ML23137A441

From kanterella
Jump to navigation Jump to search

Authorization for Shipment of the Model No. Halfpact Package - Inner Containment Vessel No. 506
ML23137A441
Person / Time
Site: 07109279
Issue date: 06/02/2023
From: Yoira Diaz-Sanabria, Garcia-Santos N
Storage and Transportation Licensing Branch
To: Sellmer T
Salado Isolation Mining Contractors (SIMCO) LLC
References
EPID L-2023-LLA-0030, CAC 001029
Download: ML23137A441 (23)
v • d • e


Text

P. Nos UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 2, 2023 Todd E. Sellmer, Manager Packaging and Information Systems Salado Isolation Mining Contractors P.O. Box 2078 Carlsbad, NM 88221

SUBJECT:

AUTHORIZATION FOR SHIPMENT OF THE MODEL NO. HALFPACT PACKAGE CREDITING THE OUTER CONFINEMENT VESSEL AS THE CONTAINMENT BOUNDARY

Dear Mr. Todd E. Sellmer:

As requested by your letter dated February 15, 2023 (Agencywide Documents Access and Management System [ADAMS] Accession Number ML23046A454), as supplemented on April 27, 2023 (ML18275A113), pursuant to Title 10 of the Code of Federal Regulations Part 71, the Certificate of Compliance (CoC) No. 9279 for the Model No. HalfPACT package is amended by letter to allow a one-time shipment of the HalfPACT package from the Waste Isolation Pilot Plant to the Savannah River Site crediting the outer confinement vessel as the packages containment boundary. This configuration is not currently approved in CoC No. 9279. All other conditions of CoC No. 9279, Revision 11 (ML22312A405), shall remain the same. This authorization is valid for one shipment of a HalfPACT package limited by the following additional conditions:

1) The package will be shipped by truck.
2) There will be a maximum of one loaded HalfPACT package per shipment on a single truck.
3) The shipment will be made under exclusive use.
4) The shipment will only include the inner containment vessel of HalfPACT package No.

506 as authorized content.

T. E. Sellmer 2 If you have any questions regarding this authorization, please contact me or Norma García Santos at Norma.GarciaSantos@nrc.gov.

FOR THE U.S. NUCLEAR REGULATORY COMMISSION Signed by Diaz-Sanabria, Yoira on 06/02/23 Yoira Diaz Sanabria, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-9279 EPID L-2023-LLA-0030

Enclosure:

Safety Evaluation Report

This page was left intentionally blank.

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION REPORT Letter Authorization Docket No. 71-9279 Model No. HalfPACT Certificate of Compliance No. 9279 Enclosure

This page was left intentionally blank.

Table of Contents Page

SUMMARY

....................................................................................................................................1 1.0 GENERAL INFORMATION...............................................................................................1 1.1 Purpose of the application .....................................................................................2 1.2 Package Design Information..................................................................................3 1.3 Evaluation Findings................................................................................................3 2.0 STRUCTURAL EVALUATION..........................................................................................3 2.1 Description of Structural Design ............................................................................3 2.1.1 Outer Confinement Vessel .........................................................................4 2.1.2 Inner Containment Vessel..........................................................................5 2.2 Evaluation Findings................................................................................................5 4.0 CONTAINMENT EVALUATION........................................................................................5 4.1 Description of the Containment System ................................................................6 4.2 Containment Evaluation.........................................................................................6 4.3 Evaluation Findings................................................................................................6 7.0 MATERIALS EVALUATION .............................................................................................7 7.1 Evaluation of Materials of Packages Designs........................................................7 7.1.1 Evaluation of Codes and Standards for Materials, Fabrication, Examination, and Testing...........................................................................8 7.1.1.1 Materials.........................................................................................8 7.1.1.2 Fabrication......................................................................................9 7.2 Evaluation findings...............................................................................................14 8.0 OPERATING PROCEDURES EVALUATION ................................................................14 REFERENCES ............................................................................................................................14 CONCLUSION ............................................................................................................................15

This page was left intentionally blank.

SAFETY EVALUATION REPORT Letter Authorization Docket No. 71-9279 Model No. HalfPACT Certificate of Compliance No. 9279

SUMMARY

By application dated February 15, 2023 (SIMCO, 2023a), as supplemented on April 27, 2023 (SIMCO, 2023b), pursuant to Title 10 of the Code of Federal Regulations Part 71, Salado Isolation Mining Contractors LLC SIMCO (the applicant thereafter) requested approval by letter to allow a one-time shipment of the HalfPACT package No. 506 Inner Containment Vessel (ICV 506), with payload SRE033, from the Waste Isolation Pilot Plant (WIPP) to the Savannah River Site (SRS). The request sought to credit the outer confinement vessel (OCV) as the HalfPACT packages containment boundary.

Revision 11 of the Certificate of Compliance (CoC) is the basis of this request since it is the most recent revision of the certificate for the Model HalfPACT. The proposed configuration is not currently authorized as contents in CoC No. 9279, Revision 11 (NRC, 2022).

The CoC No. 9279 for the Model No. HalfPACT package is amended by letter. The conditions of this approval are included in the Conditions section of this safety evaluation report (SER). The contents will be transported under Title 10 of the Code of Federal Regulations (10 CFR) Part 71, Packaging and Transportation of Radioactive Material, in an exclusive use transport.

