Information Notice 1990-27, Clarification of the Recent Revisions to the Regulatory Requirements for Packaging of Uranium Hexafluoride (UF6) for Transportation

Clarification of the Recent Revisions to the Regulatory Requirements for Packaging of Uranium Hexafluoride (UF6) for Transportation

ML031210564
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	04/30/1990
From:	TenEyck E Q Office of Nuclear Material Safety and Safeguards
To:
References
IN-90-027, NUDOCS 9004240313
Download: ML031210564 (13)

--'-UNITED STATES NUCLEAR REGULATORY

COMMISSION

OFFICE OF NUCLEAR MATERIALS

SAFETY AND SAFEGUARDS

WASHINGTON, D.C. 20555 April 30, 1990 NRC INFORMATION

NOTICE NO. 90-27: CLARIFICATION

OF THE RECENT REVISIONS

TO THE REGULATORY

REQUIREMENTS

FOR PACKAGING

OF URANIUM HEXAFLUORIDE (UF 6) FOR TRANSPORTATION

Addressees

All Uranium Fuel Fabrication

and Conversion

Facilities.

Purpose

This notice Is being issued to review and clarify the significant

features of two recent rulemaking

actions which were completed

by the U.S. Department

of Transportation (DOT), relating to the regulatory

requirements

for the packaging of UF for transportation.

It is suggested

that recipients

review the infor-matiog here, and consider actions, if appropriate, to preclude possible problems in the transport

of UF .However, this information

does not constitute

new U.S.Nuclear Regulatory

C;Amission (NRC) requirements, therefore

no specific action or written response Is required.Background:

The routine transportation

of UF,, both as a non-fissile

radioactive

material (depleted

and natural uranium, a "low specific activity" [LSA) material)

and as a fissile radioactive

material (when containing

'greater than" 1.0 weight percent U-235), constitutes

a very significant

volume of radioactive

materials transportation

in the nuclear fuel cycle, both within the USA and worldwide.

UF is packaged for transport

in cylinders

which must meet certain inspection, testing and in-service

requirements

which are found in the 49 CFR DOT regu-lations and certain physical standards

which are adopted by reference

in those regulations.

The primary type of packaging

used are cylinders

of steel, nickel, or monel in various diameters

ranging from 1 inch to 48 inches.For shipments

of the unenriched

UF6 as an LSA, non-fissile

radioactive

material, the cylinders

are normally shipped bare, without protective

overpacks.

Over-packs are used, however, for the shipment of enriched UF , as a fissile material, when the U-235 content exceeds 1.0 weight percent. The overpacks

used are either of the DOT Specifications

2OPF or 21PF Series as prescribed

in 49 CFR 178.120 and 178.121 of DOT regulations, or as authorized

in several NRC Certificates

of Compliance. (See Attachment

1.) Most shipments

of UF are made in exclusive- use highway or rail vehicles, and in equivalent

defined stowage areas or inter-modal freight containers

aboard seagoing vessels.9004240313

.

IN 90-27 April 30, 1990 Before November 1986, the DOT regulations

were not specific on the standards for the cylinders, but rather, referenced

the need to use a "strong tight package" for exclusive-use

shipments.

For non-exclusive-use

shipments, the cylinders

were required to meet the requirements

for DOT Specification

7A, Type A packaging.

[The cylinders

actually used, however, were in accordance

with industry standards

that exist in ANSI N14.1 and/or a Department

of Energy (DOE) document, ORO-651].

On November 17, 1986, DOT issued a new regulation

49 CFR 173.420) specifying

cylinder standards

and other requirements

for all shipments

of UF Several supplemental

notices and amendments

were subsequently

issued in the Docket HM-166V, with the last revision of the final rule having been issued on August 29, 1989.As for the protective

overpacks

for the cylinders, DOT originally

issued its regulatory

specifications

for the DOT Specifications

2OPF and 21PF series in 1974. Over the years, during the use of these overpacks, increasing

diffi-culties have been experienced

in their use, maintenance

and quality control.The primary difficulty

has been with the tendency of the packagings

to collect and retain water within the phenolic foam insulating

medium within the walls of the overpack.

Although the presence of this water is not an immediate safety problem, the water does increase the gross weight of the packages significantly, and also accelerates

corrosion

of the metal and rotting of the wood components

of the overpacks.

It often tends to 'slosh' out from the drain holes, and sometimes

creates considerable

alarm to the public and to carriers, when water (albeit non-radioactive

water) is observed to be leaking from a package marked "RADIOACTIVE" in commerce.

