ML22195A185

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71-5797_Enclosure_3_Summary_of_SAR_R14_Changes
ML22195A185
Person / Time
Site: 07105797
Issue date: 07/12/2022
From:
US Dept of Energy, Office of Packaging and Transportation
To:
Storage and Transportation Licensing Branch
PSAVEROT NMSS/DFM/STLB 3014157505
Shared Package
ML22195A181 List:
References
Download: ML22195A185 (3)


Text

ENCLOSURE 3

SUMMARY

OF CHANGES TO SAFETY ANALYSIS REPORT FOR PACKAGING:

THE ORNL HFIR UNIRRADIATED FUEL ELEMENT SHIPPING CONTAINER, ORNL/TM-11656 71-5797 Page 1 of 3

Revision 14 SAR Changes Summary of Volume I Changes SAR Location Change Reason for Change Cover page and List of Effective Pages (LOEP)

The LOEP is being updated as appropriate to reflect the changes described below.

Editorial change reflecting latest revision.

Revision Log Updated for Rev. 14.

Editorial change explaining scope of Rev. 14.

Section 1.2.1.1, first paragraph This section was updated to provide a brief discussion on the use of fuel element combs.

It is desired to eventually install combs at the fuel element manufacturer, thus requiring the elements with combs to be shipped in fresh fuel shipping containers.

Chapter 1 Figures The drawings provided as Figures 1.3, 1.4, and 1.5 were updated to remove the tie down band.

The tie down bands are not credited or analyzed in the fresh fuel SAR and are not integral to the package and therefore will not be included in the certification drawings.

Chapter 1 Figures The drawings provided as Figures 1.7 and 1.8 were updated to Rev. 5.

Revision 5 of the subject drawings depict and provides details on fuel element combs.

71-5797 Page 2 of 3

Summary of Volume II Changes SAR Location Change Reason for Change Cover page, List of Effective Pages (LOEP),

and Summary of Revision Changes Updated for Rev. 14.

The Summary of Revision Changes page was revised to remove the specific revision level.

Editorial changes reflecting latest revision.

The Summary of Revision Changes only refers the reader to Vol. 1 for information on the changes made in the latest revision. It is therefore unnecessary to update this page every time Vol. 2 of the SAR is revised.

Section 7.1, #11 New ORNL drawing M-20978-EL-008B, Shipping Container Tie Down Band For Unirradiated Out/In HFIR Element Details, was added in the text where the TDB (referred to as a removable shoring ring) is discussed.

Added for reference since the TDB details were removed from the SAR figures in Chapter 1.

Section 8.2, second paragraph Clarified that the containers are inspected for legibility of labels and markings.

Clarification to align with changes to Section 8.2.7.

Section 8.2.7 Revised this section to remove the 3-year periodic inspection/repainting of the containers.

The containers are inspected prior to each shipment per an RRD internal procedure for excessive wear, water damage, surface contamination, correct installation of hardware, etc. The 3-year periodic inspection was added in 1989 following discovery that an unauthorized modification had been made to one or more of the containers. A periodic detailed as-built inspection of the containers per the drawings is no longer warranted because: 1) it is not required by the regulations, 2) over the past thirty years no additional unauthorized modifications have been identified, and 3) adequate controls are in place through the ORNL and RRD work control processes to prevent future unauthorized modifications.

Section 9.3.11.2, first paragraph Deleted the first two sentences of this section to remove the periodic inspection/repainting of the containers.

The containers are inspected prior to each shipment per an RRD internal procedure for excessive wear, water damage, surface contamination, correct installation of hardware, etc. A periodic detailed as-built inspection of the containers per the drawings is not warranted for the reasons stated above.

71-5797 Page 3 of 3