NRC staff (the staff) reviewed the application, using the guidance in NUREG-2216, Standard Review Plan for Transportation Packages for Spent Fuel and Radioactive Material (NRC, 2020). Based on the statements and representations in the application, as supplemented, the staff concludes that the that the request does not affect the ability of the package to meet the regulatory requirements of 10 CFR Part 71 1.0 GENERAL INFORMATION The objective of this general information evaluation is to verify that the applicant has provided an adequate description of the package to familiarize reviewers with the pertinent features of package. The drawings provided by the applicant, as these pertain to the proposed changes to the package Model No. HalfPACT, are sufficiently detailed and consistent with the package description to provide reasonable assurance that the transportation package can meet the regulations.

Revision 9 of the safety analysis report (SAR) of the HalfPACT package is the basis for Revision 11 of CoC No. 9279 (NRC, 2022). The applicant submitted the following additional documents as part of the application for the letter authorization (SIMCO, 2023a and SIMCO, 2023b):

1) Document No. HPT-PRO-0003, Revision 1, Containment for One-Time Shipment Supporting ICV 506
2) Document No. HPT-PRO-0001, Revision 2, Operating Procedures for One-Time Shipment Supporting ICV 506
3) Document No. HPT-PRO-0002, Revision 2, Acceptance Tests and Maintenance Program for One-Time Shipment Supporting ICV 506
4) Document ICV 506,Payload SRE033 Flammable Gas Concentration Initial Condition
5) Document No. PLD-CAL-0007, Revision 1, Flammable Gas Concentration Evaluation for HalfPACT Payload SRE033
6) Document No. HPT-CAL-0001, Revision 1, Loaded HalfPACT ICV Lifting Evaluation
7) WIPP Container Data Report SWD12275 and WIPP Payload Data Report SRE033
8) Section 3.1.4, Payload Container (PT03) Requirements (Balance of Plant), of Packaging and Transportations System (PT00) System Design Description (SDD) (SDD PT00),

Revision 13 In this SER, Revision 9 of the SAR of the HalfPACT package is referred as Revision 9 of the HalfPACT application. Revision 9 of the HalfPACT application and documents listed above constitute the application for the letter authorization. Therefore, the latter is referred as the application in this SER.

1.1 Purpose of the application The purpose of this application is to allow shipping the HalfPACT package No. 506 ICV to the SRS crediting the OCV as the containment boundary. The HalfPACT package No. 506 was received from SRS to the WIPP on August 26, 2022 (shipment No. SR220010). The applicant describes that, as part of the operating procedures of the HalfPACT package, they vented and drew a sample of the head space between the OCV and the ICV (i.e., ICV headspace) prior to removing the ICV lid. The sample of the ICV headspace came back with detectable airborne plutonium-238 and americium-241 contamination. The applicants safety protocol does not allow opening a contaminated ICV and indicates that the package should be returned to SRS to investigate the possible source of contamination.

Condition 11(b) of CoC No. 9279 (NRC, 2022), requires a 5-year maintenance certification for the HalfPACT package. This certification was expired for the HalfPACT No. 506 by the time that possible contamination was detected. Therefore, the applicant could not ship the HalfPACT No. 506 to the SRS.

The staffs evaluation of the proposed action is included in the following sections of the SER.

2

1.2 Package Design Information The applicant proposed to allow crediting the OCV as the packages containment boundary to allow a one-time shipment of the HalfPACT package No. 506 ICV to the SRS. The applicant did not propose changes to the package drawings. The applicant provided calculations and assumptions related to crediting the OCV as the containment boundary.

Prior NRC authorization of the HalfPACT package per 10 CFR 71, including use the ICV as the single containment boundary, is provided in NRCs CoC No. 9279, Revision 11, dated November 21, 2022 (NRC, 2022). This CoC was issued based on NRC staff (the staff thereafter) review of Revision 9 of the HalfPACT application, dated October 2022 (NWP, 2022).

The staffs review is documented in the SER, dated November 21, 2022 (NRC, 2022). This prior approval of the HalfPACT package included only the ICV as the single authorized containment boundary; it did not include the use of the OCV as the containment boundary for this single containment package.

1.3 Evaluation Findings

The staff reviewed documentation provided by the applicant to verify that statements presented by the applicant are acceptable for the review and approval of the revision of the CoC for the Model No. HalfPACT package, as required by 10 CFR 71.33. Based on the review of the statements and representations provided by the applicant, the staff concludes that the package, packaging, and contents have been adequately described to meet the requirements of 10 CFR Part 71.

2.0 STRUCTURAL EVALUATION The purpose of this evaluation is to verify that the proposed action related to the HalfPACT package provides adequate protection against loss or dispersal of the proposed radioactive contents as required in 10 CFR Part 71 under normal conditions of transport (NCT) and hypothetical accident conditions (HAC). The following sections document the staffs evaluation of the proposed design changes to the HalfPACT transportation package.

2.1 Description of Structural Design The applicant requested authorization for a one-time shipment of HalfPACT No. 506 package ICV inside of a different HalfPACT OCV that will be equipped and qualified to serve the containment function during transport. As the HalfPACT maintenance certificate is expired, the ICV containment function can no longer be credited. The OCV is equipped and qualified to serve as a containment for this one-time shipment by first installing important-to-safety (ITS)

Category A O-rings as the OCV main and vent port seals. The fully assembled OCV will then undergo a set of containment boundary verification tests:

1) an internal pressure test, a full-body helium in-leakage test, and
2) external leakage tests at the main and vent port seal locations.