Accordingly, DOE petitioned

DOT for rulemaking

to amend the DOT 21PF series protective

overpack specification, so as to authorize

the use of an improved design that would correct the deficiencies.

A notice of proposed rulemaking

was issued in August 1984, with the final rule issued on September

20, 1988 (Docket HM-190).During the interim period, between the notice and final rule, several NRC-licensee shippers of UF in protective

overpacks

applied for and received NRC certificates

of compliance

authorizing

use of non-DOT specification, improved overpacks.

Discussion:

Attachments

2 and 3 are chronological

summaries

of the two recently completed DOT rulemaking

dockets relating to UF packaging

and transportation.

Attach-ment 2 summarizes

the Docket HM-166V 9n cylinder requirements, and Attachment

3 summarizes

the Docket HM-190 rule changes on the DOT Specification

21PF series of protective

overpacks.

Attachment

1 is a summary of the present status of several NRC certificates

of compliance

for overpacks

that are similar to the DOT Specification

21PF overpacks.

Discussion

of each of these areas follows: CYLINDERS The net effect of the cylinder rulemaking

imposed by the new 49 CFR 173.420 in Docket HM-166V has been to formalize, as regulatory

requirements, the use of cylinders

which have already been in use for many years, pursuant to certain industry standards, as well as other requirements (e.g., requirements

for UF 6 IN 90-27 April 30, 1990 to be In solid fiorm and specified

vl inetric fill liipits). .In carrying out te ru ema ng, owever, severa dY culties were Observed te.g., he method of cleaning for other than new cylinders, provisions

for use of existing cylinders, etc.), as evidenced

by the series of eight notices and amendments

between April 1986 and April 1989. It is noted that the final rule also formalizes

the use of the DOT Class 106A multiunit

tank car tank (which is actually referred to in the industry as the Model 30A cylinder).

However, both of the published

industry standards

-- ANSI N14.1-1987 and ORO-651, Rev. 5 -- have taken the position that the Model 30A cylinder is obsolete, and will be replaced by the Model 30B. In effect, therefore, DOE has stated that it will no longer fill Model 30A cylinders

at its gaseous diffusion facilities

after December 31, 1992.For any existing cylinder constructed

before the new rules, continued

use is authorized, provided that it was designed, inspected, tested, and marked in accordance

with the 1987, 1982 or 1971 version of ANSI N14.1, in effect at the time of construction;

or for cylinders

manufactured

before June 30, 1987,Section III, Div. I of the ASME Code.PROTECTIVE

OVERPACKS The net result of the rulemaking

in Docket HM-190 has been to upgrade the regulatory

requirements

for the fabrication, maintenance, and use of the DOT Specification

21PF-1 protective

overpacks.

The key dates for compliance

with these new rules are: April 1, 1989--Construction

of all new overpacks

must be in accordance

with DOT Specification

21PF-1B afte'rthis

date, and these overpacks

marked as such; and April 1, 1991--Refurbishment

and conversion

of all existing overpacks

to the requirements

of DOT Specification

21PF-1A must be accomplished

and these overpacks

marked as such.During the period between April 1, 1989 and April 1, 1991, therefore, the use of unmodified

DOT Specification

21PF-1 overpacks

continues

to be authorized.

However, both the owners of unmodified

overpacks

and the U.S. enrichment

plants which fill the cylinders

for subsequent

loading into the overpacks

are taking steps to perform quality control inspections

of the overpacks

to correct defi-ciencies, such as containing

excessive

water. (See Attachment

4). If such inspections

reveal excessive

water, measures are being taken to remove the overpack from service for drying, resealing, gasket replacement, or other necessary

refurbishment, or if necessary, for disposal.

The U.S. enrichment

plants are also requesting

the owners of unmodified

overpacks

to supply them with acceptance

certifications

stating that the quality control inspections

and other maintenance

procedures

have been accomplished.

IN 90-27 April 30, 1990 r NRC CERTIFICATES

OF COMPLIANCE

During the period of the Docket HM-190 rulemaking, several U.S. owners of pro-tective overpacks

for 30" cylinders

obtained certificates

of compliance

from the NRC to authorize

the use of overpacks

of improved design. These are sum-marized in Attachment

1. A comparison

of the specifics

of the DOT Specification

21PF-1A and 18 requirements

with these certificates

indicates

that there will islTTTremain

a need for the certificates, in that there are substantial

dif-Terences between, for example, the Model UX-30 (USA/9234/AF)

and the NCI-21-PF-1 JUSA/9196/AF)

and the DOT specifications.

