critical components of packaging and transportation systems utilizing a graded approach.
Activities related to the control of special processes shall be controlled. The requirements for control of special processes consist of the following elements:
Implementing procedures shall be established to control special processes used in the fabrication and inspection of storage/transport systems. These processes may include welding, non-destructive examination, or other special processes as identified in procurement documents.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-20 Special processes are performed in accordance with approved procedures.
Personnel who perform special processes shall be trained and qualified in accordance with applicable codes, standards, specifications, and/or other special requirements.
Records of qualified procedures and personnel are to be maintained and kept current by the organization that performs the special processes.
Package users are responsible to ensure special processes for welding and nondestructive examination of the ATR FFSC during fabrication, use, and maintenance are controlled.
Equipment used in conduct of special processes must be qualified in accordance with applicable codes, standards, and specifications. Special process operations must be performed by qualified personnel and accomplished in accordance with written process sheets or procedures with recorded evidence of verification when applicable. Qualification records of special process procedures, equipment, and personnel must be maintained.
Welders, weld procedures, and examination personnel are to be qualified in accordance with the appropriate articles of ASME BPVC,Section IX, Welding and Brazing Qualifications;4 and ASME BPVC,Section V, Nondestructive Examination.5 Special processes for QA Level A and B items must be performed by qualified personnel in accordance with documented and approved procedures. Applicable special processes performed by an outside supplier such as welding, plating, anodizing, and heat treating, which are controlled by the suppliers quality program, are reviewed and/or witnessed in accordance with procurement requirements.
9.10 Internal Inspection As required by the INL Contractor Quality Program, internal inspection activities shall be established to satisfy the requirements of the QAPD. These requirements are to be in accordance with:
10 CRF 830.122(b), Criterion 2 - Management/Personnel Training and Qualifications 10 CFR 830.122(h), Criterion 8 - Performance/Inspection and Acceptance Testing DOE Order 414C, CRD, Attachment 1, 2.a.(2), Criterion 2 - Personnel Training and Qualifications DOE Order 414C, CRD, Attachment 1, 2.b.(4), Criterion 8 - Inspection and Acceptance Testing.
Requirements are implemented to ensure only trained and qualified personnel perform transportation and packaging activities. The program shall ensure processes and procedures are in place to ensure appropriate inspections and tests are applied prior to acceptance or use of the packaging or component, and to identify the status of packaging items, components, etc.
4 ASME, 2004, American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section IX, Welding and Brazing Qualifications, American Society of Mechanical Engineers, New York, NY 5 ASME, 2004, American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section V, Nondestructive Examination, American Society of Mechanical Engineers, New York, NY
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-21 Activities related to internal inspection shall be controlled. The program requirements for control of internal inspection consist of the following elements:
Implementing procedures shall be established to assure that inspection or surveillance is performed to verify that materials, parts, processes, or other activities affecting quality conform to documented instructions, procedures, specifications, drawings, and/or procurement documents.
Personnel performing inspection and surveillance activities shall be trained and qualified in accordance with written approved procedures.
Inspections and surveillances are to be performed by individuals other than those who performed or supervised the subject activities.
Inspection or surveillance and process monitoring are both required where either one, by itself, will not provide assurance of quality.
Modifications and/or repairs to and replacements of safety-related and important-to-safety structures, systems, and components are inspected in accordance with the original design and inspection requirements or acceptable alternatives.
Mandatory hold points, inspection equipment requirements, acceptance criteria, personnel qualification requirements, performance characteristics, variable and/or attribute recording instructions, reference documents, and other requirements are considered and included, as applicable, during inspection and surveillance planning.
9.10.1 Inspections During Fabrication Specific inspection criteria are incorporated into the drawings for the ATR FFSC packaging.
Inspection requirements for fabrication are divided into two responsible areas that document that an accepted ATR FFSC package conforms to tested and certified design criteria. These two areas are:
In-process inspections performed by the fabricator.
Independent surveillance of fabrication activities performed by individuals acting on behalf of the purchaser.
The vendor (fabricator) is required to submit Manufacturing/Fabrication Plans prior to the start of fabrication for approval by the customer. These plans shall be used as a tool for establishing witness and hold points. A review for compliance with procurement documents is normally performed as part of the surveillance function at the vendors facility. The plans shall define how fabrications and inspections are to be performed, processes to be engaged. Inspections must be documented and records delivered in individual data packages accompanying the package in accordance with the procurement specification.
