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 Office of Nuclear Material Safety and Safeguards
To:
References
IN-90-027, NUDOCS 9004240313
Download: ML031210564 (13)

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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 (UF6 ) 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 UF6

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. Itis 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. Ineffect, therefore, DOE has stated

that itwill 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 itwas designed, inspected, tested, and marked in

accordance with the 1987, 1982 or 1971 version of ANSI N14.1, ineffect 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

tective overpacks for 30" cylinders obtained certificates of compliance of pro- the NRC to authorize the use of overpacks of improved design. These from

marized in Attachment 1. A comparison of the specifics of the DOT are sum- Specification

21PF-1A and 18 requirements with these certificates indicates that there

islTTTremain a need for the certificates, in that there are substantial will

Terences between, for example, the Model UX-30 (USA/9234/AF) and the dif- JUSA/9196/AF) and the DOT specifications. NCI-21-PF-1 Eli a eth Q. Eyck, Actng Director

Di f-ion of Safeguards

and Transportation

Office of Nuclear Material Safety

and Safeguards

A. W. Grella, NMSS

(301) 492-3381 Attachments:

1. NRC Certificates of Compliance for UF6 Overpacks

2. Chronology of UF6 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

wSWl rw -vfw w

7FWCOMPLIANCE ISUED FOR UF

, _w." _,.,.,_

CTIVE OVERPACKS

CERT # REV # MODEL # REGISTERED USERS COMMENTS

USA/4909/AF 8 GEr2l-PF-I General Electric May be equivalent

W-21.PF-1 Westinghouse t-S6pec 21-PF-1A or 1B.

Authorized gross

weight: 8000 lbs.

USA/9196/AF 2 UX-30 Nuclear Packaging Not equivalent to

U.S. Department of Specs. 21-PF-1A or

Energy (DOE) 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 Containers Similar, but not

Inc. equivalent to

Spec. 21-PF-1B; auth.

AdvanceO Nuclear gross weight: 8700 lbs.

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 UF6 RULE-MAKING (DOCKET HM-166V)

Date NUMBER MAJOR ACTIONS INVOLVED

April 11, 1986 Notice 86-2 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 700F; and would require Internal

pressure to be less than 14.7 psia at 701F.

Nov. 18, 1986 Amdts. 172-107 Adopts the changes as proposed in Notice 86-2, and 173-198 and adds requirement for cleaning of cylinders

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

Eff. Date: January 1, 1987.

Dec. 24, 1986 Andt. 173-198 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 UF6 rule-making.

Eff. Date: January 1, 1987.

March 12, 1986 Amdt. 173-199 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.

July 6, 1987 Amdt. 173-198 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.

July 6, 1987 Notice 87-7 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 Notice 88-2 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.

April 29, 1989 Amdts 171-103 Amends previous final rules by authorizing

and 173-214 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 NUMBER ACTION INVOLVED

Aug. 16. 1984 Notice # 84-7 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.

Sept. 20, 1908 Amdts. 171-96, Final rule based on earlier notice. Revisions

173-206, and essentially as proposed. Modified overpacks

178-90 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 UF6 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 UF6 cylinder or a dummy cylinder which is the same diameter and weight as a

loaded UF6 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 Transportation of Model 04/10/90 All NRC licensees

SPEC 2-T Radiographic authorized to use, Exposure Device transport, or operate

radiographic exposure

devices and source

changers.

90-20 Personnel Injuries 03/22/90 All U.S. NRC licensees

Resulting from Improper who process or incinerate

Operation of Radwaste radioactive waste.

Incinerators

90-16 Compliance with New 03/07/90 All materials licensees.

Decommissioning Rule

90-15 Reciprocity: Notification 03/07/90 All holders of NRC

of Agreement State Radiation materials licenses that

Control Directors before authorize use of radio- Beginning Work in Agreement active material at

States temporary job sites.

90-14 Accidental Disposal of 03/06/90 All NRC byproduct

Radioactive Materials materials licensees.

90-09 Extended Interim Storage of 02/05/90 All holders of NRC

Low-Level Radioactive Waste materials licenses.

by Fuel Cycle and Materials

Licensees

90-01* Importance of Proper 01/12/90 All holders of NRC

Response to Self-Identified materials licenses.

Violations by Licensees

• 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, Possible Indications of 4/26/90 All holders of OLs

Supp. 1 Misrepresented Vendor or CPs for nuclear

Products power reactors.

90-26 Inadequate Flow of 4/24/90 All holders of OLs

Essential Service Water or CPs for nuclear

to Room Coolers and Heat power reactors.

Exchangers for Engineered

Safety-Feature Systems

90-25 Loss of Vital AC Power 4/16/90 All holders of OLs

with Subsequent Reactor or CPs for nuclear

Coolant System Heat-Up power reactors.

90-24 Transportation of Model 4/10/90 All NRC licensees

Spec 2-T Radiographic authorized to use, Exposure Device transport, or operate

radiographic exposure

devices and source

changers.

90-23 Improper Installation of 4/4/90 All holders of OLs

Patel Conduit Seals or CPs for nuclear

power reactors.

90-22 Unanticipated Equipment 3/23/90 All holders of OLs

Actuations Following or CPs for nuclear

Restoration of Power power reactors.

to Rosemount Transmitter

Trip Units

90-21 Potential Failure of Motor- 3/22/90 All holders of OLs

Operated Butterfly Valves or CPs for nuclear

to Operate Because Valve power reactors.

Seat Friction was Under- estimated

90-20 Personnel Injuries Resulting 3/22/90 All NRC licensees

from Improper Operation of who process or

Radwaste Incinerators incinerate radio- active waste.

OL = Operating License

CP = Construction Permit