The ICV 506 is sealed and contains payload in a standard waste box, weighing a total of 3,152.35 pounds (lbs.). In order to transfer the loaded ICV 506 to the new OCV, the ICV must be lifted by attachment to all three of its lifting sockets which are located on the lid. In a typical 3

HalfPACT package assembly for shipment, the ICV lid only or empty ICV, weighing 2,250 lbs.,

is permitted to be lifted using these lifting sockets. As the one-time shipment requires a previously unanalyzed ICV lift scenario, the applicant provided an analysis of the ICV lid to evaluate its structural acceptability for this transfer lift condition.

2.1.1 Outer Confinement Vessel Per Revision 11 of CoC No. 9279 (NRC, 2022), the OCV is credited as a confinement vessel only. Accordingly, per drawing No. 707-SAR, Revision 12, the OCV fabrication and inspection is performed in accordance with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section III, Division 1, Subsection NF, Supports. However, per section 2.1.2.1.2 of Revision 9 of the HalfPACT application (NWP, 2022), the structural design of the OCV was performed in accordance with ASME Subsection NB, Class I Nuclear Components, as the OCV previously served a containment function from the CoC Revisions 0 to 6. As such, the package was previously evaluated for and found to satisfy the NCT and HAC, employing the maximum loaded ICV weight of 9,850 lbs., which bounds that of ICV 506.

Therefore, staff concludes that the current package is structurally adequate to meet the requirements of 10 CFR Parts 71.71 and 71.73.

For this one-time shipment, in section 1.1 of HPT-PRO-0003, Revision 1, the applicant notes that the OCV to be employed will have its main and vent port seals replaced with ITS Category A butyl rubber O-rings.

Per section 8.1 of HPT-PRO-0002, Revision 2, pre-shipment inspections and tests will also be performed on the assembled OCV to verify its physical capability to function as a vessel. First, visual inspection of the welds and seals will be performed, followed by an internal pressure test to 150% of maximum operating pressure.

Finally, the application states, in section 8.1.3 of HPT-PRO-0002, that helium leakage rate tests on the overall OCV in-leakage and the main and vent port O-ring seal leakage will be performed in accordance with ANSI N14.5, American National Standard for Radioactive Materials -

Leakage Tests on Packages for Shipment (ANSI, 1997). The staff concludes that these tests are adequate to determine the acceptability of the OCV as a containment vessel for the one-time shipment. Further, per section 8.1.2.2, Revision 9 of the HalfPACT application (NWP, 2022), due to the OCVs normal service as a confinement boundary, the internal pressure and leakage rate testing to the leaktight criterion per ANS N14.5 are optional tests at the time of fabrication. Section 4.0 of this SER includes the evaluation of the adequacy and applicability of the leak test criteria to the one-time shipment requested in the application (SIMCO, 2023a and SIMCO, 2023b).

The staff notes that in section 7.0, Materials Evaluation, of this SER, the differences in fabrication requirements between ASME subsections NB and NF are compared for the OCV and it is concluded that the OCV fabrication per subsection NF is acceptable solely for this one-time shipment.

The staff has reviewed the applicable information provided in the application for the authorization request letter (SIMCO, 2023a and SIMCO, 2023b), Revision 9 of the HalfPACT application (NWP, 2022), and drawing No. 707-SAR, Revision 12. The staff concludes that, based on the design criteria and pre-shipment testing performed, the equipped and qualified HalfPACT OCV meets the requirements of 10 CFR 71.71 and 71.73 and is structurally acceptable to serve as a containment vessel for the one-time shipment of ICV 506.

4

2.1.2 Inner Containment Vessel The ICV 506 is sealed and contains a payload housed within a standard waste box. Per HPT-CAL-0001, Revision 1, an empty ICV weights 2,250 lbs. and the loaded ICV for HalfPACT package No. 506 weighs 3,152.35 lbs. Drawing 707-SAR, Revision 12, indicates that the lifting sockets on the ICV lid may only be utilized for the lift of the lid alone or an empty ICV.

Therefore, the lift of a loaded ICV is not a previously analyzed condition in Revision 9 of the HalfPACT application (NWP, 2022).

The applicant provided the following analyses as part of this application (SIMCO, 2023a and SIMCO, 2023b):

a) a structural finite element (FE) model of a portion of the ICV to analyze the ICV under the lifted total load of 3,152.35 lbs. and internal pressure conditions of 5.54 psig (pounds per square inch gauge) using the FE computer code, ANSYS.

Limiting the allowable Von Mises stress in the vicinity of the lifting sockets stress to one-third of the material yield stress (i.e., 10,000 psi) in accordance with 10 CFR 71.45(a), the resulting maximum stress is determined to be 6,045 psi, resulting in a design safety margin of 65 percent (%).

b) a local structural FE model of the lifting pin to determine the effects of the lifted load alone, resulting in a maximum equivalent stress of 6,639 psi, corresponding to a design safety margin of 51% in the thinnest portion of the lifting pin. The local and global design margins determined for the effects of the proposed lift correspond to a minimum design safety margin of over 50% against the allowable material stress, the transfer lift of the ICV is structurally acceptable In section 8.1.2.1 of Revision 9 of the HalfPACT application (NWP, 2022), the applicant noted that the three ICV lifting sockets are tested to a combined total load of 7,500 lbs. which is larger than the actual load of ICV No. 506. The staff finds with reasonable assurance that the HalfPACT package ICV No. 506 lift is feasible.