Independent surveillance activities will be performed by qualified personnel selected with approval of the customer.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-22 9.10.2 Inspections During Initial Acceptance and During Service Life Independent inspections are performed upon receipt of the ATR FFSC packaging prior to first usage (implemented by package user procedures) and on an annual basis. Post-loading inspections are also performed prior to shipment. Inspection to be implemented by the package user (by qualified independent inspection personnel) must include the following:
Acceptance - Ensure compliance with procurement documents. Per Chapter 8, Acceptance Tests and Maintenance Program of this SAR, perform (as applicable) first-time-usage inspections, and weld examinations.
Operation - Verify proper assembly and verify that post-load leak testing (if applicable) is carried out as discussed in Chapter 7, Package Operations, of this SAR.
Maintenance - Ensure adequate packaging maintenance to ensure that performance is not impaired as discussed in Chapter 8, Acceptance Tests and Maintenance Program of this SAR.
Final - Verify proper contents, assembly, marking, shipping papers, and implementation of any special instructions.
9.11 Test Control As required by the INL Contractor Quality Program, test control activities shall be established and implemented to satisfy the requirements of the QAPD. These requirements are to be in accordance with:
10 CFR 830.122(e), Criterion 5 - Performance/Work Processes DOE Order 414C, CRD, Attachment 1, 2.b.(1), Criterion 5 - Work Processes.
Requirements are implemented to ensure processes and procedures are in place that achieve quality objectives and ensure appropriate levels of quality and safety are applied to critical components of packaging and transportation systems utilizing a graded approach.
Activities related to test control shall be controlled. The requirements for test control consist of the following elements:
Implementing procedures shall be established to assure that required proof, acceptance, and operational tests, as identified in design or procurement documents, are performed and appropriately controlled.
Test personnel shall have appropriate training and shall be qualified for the level of testing which they are performing. Personnel shall be qualified in accordance with approved, written instructions, procedures, and/or checklists.
Tests are performed by qualified personnel in accordance with approved, written instructions, procedures, and/or checklists. Test procedures are to contain or reference the following information, as applicable:
- Acceptance criteria contained in the applicable test specifications, or design and procurement documents.
- Instructions for performance of tests, including environmental conditions.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-23
- Test prerequisites such as test equipment, instrumentation requirements, personnel qualification requirements, fabrication, or operational status of the items to be tested.
- Provisions for data recording and records retention.
Test results are to be documented and evaluated to ensure that acceptance criteria have been satisfied.
Tests to be conducted after modifications, repairs, or replacements of safety-related and important-to-safety structures, systems, or components are to be performed in accordance with the original design and testing requirements or acceptable alternatives.
Tests are required when it is necessary to demonstrate that an item or process will perform satisfactorily. Test procedures must specify the objectives of the tests, testing methods, required documentation, and acceptance criteria. Tests to be conducted by vendors at vendor facilities must be specified in procurement documents. Personnel conducting tests, test equipment, and procedures must be qualified and records attesting to qualification retained.
9.11.1 Acceptance and Periodic Tests The fabricator must supply QA documentation for the fabrication of each ATR FFSC packaging in accordance with applicable drawings, specifications, and/or other written requirements.
The package user must ensure required ATR FFSC packaging inspections and tests are performed prior to first usage.
Periodic testing, as applicable, will be performed to ensure the ATR FFSC packaging performance has not deteriorated with time and usage. The requirements for the periodic tests are given in the Chapter 8, Acceptance Tests and Maintenance Program of this SAR. The results of these tests are required to be documented and maintained with the specific packaging records by the package user.
9.11.2 Packaging Nonconformance Packaging that does not meet the inspection criteria shall be marked or tagged as nonconforming, isolated, and documented in accordance with Section 9.15, Nonconforming Parts, Materials, or Components. The packaging must not be used for shipment until the nonconformance report has been properly dispositioned in accordance with Section 9.15.
9.12 Control Of Measuring And Test Equipment As required by the INL Contractor Quality Program, activities pertaining to the control of measuring and test equipment shall be established and implemented to satisfy the requirements of the QAPD. These requirements are to be in accordance with:
10 CFR 830.122(h), Criterion 8 - Performance/Inspection and Acceptance Testing DOE Order 414C, CRD, Attachment 1, 2.b.(4), Criterion 8 - Inspection and Acceptance Testing.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-24 Requirements are implemented to ensure processes and procedures are in place to ensure appropriate inspections and tests are applied prior to acceptance or use of the packaging or component, and to identify the status of packaging items, components, etc.