Eli a eth Q. Eyck, Actng Director Di f-ion of Safeguards

and Transportation

Office of Nuclear Material Safety and Safeguards

Technical

Contact: A. W. Grella, NMSS (301) 492-3381 Attachments:

1. NRC Certificates

of Compliance

for UF 6 Overpacks 2. Chronology

of UF 6 Cylinder Rulemaking (HM-166V)3. Chronology

of UF Overpack Rulemaking (HM-190)4. "Interim Inspection

and Sealing Procedures

for DOT-21PF-1 Overpacks" 5. List of Recently Issued NMSS Information

Notices 6. List of Recently Issued NRC Information

Notices

Attachment

1 IN 90-27 April 30, 1990 U.S. NUCLEAR REGULATORY

COMMISSION (NRC)____. _@ _.__ .._ ..rFRTJFIEATIS

7FWCOMPLIANCE

ISUED FOR UF CTIVE OVERPACKS wSWl rw -vfw w , _w." _,.,.,_CERT #REV #8 MODEL #REGISTERED

USERS COMMENTS USA/4909/AF

GEr2l-PF-I

W-21.PF-1 General Electric Westinghouse

May be equivalent

t-S6pec 21-PF-1A or 1B.Authorized

gross weight: 8000 lbs.USA/9196/AF

2 UX-30 Nuclear Packaging U.S. Department

of Energy (DOE)Not equivalent

to Specs. 21-PF-1A or 1B: uses different

insu-lating media and has other physical features which differ. Author-ized gross weight: 8000 lbs.USA/9234/AF

0 NCI-21rPF-I

Nuclear Inc.Containers

Similar, but not equivalent

to Spec. 21-PF-1B;

auth.gross weight: 8700 lbs.AdvanceO Nuclear Fuels USA/6553/AF

3 Paducah Tiger DOE Overpack for model 48A and 48X 10-ton cylinders.

Authorized

gross weight: 37,500 lbs.

Attachment

2 IN 90-27 April 30 1990 CHRONOLOGY

OF UF 6 RULE-MAKING (DOCKET HM-166V)Date NUMBER MAJOR ACTIONS INVOLVED April 11, 1986 Nov. 18, 1986 Dec. 24, 1986 March 12, 1986 July 6, 1987 July 6, 1987 Notice 86-2 Amdts. 172-107 and 173-198 Andt. 173-198 Amdt. 173-199 Amdt. 173-198 Notice 87-7 Proposes adding specific requirements, as a new paragraph

173.420, for all UF cylinders, referencing

ANSI N14.1-1982 standards;

also would require UF to be in solid form; and would impose a volumetric.

fill limit of 61-percent

at 70 0 F; and would require Internal pressure to be less than 14.7 psia at 701F.Adopts the changes as proposed in Notice 86-2, and adds requirement

for cleaning of cylinders per App. A of ANSI N14.1-1982.

Eff. Date: January 1, 1987.Delays effective

required date for applicability

of ANSI standards

to new cylinders

to June 30, 1987 and references

additional

applicability

of above changes to previous editions of ANSI N14.1.Also provides notice of public meeting to be held on March 2, 1987 to discuss UF 6 rule-making.

Eff. Date: January 1, 1987.An emergency

final rule which amends Nov. 18, 1986 final rule by removing the requirement

for other than new cy fnders or those undergoing

periodic retesting

to be cleaned in accordance

with App. A of ANSI N14.1-1982.

Eff. Date: March 12, 1987.Revises final rule of Nov. 18 and Dec. 24, 1986, so as to reference

an alternative

to use cylinders

manufactured

to U.S. Department

of Transporation (DOT) Class 106A multiunit

tank car tanks. (Model 30A cylinders), in addition to those conforming

to ANSI N14.1-1982 (for cylinders manufactured

after May 30, 1987).Eff. Date: June 30, 1987.Proposes to authorize

the indefinite

continued use of cylinders

which were not made in accordance

with ANSI N14.1-1987 or DOT Class 106A tanks.