2.2 Evaluation Findings

Based on the review of the information provided in the authorization request letter (SIMCO, 2023a and SIMCO, 2023b) and the Revision 9 of the HalfPACT application (NWP, 2022), the staff finds that the equipped and qualified HalfPACT OCV meets the package description and evaluation requirements of 10 CFR 71.33 and 71.35, and is structurally acceptable to serve as a containment vessel for the one-time shipment of ICV package No. 506. Based on the information provided in the authorization request letter (SIMCO, 2023a and SIMCO, 2023b) and the Revision 9 of the HalfPACT application (NWP, 2022), the staff finds that the ICV No. 506 meets the lifting requirements of 10 CFR 71.45(a). The applicant adequately demonstrated that the HalfPACT package satisfies the structural requirements of 10 CFR Part 71.

4.0 CONTAINMENT EVALUATION The purpose of this evaluation is to verify that the proposed changes to HalfPACT package No. 506 for this one-time shipment provide adequate protection against loss or dispersal of 5

radioactive contents and to verify that the package design meets the requirements of 10 CFR Part 71 NCT and HAC.

4.1 Description of the Containment System The description of the proposed OCV for this shipment, contained in document No.

HPT-PRO-0003, Revision 1, Containment for One-Time Shipment Supporting ICV 506, submitted as part of the application, describes a change to the containment boundary of the HalfPACT package for this one-time shipment. The applicant proposes a single leaktight barrier, defined by the OCV closure since, in this case, ICV 506 may no longer be leaktight, and, as such, can no longer be relied upon as the containment boundary.

4.2 Containment Evaluation Section 1.0 of the SER includes a description of the proposed change. The staff reviewed the changes proposed by the applicant in preparation for the requested one-time shipment. The changes to section 4.1.2 of the HalfPACT application (SIMCO, 2023a and SIMCO, 2023b) indicate that the ICV 506 will be placed into another OCV that will then be tested to leaktight criteria as defined in ANSI N14.5-1997 (ANSI, 1997). The latter defines leaktight sealing integrity as a leakage rate not to exceed 1 x 10-7 standard cubic centimeters per second (scc/sec), air.

Demonstration of the leaktight leakage criteria would preclude leakage of radioactive contents from the HalfPACT package and, thus, would meet the criteria for release of radioactive material from the HalfPACT package for transportation under both NCT (as found in 10 CFR 71.43(f) and 71.51(a)(1)) and HAC (as found in 10 CFR 71.51(a)(2)).

Further, in accordance with section 5.0 of the applicants document titled CH-TRU Waste Authorized Methods for Payload Control (CH-TRAMPAC), the applicant provided an analysis of the potential for generation of combustible gases from the package contents as well as pressure generation in the ICV cavity. Attachment E of their submittal, ICV 506 Payload SRE033 Flammable Gas Concentration Initial Condition, (SIMCO, 2023a) includes the calculation provided by the applicant considering the potential for flammable gas generation in the ICV 506 during shipment. The staff reviewed the calculation and agreed with the conclusion provided by the applicant that:

1) flammable gas concentration will remain less than or equal to the CH-TRAMPAC section 5.0 limit of 5%... and
2) the associated pressure increasewill easily comply with the 50 psig HalfPACT design pressure limit.

In response to RAIs (SIMCO, 2023b), the applicant included an internal pressure calculation in section 4.1.2 of the application. The staff reviewed the calculations and found them to be acceptable.

4.3 Evaluation Findings

The staff has reviewed the applicants description and evaluation of the containment system and concludes that:

6

1) the application identifies established codes and standards for the containment system
2) the package includes a containment system securely closed by a positive fastening device that cannot be opened unintentionally or by a pressure that may arise within the package The staff has reviewed the applicants evaluation of the containment system under NCT and concludes that the package is designed, constructed, and prepared for shipment so that under the tests specified in 10 CFR 71.71, Normal Conditions of Transport, the package satisfies the containment requirements of 10 CFR 71.43(f) and 10 CFR 71.51(a)(1) for NCT with no dependence on filters or a mechanical cooling system.

The staff has reviewed the applicants evaluation of the containment system under HACs and concludes that the package satisfies the containment requirements of 10 CFR 71.51(a)(2) for HACs, with no dependence on filters or a mechanical cooling system.

Based on the review of the statements and representations in the application, the staff concludes that the containment boundary has been adequately described and evaluated and that the applicant provided sufficient evidence that use of the OCV as a containment boundary demonstrates adequate containment capability to meet the requirements of 10 CFR Part 71 for a one-time shipment.

7.0 MATERIALS EVALUATION The staff reviewed the applicants proposed changes to the HalfPACT package design to verify that applicant performed an acceptable evaluation with respect to materials to demonstrate that the HalfPACT package meets the requirements of 10 CFR Part 71 under NCT and HAC. The staff's materials review focused on materials topics relevant to the proposed change.

7.1 Evaluation of Materials of Packages Designs For the NRC-approved configuration of the HalfPACT package in CoC No. 9279, Revision 11 (NRC, 2022), and described in Revision 9 of the application (NWP, 2022), the stainless steel OCV is the innermost metallic boundary of the outer confinement assembly (OCA). In the approved configuration, the OCA is used primarily for structural and thermal protection of the ICV containment boundary and radioactive contents. The OCV portion of the OCA may also be used as an optional secondary containment boundary if the optional rubber O-ring seals are used to establish a leaktight seal between the OCV upper and lower seal flanges. However, for this NRC-approved configuration, the ICV must always serve as the single designated pressure-retaining and leaktight containment boundary regardless of whether the OCV is optionally used as a secondary containment through the use of its optional O-ring seals; the NRCs prior approval of the package only credits the ICV for containment and does not credit the OCV for any containment function.