Activities pertaining to the control of measuring and test equipment shall be controlled. The requirements for control of measuring and test equipment shall consist of the following elements:
Implementing procedures shall be established to assure that tools, gages, instruments and other measuring and testing devices (M&TE) used in activities affecting quality are properly controlled, calibrated and adjusted to maintain accuracy within required limits.
M&TE are calibrated at scheduled intervals against certified standards having known valid relationships to national standards. If no national standards exist, the basis for calibration shall be documented. Calibration intervals are based on required accuracy, precision, purpose, amount of use, stability characteristics and other conditions that could affect the measurements.
Calibrations are to be performed in accordance with approved written procedures.
Inspection, measuring and test equipment are to be marked to indicate calibration status.
M&TE are to be identified, labeled or tagged indicating the next required calibration due date, and traceable to calibration records.
If M&TE is found to be out of calibration, an evaluation shall be performed and documented regarding the validity of inspections or tests performed and the acceptability of items inspected or tested since the previous acceptable calibration. The current status of M&TE is to be recorded and maintained. Any M&TE that is consistently found to be out of calibration shall be repaired or replaced.
Special calibration and control measures on rules, tape measures, levels and other such devices are not required where normal commercial practices provide adequate accuracy.
9.13 Handling, Storage, And Shipping Control As required by the INL Contractor Quality Program, handling, storage, and shipping control activities shall be established and implemented to satisfy the requirements of the QAPD. These requirements are to be in accordance with:
10 CFR 830.122(e), Criterion 5 - Performance/Work Processes DOE Order 414C, CRD, Attachment 1, 2.b.(1), Criterion 5 - Work Processes.
Requirements are implemented to ensure processes and procedures are in place that achieve quality objectives and ensure appropriate levels of quality and safety are applied to critical components of packaging and transportation systems utilizing a graded approach.
Activities pertaining to handling, storage, and shipping shall be controlled. The requirements for handling, storage, and shipping control consist of the following elements:
Implementing procedures shall be established to assure that materials, parts, assemblies, spare parts, special tools, and equipment are handled, stored, packaged, and shipped in a manner to prevent damage, loss, loss of identity, or deterioration.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-25 When necessary, storage procedures address special requirements for environmental protection such as inert gas atmospheres, moisture control, temperature levels, etc.
Package users shall ensure that components associated with the ATR FFSC are controlled to prevent damage or loss, protected against damage or deterioration, and provide adequate safety of personnel involved in handling, storage, and shipment (outgoing and incoming) operations.
Handling, storage, and shipping must be accomplished in accordance with written and approved instructions, procedures, specifications, and/or drawings. These documents must identify appropriate information regarding shelf life, environment, temperature, cleaning, handling, and preservation, as applicable, to meet design, regulatory, and/or DOE shipping requirements.
Preparation for loading, handling, and shipment will be done accordance with approved procedures to ensure that all requirements have been met prior to delivery to a carrier. A package ready for shipment must conform to its shipping paper.
Empty packages, following usage, must be checked and decontaminated if required. Each package must be inspected, reconditioned, or repaired, as appropriate, in accordance with approved written procedures before storing or loading. Empty ATR FFSC packagings are to be tagged with EMPTY labels and stored in designated protected areas in order to minimize environmental effects on the containers.
Routine maintenance on the ATR FFSC packaging may be performed as deemed necessary by package users and is limited to cleaning, rust removal, painting, light metal working to restore the original contours and replacement of damaged, worn, or malfunctioning components. Spare components will be placed in segregated storage to maintain proper identification and to avoid misuse.
9.14 Inspection, Test, And Operating Status As required by the INL Contractor Quality Program, inspection, test, and operating status activities shall be established and implemented to satisfy the requirements of the QAPD. These requirements are to be in accordance with:
10 CFR 830.122(e), Criterion 5 - Performance/Work Processes 10 CFR 830.122(h), Criterion 8 - Performance/Inspection and Acceptance Testing DOE Order 414C, CRD, Attachment 1, 2.b.(1), Criterion 5 - Work Processes DOE Order 414C, CRD, Attachment 1, 2.b.(4), Criterion 8 - Inspection and Acceptance Testing.
Requirements are implemented to ensure processes and procedures are in place that achieve quality objectives and ensure appropriate levels of quality and safety are applied to critical components of packaging and transportation systems utilizing a graded approach. In addition, processes and procedures shall be in place to ensure appropriate inspections and tests are applied prior to acceptance or use of the packaging or component, and to identify the status of packaging items, components, etc.