Attachment

2 IN 90-27 April 30, 1990 April 6, 1988 April 29, 1989 Notice 88-2 Amdts 171-103 and 173-214 Proposes to amend the earlier rule-making

to permit use of cylinders

manufactured

in accordance

with ANSI N14-1-1987;

and to permit loading of depleted UF6 to a fill limit of 62.percent

by volume rather than 61 percent at 70'F.Amends previous final rules by authorizing

continued

use of cylinders

manufactured

before June 30, 1987, in accordance

with Section VIII, Div. I of the ASME Code in effect at time of manufacture;

and also authorizes

a fill limit of 62 percent by volume for depleted UF at 201C.Eff. date: September

29, 1989.

Attachment

3 IN 90-27 April 30, 1990 CHRONOLOGY

OF UFg PROTECTIVE

OVERPACK RULEMAKING (HM-190)Date Aug. 16. 1984 Sept. 20, 1908 NUMBER Notice # 84-7 Amdts. 171-96, 173-206, and 178-90 ACTION INVOLVED Proposal to modify design of Spec. 21-PF-1 overpacks

to alleviate

problems resulting from water in-leakage, retention

and sub-sequent leaking out. Based on U.S. Depart-ment of Energy (DOE) petition.

Contained proposals

for required physical modifications

to existing overpacks

and requirements

for newly constructed

overpacks.

Major changes would be the use of stainless

rather than carbon steel and reversal of steps joints on shell closure interfaces.

Final rule based on earlier notice. Revisions essentially

as proposed.

Modified overpacks to be designated

as Spec. 21-PF-1A and newly constructed

overpacks

as Spec. 21-PF-1B.Eff. date: April 1, 1991 for required modITYTaTions

as Spec. 21-PF-1A;

and April 1, 1989, for new construction

as Spec. 21-PF-1B.

Attachment

4 IN 90-27 April 30, 1990 [This procedure

was sent by the U.S. Department

of Energy (DOE), Oak Ridge Operations

Office on January 18, 1990, to the owners of U.S. Department

of Transportation (DOT) Spec. 21PF-1 Overpacks.

It has currently

been implemented

by DOE enrichment

plants.This procedure

is quoted below.]"INTERIM INSPECTION

AND SEALING PROCEDURES

FOR DOT-21PF-1 OVERPACKS" 21PF- Overpack Conference

The U.S. Department

of Energy and Martin Marietta Energy Systems, Inc., hosted the first conference

on the DOT-21PF-1 Overpack at the DOE Gaseous Diffusion Plant in Piketon, Ohio on November 14-15, 1989. The conference

was attended by representatives

from the DOT, NRC, DOE, U.S. and non-U.S. industrial

firms. One of the primary concerns of conference

attendees

was the establishment

of criteria for acceptance

of overpacks

in the interium between now and the deadline (April 1991) for the full implementation

of the provisions

of 49CFR278.121.

Accordingly, a working group was formed to recommend

procedures

that could be adopted by industry prior to April 1991.The procedures

described

in this report were recommended

to the conference

at the end of the morning session.Introduction

It has been known for a long time that the foam insulation

in the 21PF-1 Overpack will pick up water due to its open cell structure, and that the water may subsequently

leak out of the foam through the vent holes in the outer shell. Although numerous studies have shown that the water does not adversely affect the thermal and impact protection

capabilities

of the foam, the public perceives

a leaking overpack as hazardous.

This public perception

is reason enough to take whatever steps are necessary

to preclude leaking overpacks.

49CFR178.121 requires that all existing overpacks

be dried and modified to meet the 21PF-1A standards

by April 1991.

Attachment

4 IN 90-27 April 30, 1990 The 21PF-1A standards

required that neither the top half nor the bottom half of the overpack contain more than 25 pounds of water. This amount of water will be absorbed by the foam and will not leak out even when the foam is subjected

to the compressive

loading imposed by a full UF cylinder.

The problem with this requirement

is that accurate initial taWe weights were not obtained when the existing overpacks

were manufactured, such that water pickup cannot be determined

by simply weighing the overpacks.

This will not be a problem in the future because the packages will be accurately

weighed when they are dried and modified, and the new dry tare weight will be engraved on the modified overpack's

stainless

steel nameplates.

Between now and April 1991, there is a need for some method for satisfactorily

determining

that no leaking overpack will be used in public transportation

without prematurely

implementing

49CFR178.121.