The application for one-time shipment using the OCV as the single containment boundary instead of the ICV includes proposed changes to nondestructive examination (NDE) methods, acceptance tests, and operating procedures. However, the application does not include any change to the materials and fabrication methods that are used for construction of packaging 7

components, including the ICV and OCV. There is also no change to any of the authorized package contents. Therefore, the staffs materials evaluation considers the suitability of the prior approved non-containment OCV materials and fabrication methods, in concert with the proposed changes to the OCV NDE methods and acceptance tests, to evaluate the proposed one-time use of the OCV as the authorized containment boundary instead of the ICV.

7.1.1 Evaluation of Codes and Standards for Materials, Fabrication, Examination, and Testing The NRCs prior approval of the HalfPACT package design is based, in part, on the use of the applicable requirements of the 1995 Edition with 1997 Addenda of the ASME BPV Code,Section III for materials, fabrication, and NDE of the stainless steel ICV containment boundary components and the non-containment boundary OCV components. For the proposed one-time shipment, the ICV cannot be credited as the containment due to special circumstances that are explained in detail in the application. For this one-time shipment application, only the OCV is to be used as the containment boundary for the one-time shipment. Therefore, the staff considered whether the applicants continued implementation of the same ASME BPV Code requirements for OCV materials and fabrication, and the applicants proposed changes to NDE and acceptance test criteria for the OCV, are acceptable to ensure that the OCV will adequately perform the containment function for the one-time shipment of the HalfPACT package.

7.1.1.1 Materials The application for the one-time shipment crediting the OCV instead of the ICV as the containment boundary does not propose any change to OCV, ICV, or other packaging materials. However, the staff determined that the approved materials should be reviewed to assess whether the OCV materials are suitable for use in lieu of the ICV materials as containment boundary materials for one-time shipment since the NRCs prior approval of the packaging materials authorized the use of only the ICV (and not the OCV) as the single containment boundary. Therefore, the staff compared the description of the ICV and OCV materials in the prior approved application to determine whether the OCV materials are suitable for use as containment boundary materials for one-time shipment, in lieu of the ICV materials.

The application for one-time shipment states that the OCV containment boundary is a stainless steel vessel comprised of a mating stainless steel lid and body, plus the innermost of two required main O-ring seals between them. In addition, the application states that the OCV containment boundary includes an American Society for Testing and Materials (ASTM) B16, Alloy 360 brass OCV vent port plug with a required O-ring seal. The application specifies that both the ICV and OCV shells and heads are primarily fabricated from Type 304 austenitic stainless steel plates joined by complete joint penetration welds. The application specifies the use of ASTM A240 Type 304 plate material (equivalent to ASME BPV Code, section II, SA-240 Type 304). The application also specifies additional options for stainless steel product forms for the ICV and OCV seal flanges and locking rings, including ASTM A182 Grade F304 forgings (equivalent to ASME BPV Code, section II, SA-182 Grade F304) and ASTM A351 Grade CF8A castings (equivalent to ASME BPV Code, section II, SA-351 Grade CF8A).

The staff confirmed that there is no significant difference between the ICV and OCV with respect to the base material alloy types and associated product form specifications that are used for fabrication of the structural containment boundary components. The staff also confirmed that all of the stainless steel alloys and product specifications for both the ICV and OCV are acceptable for use as pressure-retaining and leaktight containment materials based on the criteria specified 8

in paragraph NB-2120 of the ASME BPV Code,Section III, as recommended in NUREG/CR-3854, Fabrication Criteria for Shipping Containers, March 1985.

The staff also noted that the approved application includes an evaluation of the potential for brittle fracture. This evaluation states that most structural components, including the ICV and the OCV, are fabricated from austenitic stainless steel, and since this material does not undergo a ductile-to-brittle transition in the service temperature range (down to -40 °F), there is adequate protection against brittle fracture. The staff confirmed that both the approved ICV structural containment boundary and the proposed OCV structural containment boundary for one-time shipment are fabricated from austenitic stainless steel. Considering the stainless steel construction, the staff verified that the requirements of the ASME BPV Code,Section III, Subarticles NB-2200 and NB-2300, and the additional guidance of NRC Regulatory Guides 7.11 (NRC, 1991a) and 7.12 (NRC, 1991a), related to ferritic material testing and fracture toughness properties are not applicable since there is no ductile-to-brittle transition in the lower service temperature range. Therefore, considering the selection of OCV base materials and the use austenitic stainless steel for ensuring protection against non-ductile fracture, the staff finds that the application to use the OCV instead of the ICV as the containment boundary for the one-time shipment is acceptable.

With respect to non-metallic containment boundary materials, the staff noted that the one-time shipment application specifies the use of the butyl rubber O-rings for the OCV containment seals. For the prior approved application, the staff confirmed that this O-ring material was previously evaluated for the ICV containment seals and was accepted for use in establishing a leaktight containment seal between the ICV seal flange components. Therefore, the staff finds that the butyl rubber O-rings are acceptable for the OCV containment seals.

7.1.1.2 Fabrication The application for the one-time shipment crediting the OCV instead of the ICV as the containment boundary does not propose any change to the welding and related fabrication methods used to construct the packaging components. However, as with the review of the base materials, the staff determined that the approved fabrication methods should be reviewed to assess whether the OCV is suitable for use, in lieu of the ICV, as the containment boundary for one-time shipment. Therefore, the staff compared the description of the ICV and OCV fabrication methods in the prior approved application to determine whether the OCV is suitable for use as the containment boundary, in lieu of the ICV.

