ML24144A267
| ML24144A267 | |
| Person / Time | |
|---|---|
| Site: | 07109355 |
| Issue date: | 04/29/2024 |
| From: | Storage and Transportation Licensing Branch |
| To: | |
| Shared Package | |
| ML24144A266 | List: |
| References | |
| Download: ML24144A267 (2) | |
Text
4/29/2024 1
DRAFT NRC Staff Observation related to 435-B Package Safety Analysis Report, Rev. 6 Section 7-1, Procedures for Loading the Package Docket No. 71-9355 Observation 7-1 Clarify section 7.1.3.1 step 10 of the application, related to:
- 1. the shipment of Type B contents that has been preceded in shipment by Special Form, Type A contents, Low Specific Activity (LSA) material, or Surface Contaminated Objects (SCO) contents, specifically when the vent port plug cannot be verified as being closed for the Type B contents, and
- 2. the performance of an ANSI N14.5 pre-shipment leakage rate test on seals that have been opened.
Section 7.1.3.1, step 10 of the application states (with underlining for emphasis):
- 10. Preshipment leakage rate testing of the main containment O-ring seal and vent port sealing washer shall be performed according to the following criteria:
- a. If all of the radioactive material in the 435-B package is contained in sealed sources that have been qualified as special form according to the requirements of Section 7.1.6, Recognition of Special Form, no leakage rate test is required. NOTE: If this criterion is not met, a leakage rate test must be performed according to (b) or (c) of this step.
- b. If the main containment (upper) O-ring seal has been replaced or the corresponding sealing surface repaired, or if the vent port plug or sealing washer has been replaced or the mating sealing surface repaired, the leakage rate tests shall be performed according to Section 8.2.2, Maintenance/Periodic Leakage Rate Tests.
- c. If the criteria of step (b) above do not apply, as an option, preshipment leakage rate testing may be performed according to Section 7.4, Preshipment Leakage Rate Test.
For part 1 of the clarification, package users should consider the following (with underlining for emphasis) from NRC Information Notice (IN) 2016-04 (ML16063A287), which would also apply to special form material as well as Type A contents, LSA material, or SCO. The staff acknowledges that the circumstances described below could be unlikely.
Pre-shipment leakage rate test on Type B package containment boundary components that have been opened: Section 7.6 and Table 1 of ANSI N14.5-2014 address the pre-shipment leakage rate test on Type B package containment boundary components that have been opened. The pre-shipment leakage rate test is necessary to confirm that the containment system is properly assembled for each shipment. Type B packages
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containing a Type B quantity of material could have been used to transport Type A, Low Specific Activity (LSA) material, or Surface Contaminated Objects (SCO) in a previous shipment. Containment boundary components (e.g., seals and valves) could have been opened during a previous shipment of Type A contents, LSA material, or SCO, but a pre-shipment leakage rate test might not have been performed at that time. A pre-shipment leakage rate test should be performed on the containment boundary components that cannot be verified as being closed to confirm that the containment system is properly assembled on packages containing a Type B quantity of material.
For part 2 of the clarification, an ANSI N14.5 pre-shipment leakage rate testing should be performed on containment boundary seals that have been opened, unless a maintenance/periodic leakage rate test has been performed before each shipment, after the contents are loaded, and the containment system is assembled, in lieu of a pre-shipment leakage rate test. This is especially important for Type B contents in normal form.
This information is needed to determine compliance with 10 CFR 71.37(b), 71.51(a)(1) and (2),
71.87(c).