The following

procedures

were developed

by the working group and recommended

to the conference

as one workable answer to this problem.Procedure Prior to shipping an overpack to a USDOE enrichment

facility, the overpack will be prepared and inspected

as follows to ensure that water leakage will not be a problem when the overpack is loaded with a full UF 6 cylinder: 1. Drill out the four bottommost

vent holes in the overpack using a i" drill.2. Load the overpack with a full weight cylinder;

use either a loaded UF 6 cylinder or a dummy cylinder which is the same diameter and weight as a loaded UF 6 cylinder.3. Maintain the load test for a minimum of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> at temperatures

above freezing.4. Inspect for leakage while under load.5. If any leakage is found; remove the overpack from service to be dried and refurbished, or to be discarded.

6. If no leakage is found: (a) Use Silicone RTV Caulking to seal the metal/wood

interface

at the closure plane step joint.(b) Use Silicone RTV Caulking to seal the spaces between skip welds on all external reinforcements.(c) Reseal the bottom vent holes using i" plastic capplugs set in Silicone RTV Caulking.

Attachment

4 AN j90-2 g o pr 3 ,1990 (d) Inspect to ensure that the overpack is in sound condition

and the gaskets are acceptable

and in place.(e) Use matching paint to touch up old indications

of water leakage so that enrichment

facility inspectors

will not treat them as indica-tions of fresh new leaks.(f) Accompany

each overpack shipment with a certification

that the overpack has been inspected, sealed, and painted as described above and that the overpack is in sound condition

and free of water leaks when loaded.Enrichment

Facility Acceptance

The purpose of providing

overpacks

with the above described

certification

to the enrichment

facilities

is to provide the means for the overpack to be loaded and shipped from the enrichment

facility with no more than the routine inspection

for soundness

and for absence of water leakage. With such user provided certification

and with physical evidence that the overpacks

have been sealed as described

above and are not leaking, a DOE enrichment

facility would permit shipment of UF in such an overpack without accurate water weight data on the overpack.

Thi4 provision

will not apply to overpacks

which have been modified and certified

as meeting DOT-21PF-1A

specifications

and will not apply to any overpacks

after April 1991.

Attachment

5 IN 90-27 April 30, 1990 LIST OF RECENTLY ISSUED NMSS INFORMATION

NOTICES Information

Date of Notice No. Subject Issuance Issued to: 90-24 90-20 90-16 90-15 Transportation

of Model SPEC 2-T Radiographic

Exposure Device Personnel

Injuries Resulting

from Improper Operation

of Radwaste Incinerators

Compliance

with New Decommissioning

Rule Reciprocity:

Notification

of Agreement

State Radiation Control Directors

before Beginning

Work in Agreement States Accidental

Disposal of Radioactive

Materials Extended Interim Storage of Low-Level

Radioactive

Waste by Fuel Cycle and Materials Licensees Importance

of Proper Response to Self-Identified

Violations

by Licensees 04/10/90 03/22/90 03/07/90 03/07/90 03/06/90 02/05/90 01/12/90 All NRC licensees authorized

to use, transport, or operate radiographic

exposure devices and source changers.All U.S. NRC licensees who process or incinerate

radioactive

waste.All materials

licensees.

All holders of NRC materials

licenses that authorize

use of radio-active material at temporary

job sites.All NRC byproduct materials

licensees.

All holders of NRC materials

licenses.All holders of NRC materials

licenses.90-14 90-09 90-01**Correct Number for 90-01 should be 90010145.

Attachment

6 IN 90-27 April 30, 1990 LIST OF RECENTLY ISSUED NRC INFORMATION

NOTICES Information

Date of Notice No. Subject Issuance Issued to 89-70, Supp. 1 90-26 90-25 90-24 Possible Indications

of Misrepresented

Vendor Products Inadequate

Flow of Essential

Service Water to Room Coolers and Heat Exchangers

for Engineered

Safety-Feature

Systems Loss of Vital AC Power with Subsequent

Reactor Coolant System Heat-Up Transportation

of Model Spec 2-T Radiographic

Exposure Device Improper Installation

of Patel Conduit Seals Unanticipated

Equipment Actuations

Following Restoration

of Power to Rosemount

Transmitter

Trip Units Potential

Failure of Motor-Operated Butterfly

Valves to Operate Because Valve Seat Friction was Under-estimated Personnel

Injuries Resulting from Improper Operation

of Radwaste Incinerators

4/26/90 4/24/90 4/16/90 4/10/90 4/4/90 3/23/90 3/22/90 3/22/90 All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All NRC licensees authorized

to use, transport, or operate radiographic

exposure devices and source changers.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All NRC licensees who process or incinerate

radio-active waste.90-23 90-22 90-21 90-20 OL = Operating

License CP = Construction

Permit