With respect to welding and related fabrication processes used to construct ICV and the OCV, the staff noted that the drawings specify that ICV shell joints shall be fabricated in accordance with the ASME BPV Code,Section III, Subsection NB, article NB-4230, whereas OCV shell joints shall be fabricated in accordance with the ASME BPV Code, section III, subsection NF, article NF-4230. The drawings also specify that the welds for the ICV shell shall conform to the ASME Code,Section III, Subsection NB, article NB-4400, whereas the welds for the OCV shell and non-containment boundary components shall conform to the ASME Code,Section III, Subsection NF, article NF-4400.

The staff noted that NUREG/CR-3854, Fabrication Criteria for Shipping Containers, and NUREG/CR-3019, Recommended Welding Criteria for Use in the Fabrication of Shipping Containers for Radioactive Materials, March 1984, recommend applicable provisions of NB-4000 for fabrication of metallic containment components for transportation packages, whereas these NUREG/CRs generally recommend the use of NF-4000 for fabrication of other 9

safety-related components, such as radiation shielding components, secondary enclosures, and external lifting components, that do not perform containment or criticality safety functions.

Considering these different applications, the staff evaluated the applicants use of NF-4230 and NF-4400 requirements for fabrication of OCV shell welds, considering their use as containment welds during the one-time shipment, by comparing the NF-4230 and NF-4400 requirements with the corresponding ICV containment weld fabrication requirements in NB-4230 and NB-4400.

The NB-4230 and NF-4230 provide requirements for fitting, aligning, and retaining in position parts that are to be joined by welding. The staff noted that NB-4230 and NF-4230 provide similar requirements for fitting and alignment of base metal components for fabrication of full penetration welds in vessel shells. However, the staff also noted the following differences between the two sets of requirements when applied to vessel shell fabrication:

i. NB-4230 specifies different sets of maximum allowable offsets for alignment of base metal sections for fabrication of longitudinal versus circumferential welds in cylinders. NF-4230 specifies just one set of maximum allowable offsets that are equivalent to the offsets specified in NB-4230 for circumferential welds in cylinders, but slightly less conservative than those specified in NB-4230 for longitudinal welds. The staff reviewed this discrepancy and determined that, while not acceptable for longitudinal weld fabrication for containment vessels in packagings for long-term service, the use of the NF-4230 offset requirements for fabrication of longitudinal containment welds for one-time shipment does not present an unacceptable risk of the loss of weld integrity during the one-time shipment. Therefore, the staff found the NF-4230 offset requirements for fabrication of the OCV circumferential and longitudinal shell welds to be acceptable for containment for the one-time shipment.

ii. For fairing of offsets that meet the allowable offset criteria, NB-4230 includes a specific taper ratio requirement for ensuring an acceptable taper over the width of the finished welds, whereas NF-4230 qualitatively specifies that fairing of offsets shall be accomplished by uniform blending over the width of the weld. The staff reviewed this discrepancy and determined that, while not acceptable for fabrication of containment welds for packagings for long-term service, the use of the qualitative NF-4230 requirements for fairing of offsets for containment welds for one-time shipment does not present an unacceptable risk of the loss of weld integrity during the one-time shipment. Therefore, the staff found the NF-4230 fairing requirements for fabrication of the OCV shell welds to be acceptable for containment for the one-time shipment.

The NB-4400 and NF-4400 provide requirements for making and repairing welds. The staff noted that NB-4400 and NF-4400 provide the same or sufficiently similar requirements in the following areas:

i. precautions to be taken before welding ii. welding requirements for double welded joints iii. qualitative requirements for surface condition of finished welds iv. conditions on allowable concavity on the root side of single welded butt joints 10
v. finished weld thickness requirements vi. repair of weld metal defects, including A. elimination of surface defects B. defect removal C. weld repair material, procedures, and welders D. blending of repaired areas E. examination of repair welds F. heat treatment of repaired areas.

The staff also noted several areas where NB-4400 and NF-4400 requirements differ. The staff identified the following potential non-conservatisms associated with the use of NF-4400 instead of NB-4400 requirements for fabricating containment vessel shell welds:

i. NB-4400 includes several restrictions on the use of peening processes to minimize weld distortion, whereas NF-4400 does not impose any restrictions on the use of peening. The staff noted that use of peening to control weld distortion is not included anywhere in fabrication notes on the drawings or elsewhere in the application. However, the use of peening on the OCV and ICV welds cannot be definitively ruled out.

ii. For use of backing rings or strips during welding, NB-4400 specifies detailed requirements for their use, whereas NF-4400 only specifies that backing materials shall be compatible with the base material. The staff noted that the use of backing materials is not included anywhere in the fabrication notes on the ICV or OCV drawings. Since optional use of backing materials is included for other internal package component welds, the staff inferred that backing materials are most likely not used for the ICV or OCV welds; therefore, the different NB and NF requirements related to the use of backing materials during welding are likely not applicable. Nevertheless, the staff noted that use backing materials cannot be definitively ruled out for the ICV and OCV welds.

iii. NB-4400 includes precautions on stopping and restarting of welding processes to ensure the required weld penetration and fusion; these precautions are not included in NF-4400.

iv. For fabrication of full penetration single welded joints, NB-4400 includes precautions on alignment and separation of base metal components to be joined to ensure complete penetration and fusion at the bottom of the joint for the full length; these precautions are not included in NF-4400.

v. NB-4400 includes detailed requirements for the maximum allowable height of the weld reinforcement (i.e., excess weld metal above the flat surface) on each face of the weld for butt welded joints in vessels. NF-4400 does not include any specific requirements for maximum allowable reinforcement of butt welded joints 11

in vessels. However, the staff noted that the fabrication notes in the application drawings specify the same requirement for the maximum allowable weld reinforcement for the ICV and the OCV shell weld joints. The staff confirmed that the maximum allowable weld reinforcement specified on the drawings meets the weld reinforcement requirements of NB-4400. Therefore, the staff confirmed that there is no difference in the fabrication requirements applied to the OCV and ICV shells with respect to weld reinforcement.