Activities pertaining to inspection, test, and operating status activities shall be controlled. The requirements for inspection, test, and operating status consist of the following elements:
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-26 Implementing procedures shall be established to assure that the inspection and test status of materials, items, structures, systems, and components throughout fabrication, installation, operation, and test are clearly indicated by suitable means, (e.g., tags, labels, cards, form sheets, check lists, etc.).
Bypassing of required inspections, tests, or other critical operations is prevented through the use of approved instructions or procedures As appropriate, the operating status of nonconforming, inoperative or malfunctioning components of a storage/transport system is indicated to prevent inadvertent operation.
The application and removal of status indicators is performed in accordance with approved instructions and procedures.
Any nonconforming items are identified and controlled in accordance with Section 9.15, Nonconforming Parts, Materials, or Components, of this SAR.
Package users shall ensure that the status of inspection and test activities are identified on the item or in documents traceable to the item to ensure that proper inspections or tests have been performed and that those items that do not pass inspection are not used. The status of fabrication, inspection, test, assembly, and refurbishment activities must be identified in documents traceable to the package components.
Measures established in specifications, procedures, and other instructions shall ensure that the following objectives are met:
QA personnel responsible for oversight of packaging inspections can readily ascertain the status of inspections, tests, and/or operating conditions.
No controlled items are overlooked.
Inadvertent use or installation of unqualified items is prevented.
Documentation is complete.
9.15 Nonconforming Materials, Parts, or Components As required by the INL Contractor Quality Program, control of nonconforming materials, parts, or components shall be established and implemented to satisfy the requirements of the QAPD.
These requirements are to be in accordance with:
10 CFR 830.122(c), Criterion 3 - Management/Quality Improvement DOE Order 414C, CRD, Attachment 1, 2.b.(3), Criterion 3 - Quality Improvement.
Requirements are implemented to ensure that processes and procedures are in place to identify and correct problems associated with transportation and packaging activities.
Activities pertaining to the control of nonconforming materials, parts, or components shall be controlled. The requirements for nonconforming materials, parts, or components consist of the following elements:
Implementing procedures shall be established to control materials, parts, and components that do not conform to requirements to prevent their inadvertent use during fabrication or during service.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-27 Nonconforming items include those items that do not meet specification or drawing requirements. Additionally, nonconforming items include items not fabricated or tested (1) in accordance with approved written procedures, (2) by qualified processes, or (3) by qualified personnel; where use of such procedures, processes, or personnel is required by the fabrication, test, inspection, or quality assurance requirements.
Nonconforming items are identified and/or segregated to prevent their inadvertent use until properly dispositioned. The identification of nonconforming items is by marking, tagging, or other methods that do not adversely affect the end use of the item. The identification shall be legible and easily recognizable. When identification of each nonconforming item is not practical, the container, package, or segregated storage area, as appropriate, is identified.
Nonconforming conditions are documented in NCRs and affected organizations are to be notified. The nonconformance report shall include a description of the nonconforming condition. Nonconforming items are dispositioned as use-as-is, reject, repair, or rework.
Inspection or surveillance requirements for nonconforming items following rework, repair are detailed in the nonconformance reports and approved following completion of the disposition.
Acceptability of rework or repair of nonconforming materials, parts, and components is verified by re-inspecting and/or re-testing the item to the original requirements or equivalent inspection/testing methods. Inspection, testing, rework, and repair methods are to be documented and controlled.
The disposition of nonconforming items as use-as-is or repair shall include technical justification and independent verification to assure compliance with design, regulatory, and contractual requirements.
Items dispositioned as rework or repair are reinspected and retested in accordance with the original inspection and test requirements or acceptable alternatives that comply with the specified acceptance criteria.
When specified by contract requirements, nonconformances that result in a violation of client contract or specification requirements shall be submitted for client approval.
Nonconformance reports are made part of the inspection records and are periodically reviewed to identify quality trends. Unsatisfactory quality trends are documented on a Corrective Action Report (CAR) as detailed in Section 9.16, Corrective Action, of this SAR. The results of these reviews are to be reported to management.
Nonconformance reports relating to internal activities are issued to management of the affected organization. The appropriate Quality Assurance Manager shall approve the disposition and performs follow-up activities to assure proper closure.
Compliance with the evaluation and reporting requirements of 10 CFR 21 related to defects and noncompliances are to be controlled by approved procedures.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-28 9.16 Corrective Action As required by the INL Contractor Quality Program, requirements for corrective action shall be established and implemented to satisfy the requirements of the QAPD. These requirements are to be in accordance with:
10 CFR 830.122(c), Criterion 3 - Management/Quality Improvement DOE Order 414C, CRD, Attachment 1, 2.b.(3), Criterion 3 - Quality Improvement.