Considering the first four potential non-conservatisms associated with using NF-4400 instead of NB-4400 for fabrication of containment vessel shell joints, the staff determined that the NF-4400 requirements are generally not acceptable for fabrication of containment welds for packagings for long-term service. However, given the limited scope of these non-conservatisms in concert with the areas (noted above) where the NF-4400 requirements are the same as, or sufficiently similar to, the NB-4400 requirements, the staff determined that the use of NF-4400 requirements for containment shell weld fabrication does not present an unacceptable risk of the loss of containment weld integrity during the one-time shipment. Therefore, the staff found the use of the NF-4400 requirements for fabrication of the OCV shell welds to be acceptable for containment for the one-time shipment.

For fabrication of vessel heads, the staff noted that the drawings specify that both the ICV and OCV heads shall be constructed to the ASME BPV Code,Section VIII, and welds for the vessel heads shall be inspected using radiographic examination methods in accordance with the ASME BPV Code,Section III, Subsection NB, Article NB-5000 and Section V, Article 2. The staff confirmed that there is no difference between the ASME BPV Code requirements that are applied to the fabrication of the vessel heads for the ICV and the OCV. With respect to the use of the less comprehensive requirements of the ASME BPV Code,Section VIII, the staff noted that the use of these fabrication methods is already authorized for the ICV head. Further, since the welds are the critical locations for potential fabrication defects, the staff determined that the more comprehensive radiographic examination requirements of ASME BPV Code,Section III, Subsection NB, NB-5000 and Section V, in concert with comprehensive pressure and leakage testing, is sufficient to ensure the absence of unacceptable defects in the OCV head for the one-time shipment. Therefore, with respect to vessel head fabrication and weld examination, the staff determined that the use of the OCV in lieu of the ICV as the containment for one-time shipment is acceptable.

For both the ICV and the OCV, the staff noted that the drawings specify that all welding procedures and personnel shall be qualified in accordance with the requirements of the ASME BPV Code,Section IX. The staff noted that, per the guidance in NUREG-2216, Standard Review Plan for Transportation Packages for Spent Fuel and Radioactive Material, August 2020 (NRC, 2020),Section IX of the ASME BPV Code is generically acceptable to the staff for ensuring adequate qualification of welding procedures and welding personnel for fabrication of containment vessel welds. Therefore, with respect to qualification of welding procedures and personnel, the staff determined that the use of the OCV in lieu of the ICV as the containment for one-time shipment is acceptable.

Based on the foregoing evaluation of the similarities and differences between the ASME BPV Code requirements used for fabrication of the ICV versus the OCV, the staff determined that, with respect to vessel fabrication, the use of the OCV in lieu of the ICV as the containment for the one-time shipment is acceptable.

12

7.1.1.2.1 Examination The staff noted that the prior approved application specifies surface and volumetric NDE requirements, based on applicable provisions of the ASME BPV Code, Sections III and V, for ICV and OCV base materials and welds for ensuring the absence of unacceptable defects. NDE of base materials is performed to meet the applicable requirements of the ASME Code,Section III, Subarticle NB-2500 and Section V, as specified in the fabrication notes on the drawings for both the ICV and OCV. The staff determined that the existing requirements for NDE of OCV base material are sufficient to ensure the absence of unacceptable defects in base materials, as needed for OCV containment boundary integrity for the one-time shipment.

The staff noted that the prior approved application includes different sets of NDE requirements for surface and volumetric examinations of the OCV and the ICV welds. The generic notes in the drawings specify that all welds of the ICV containment boundary shall be liquid penetrant inspected on final pass in accordance with the ASME BPV Code, section III, subsection NB, Article NB-5000 and section V, whereas all OCV shell welds shall be liquid penetrant inspected on final pass in accordance with the ASME BPV Code, section III, subsection NF, Article NF-5000. In addition, the drawings notes and related application information specify that all ICV containment body welds are radiographed in accordance with the ASME BPV Code, section III, subsection NB, Article NB-5000 and section V to ensure structural and containment integrity, and other non-radiographed safety-related welds, such as those that attach the ICV vent port coupling to the containment vessel shell are examined using liquid penetrant testing, as specified in the ICV drawings.

To address the above non-conservatisms in the weld NDE requirements, the application included a change to the OCV weld NDE requirements for the one-shipment specifying that all OCV containment body welds are radiographed to ensure structural and containment integrity, and other non-radiographed safety-related welds, such as those that attach the OCV vent port coupling to the containment vessel shell are examined using liquid penetrant testing, as specified in the OCV drawings. The staff verified that the performance of radiographic and surface examinations of OCV containment welds, in concert with the required containment boundary pressure and leakage testing, is sufficiently consistent for one-time shipment with the examination and testing requirements that were previously approved for the ICV containment boundary. The staff determined that these NDE criteria are adequate to ensure the absence of unacceptable weld defects that may compromise the structural and containment integrity of the OCV containment boundary during the one-time shipment. Therefore, the staff finds that the NDE requirements for the OCV containment welds are acceptable for ensuring OCV containment weld integrity for the one-time shipment.

7.1.1.2.2 Testing As addressed in the prior approved application, containment boundaries for radioactive material transportation packages are required to undergo pressure and leakage testing per established codes and standards to ensure no unacceptable loss or dispersal of radioactive contents (including gaseous radioisotope species) to the environment. Since, per the one-time shipment application, the OCV is to use as the single containment boundary for the HalfPACT package in lieu of the ICV, the staff reviewed the pressure and leakage testing requirements that are implemented for the OCV to ensure that it will function as a leaktight containment for the one-time shipment. The details of the staffs review of these testing requirements are covered in sections 2.0 and 4.0 of this SER, wherein the staff finds that these testing requirements are 13

acceptable to ensure that the OCV will adequately function as a leaktight containment boundary for the one-time shipment of the package.

7.2 Evaluation findings Based on the foregoing evaluation of the materials, fabrication, examination, and testing requirements that are implemented for the OCV containment boundary, including use of applicable ASME BPV Code requirements for materials, fabrication, and examination of OCV containment components, the staff determined that the proposed application to use of the OCV in lieu of the ICV as the containment boundary for the one-time shipment of the HalfPACT package is acceptable and meets the requirements in 10 CFR 71.41(d) and 71.43(d).

8.0 OPERATING PROCEDURES EVALUATION The purpose of the package operations evaluation is to verify that the proposed changes to the operating controls and procedures for the one-time shipment of ICV 506 are adequate and meet the requirements of 10 CFR Part 71.

The application includes HPT-PRO-0001, Revision 2, which provides procedures for the one-time shipment of ICV 506 (SIMCO, 2023b). The procedures provided include package loading of the ICV 506 into an alternate OCV and preparations for transport, package unloading, preparation of the empty package for transport, and preshipment leakage rate tests. The applicant used the approved package operations from section 7.0 of the application (NWP, 2022) to the extent possible and modified the steps as necessary for this one-time shipment.

The staff reviewed the revised operating procedures in HPT-PRO-0001 to verify that the package will be operated in a manner that is consistent with its design evaluation and the unique requirements of this one-time shipment. Based on its evaluation, the staff concludes that the combination of the engineered safety features and the operating procedures provide adequate measures and reasonable assurance for safe operation of the proposed one-time shipment of ICV 506 in an alternate OCV in accordance with 10 CFR 71.41(d).

REFERENCES (ANSI, 1997) American National Standards Institute ANSI N 14.5-1997, American National Standard for Radioactive Materials - Leakage Tests on Packages for Shipment, ANS, LaGrange Park, IL.

(DOE, 2021) U.S. Department of Energy, Carlsbad Field Office, Contact-Handled Transuranic Waste Authorized Methods for Payload Control (CH-TRAMPAC), Carlsbad, New Mexico.

(SIMCO, 2023a) Sellmer, Todd, Salado Isolation Mining Contractors LLC (SIMCO), letter to Ms. Diaz-Sanabria, Nuclear Regulatory Commission (NRC) (Attn:

Document Control Desk), February 15, 2023, ML23046A454.

(SIMCO, 2023b) Sellmer, Todd, Salado Isolation Mining Contractors LLC (SIMCO), letter to Director, Spent Fuel Project Office, Nuclear Regulatory Commission (NRC) (Attn: Document Control Desk), April 27, 2023, ML23117A072.

14

(NRC, 2020) U.S. Nuclear Regulatory Commission, Standard Review Plan for Transportation Packages for Spent Fuel and Radioactive Material: Final Report, NUREG-2216, August 2020.

(NRC, 1991a) U.S. Nuclear Regulatory Commission, Fracture Toughness Criteria of Base Material for Ferritic Steel Shipping Cask Containment Vessels with a Maximum Wall Thickness of 4 Inches (0.1 m), Regulatory Guide 7.11, June 1991, ML003739413.

(NRC, 1991b) U.S. Nuclear Regulatory Commission, Fracture Toughness Criteria of Base Material for Ferritic Steel Shipping Cask Containment Vessels with a Wall Thickness Greater than 4 Inches (0.1 m) But Not Exceeding 12 Inches (0.3 m), Regulatory Guide 7.11, June 1991, ML003739424.

(NRC, 2022) U.S. Nuclear Regulatory Commission, Certificate of Compliance for Radioactive Material Package No. 9279, Revision 11, Docket No.

71-9279, November 21, 2022, ML22312A405.

(NWP, 2022) Sellmer, Todd, Nuclear Waste Partnership LLC (NWP), letter to Director, Spent Fuel Project Office, Nuclear Regulatory Commission (NRC)

(Attn: Document Control Desk), October 10, 2022, ML22283A028; ML22319A224 (redacted).

CONDITIONS This authorization is valid for one shipment of a HalfPACT package limited by the following additional conditions:

1) The package will be shipped by truck.
2) There will be a maximum of one loaded HalfPACT package per shipment on a single truck.
3) The shipment will be made under exclusive use.
4) The shipment will only include the ICV of HalfPACT package No. 506 as authorized content.

All other conditions of CoC No. 9279, Revision 11 (NRC, 2022) shall remain the same.

CONCLUSION CoC No. 9279 has been amended by letter to authorize one shipment of the ICV No. 506 in the Model No. HalfPACT package. This authorization expires on October 31, 2023.

15

Based on the statements and representations in the application, and with the conditions listed in this SER, the staff agrees that this change does not affect the ability of the package to meet the requirements of 10 CFR Part 71.

Issued on .

June 2, 2023 16

Retrieved from "https://kanterella.com/w/index.php?title=ML23137A441&oldid=3567981"