Requirements are implemented to ensure that processes and procedures are in place to identify and correct problems associated with transportation and packaging activities.
Activities pertaining to corrective actions shall be controlled. The requirements for corrective action consist of the following elements:
Implementing procedures shall be established to identify significant conditions adverse to quality. Significant and/or repetitive failures, malfunctions and deficiencies in material, components, equipment, and operations are to be promptly identified and documented on a Corrective Action Reports (CARs) and reported to appropriate management. The cause of the condition and corrective action necessary to prevent recurrence are identified, implemented, and followed up to verify corrective action is complete and effective.
The INL Contractor Quality Assurance Director (DQA) is responsible for ensuring implementation of the corrective action program, including follow up and closeout actions. The DQA may delegate certain activities in the Corrective Action process to others.
9.17 Quality Assurance Records As required by the INL Contractor Quality Program, activities associated with QA records shall be established and implemented to satisfy the requirements of the QAPD. These requirements are to be in accordance with:
10 CRF 830.122(b), Criterion 2 - Management/Personnel Training and Qualifications 10 CFR 830.122(d), Criterion 4 - Management/Documents and Records 10 CFR 830.122(e), Criterion 5 - Performance/Work Processes 10 CFR 830.122(h), Criterion 8 - Performance/Inspection and Acceptance Testing DOE Order 414C, CRD, Attachment 1, 2.a.(2), Criterion 2 - Personnel Training and Qualifications DOE Order 414C, CRD, Attachment 1, 2.a.(4), Criterion 4 - Documents and Records DOE Order 414C, CRD, Attachment 1, 2.b.(1), Criterion 5 - Work Processes DOE Order 414C, CRD, Attachment 1, 2.b.(4), Criterion 8 - Inspection and Acceptance Testing.
Requirements are implemented to ensure that only trained and qualified personnel perform transportation and packaging activities. The program shall ensure processes and procedures are
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-29 in place to address document preparation, document control, and management of records. In addition, the program ensures processes and procedures are in place which achieves quality objectives and appropriate levels of quality and safety are applied to critical components of packaging and transportation systems utilizing a graded approach. Finally, the program ensures processes and procedures are in place to identify appropriate inspections and tests are applied prior to acceptance or use of the package or component, and to identify the status of packaging items, components, etc.
Quality assurance records shall be controlled. The requirements for quality assurance records consist of the following elements:
Implementing procedures shall be established to assure control of quality records. The purpose of the Quality Assurance Records system is to assure that documented evidence relative to quality related activities is maintained and available for use by INL Contractor, its customers, and/or regulatory agencies, as applicable.
Approved procedures identify the types of documents to be retained as QA records, as well as those to be retained by the originating organization. Lifetime and Non-Permanent records are retained by Records Management (RMA) or its customers, as appropriate.
Records are identified, indexed, and stored in accessible locations.
QA Records are maintained for periods specified to furnish evidence of activities affecting the quality of structures, systems, and components that are safety-related or important-to-safety. These records include records of design, procurement, fabrication, assembly, inspection, and testing.
Maintenance records shall include the use of operating logs; results of reviews, inspections, tests, and audits; results from monitoring of work performance and material analyses; results of maintenance, modification, and repair activities; qualification of personnel, procedures, and equipment; records of calibration of measuring and test equipment; and related instructions, procedures, and drawings.
Requirements for indexing, record retention period, storage method(s) and location(s),
classification, preservation measures, disposition of nonpermanent records, and responsibility for safekeeping are specified in approved procedures. Record storage facilities are established to prevent destruction of records by fire, flood, theft, and deterioration due to environmental conditions (such as temperature, humidity, or vermin).
As an alternative, two identical sets of records (dual storage) may be maintained at separate locations.
INL shall retain required records for at least three (3) years beyond the date of last engagement of activities.
9.17.1 General Sufficient records must be maintained by package users to furnish evidence of quality of items and of activities affecting quality. QA records that must be retained for the lifetime of the packaging include:
Appropriate production-related records that are generated throughout the package manufacturing and fabrication process
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-30 Records demonstrating evidence of operational capability; e.g., completed acceptance tests and inspections Records verifying repair, rework, and replacement Audit reports, and corrective actions Records that are used as a baseline for maintenance Records showing evidence of delivery of packages to a carrier and proof that all DOT requirements were satisfied.
9.17.2 Generating Records Package user documents designated as QA records must be:
Legible Completed to reflect the work accomplished and relevant results or conclusions Signed and dated or otherwise authenticated by authorized personnel.
QA records should be placed in a records storage area as soon as is feasible to avoid loss or damage. Individual package QA records must be generated and maintained for each package by the package serial number.
9.17.3 Receipt, Retrieval, and Disposition of Records The RMA has overall responsibility for records management for the ATR FFSC. Package users are responsible for maintaining records while they are in process and for providing completed records to the RMA. A receipt control system shall be established, and records maintained in-house or at other locations are to be identifiable and retrievable and not disposed of until prescribed conditions are satisfied.
Records are to be available for inspection upon request.
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-31 Table 9.17 Quality Assurance Records Quality Assurance Record Retention period Design and Fabrication Drawings LOP+
Test Reports LOP+
Independent Design Review Comments LOP+
Safety Analysis Report for Packaging LOP+
Vendor Manufacturing and Inspection Plans LOP+
Material Test Report of Certification of Materials LOP+
Welding Specifications and Procedures LOP+
Weld Procedure Qualification Record LOP+
Welder or Welding Operator Qualification Tests LOP+
Record of Qualification of Personnel Performing Radiographic and PT Reports LOP+
Weld Radiographs LOP+
Liquid Penetrant Reports LOP+
Dimensional Inspection Report for All Features LOP+
Visual and Dimensional Inspection upon Receipt of Packaging LOP+
Package Loading Procedure S+
Unloading Procedure S+
Maintenance Procedures LOP+
Repair Procedures LOP+
Procurement Specifications LOP+
Personnel Training and Qualification Documentation LOP+
Maintenance Log LOP+
Corrective Action Reports LOP+
Nonconformance Reports (and resolutions)
LOP+
Incident Reports per 10 CFR 71.95 LOP+
Preliminary Determinations per 10 CFR 71.85 S+
Routine Determinations per 10 CFR 71.87 S+
Shipment Records per 10 CFR 71.91(a), (b), (c), (d)
S+
LOP+ Lifetime of packaging plus 3 years S+ Shipping date plus 3 years
Docket No. 71-9330 ATR FFSC Safety Analysis Report Rev. 17, May 2022 9-32 9.18 Audits As required by the INL Contractor Quality Program, audit requirements shall be established and implemented to satisfy the requirements of the QAPD. These requirements are to be in accordance with:
10 CFR 830.122(i), Criterion 9 - Assessment/Management Assessment 10 CFR 830.122(j), Criterion 10 - Assessment/Independent Assessment DOE Order 414C, CRD, Attachment 1, 2.c.(1), Criterion 9 - Management Assessment DOE Order 414C, CRD, Attachment 1, 2.c.(2), Criterion 10 - Independent Assessment.
Requirements are implemented to ensure management assessments are performed on a regular basis. Management assessments are planned and conducted in accordance with written procedures. In addition, the program will be independently assessed periodically in accordance with procedures.
Activities pertaining to audits and assessments shall be controlled. The requirements for audits and assessments consist of the following elements:
Implementing procedures shall be established to assure that periodic audits verify compliance with all aspects of the Quality Assurance Program and determine its effectiveness. Areas and activities to be audited, such as design, procurement, fabrication, inspection, and testing of storage/transportation systems, are to be identified as part of audit planning.
INL audits supplier Quality Assurance Programs, procedures, and implementation activities to evaluate and verify that procedures and activities are adequate and comply with applicable requirements.
Audits are planned and scheduled in a manner to provide coverage and coordination with ongoing Quality Assurance Program activities commensurate with the status and importance of the activities.
Audits are performed by trained and qualified personnel not having direct responsibilities in the areas being audited and are conducted in accordance with written plans and checklists. Audit results are documented and reviewed by management having responsibility for the area audited. Corrective actions and schedules for implementation are established and recorded. Audit reports include an objective evaluation of the quality-related practices, procedures, and instructions for the areas or activities being audited and the effectiveness of implementation.
Responsible management shall undertake corrective actions as a follow-up to audit reports when appropriate. The Quality Assurance Management (QAM) shall evaluate audit results for indications of adverse trends that could affect quality. When results of such assessments so indicate, appropriate corrective action will be implemented.
The QAM shall follow up on audit findings to assure that appropriate corrective actions have been implemented and directs the performance of re-audits when deemed necessary.