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 STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR MATERIALS SAFETY AND SAFEGUARDSWASHINGTON, D.C. 20555April 30, 1990NRC INFORMATION NOTICE NO. 90-27: CLARIFICATION OF THE RECENT REVISIONS TO THEREGULATORY REQUIREMENTS FOR PACKAGING OFURANIUM 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 oftwo recent rulemaking actions which were completed by the U.S. Department ofTransportation (DOT), relating to the regulatory requirements for the packagingof UF for transportation. It is suggested that recipients review the infor-matiog here, and consider actions, if appropriate, to preclude possible problemsin the transport of UF .However, this information does not constitute new U.S.Nuclear Regulatory C;Amission (NRC) requirements, therefore no specific actionor 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) andas a fissile radioactive material (when containing 'greater than" 1.0 weightpercent U-235), constitutes a very significant volume of radioactive materialstransportation 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 thoseregulations. 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 eitherof the DOT Specifications 2OPF or 21PF Series as prescribed in 49 CFR 178.120and 178.121 of DOT regulations, or as authorized in several NRC Certificatesof 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 90-27April 30, 1990 Before November 1986, the DOT regulations were not specific on the standardsfor the cylinders, but rather, referenced the need to use a "strong tightpackage" for exclusive-use shipments. For non-exclusive-use shipments, thecylinders were required to meet the requirements for DOT Specification 7A,Type A packaging. [The cylinders actually used, however, were in accordancewith 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 regulation49 CFR 173.420) specifying cylinder standards and other requirements for allshipments of UF Several supplemental notices and amendments were subsequentlyissued in the Docket HM-166V, with the last revision of the final rule havingbeen issued on August 29, 1989.As for the protective overpacks for the cylinders, DOT originally issued itsregulatory specifications for the DOT Specifications 2OPF and 21PF series in1974. 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 collectand retain water within the phenolic foam insulating medium within the wallsof the overpack. Although the presence of this water is not an immediatesafety problem, the water does increase the gross weight of the packagessignificantly, and also accelerates corrosion of the metal and rotting ofthe wood components of the overpacks. It often tends to 'slosh' out fromthe drain holes, and sometimes creates considerable alarm to the public andto carriers, when water (albeit non-radioactive water) is observed to beleaking from a package marked "RADIOACTIVE" in commerce. Accordingly, DOEpetitioned DOT for rulemaking to amend the DOT 21PF series protective overpackspecification, so as to authorize the use of an improved design that wouldcorrect the deficiencies. A notice of proposed rulemaking was issued inAugust 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 receivedNRC certificates of compliance authorizing use of non-DOT specification,improved overpacks.Discussion:Attachments 2 and 3 are chronological summaries of the two recently completedDOT rulemaking dockets relating to UF packaging and transportation. Attach-ment 2 summarizes the Docket HM-166V 9n cylinder requirements, and Attachment 3summarizes the Docket HM-190 rule changes on the DOT Specification 21PF seriesof protective overpacks. Attachment 1 is a summary of the present status ofseveral NRC certificates of compliance for overpacks that are similar to theDOT Specification 21PF overpacks. Discussion of each of these areas follows:CYLINDERSThe net effect of the cylinder rulemaking imposed by the new 49 CFR 173.420 inDocket HM-166V has been to formalize, as regulatory requirements, the use ofcylinders which have already been in use for many years, pursuant to certainindustry standards, as well as other requirements (e.g., requirements for UF6 IN 90-27April 30, 1990 to be In solid fiorm and specified vl inetric fill liipits). .In carrying outte ru ema ng, owever, severa dY culties were Observed te.g., he methodof cleaning for other than new cylinders, provisions for use of existingcylinders, etc.), as evidenced by the series of eight notices and amendmentsbetween April 1986 and April 1989. It is noted that the final rule alsoformalizes the use of the DOT Class 106A multiunit tank car tank (which isactually 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 statedthat it will no longer fill Model 30A cylinders at its gaseous diffusionfacilities after December 31, 1992.For any existing cylinder constructed before the new rules, continued use isauthorized, provided that it was designed, inspected, tested, and marked inaccordance with the 1987, 1982 or 1971 version of ANSI N14.1, in effect atthe time of construction; or for cylinders manufactured before June 30, 1987,Section III, Div. I of the ASME Code.PROTECTIVE OVERPACKSThe net result of the rulemaking in Docket HM-190 has been to upgrade theregulatory requirements for the fabrication, maintenance, and use of the DOTSpecification 21PF-1 protective overpacks. The key dates for compliance withthese new rules are:April 1, 1989--Construction of all new overpacks must be in accordancewith DOT Specification 21PF-1B afte'rthis date, and these overpacks markedas such; andApril 1, 1991--Refurbishment and conversion of all existing overpacks tothe requirements of DOT Specification 21PF-1A must be accomplished andthese overpacks marked as such.During the period between April 1, 1989 and April 1, 1991, therefore, the useof unmodified DOT Specification 21PF-1 overpacks continues to be authorized.However, both the owners of unmodified overpacks and the U.S. enrichment plantswhich fill the cylinders for subsequent loading into the overpacks are takingsteps to perform quality control inspections of the overpacks to correct defi-ciencies, such as containing excessive water. (See Attachment 4). If suchinspections reveal excessive water, measures are being taken to remove theoverpack from service for drying, resealing, gasket replacement, or othernecessary refurbishment, or if necessary, for disposal. The U.S. enrichmentplants are also requesting the owners of unmodified overpacks to supply themwith acceptance certifications stating that the quality control inspectionsand other maintenance procedures have been accomplished.

IN 90-27April 30, 1990 r NRC CERTIFICATES OF COMPLIANCEDuring the period of the Docket HM-190 rulemaking, several U.S. owners of pro-tective overpacks for 30" cylinders obtained certificates of compliance fromthe 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 Specification21PF-1A and 18 requirements with these certificates indicates that there willislTTTremain 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-1JUSA/9196/AF) and the DOT specifications.Eli a eth Q. Eyck, Actng DirectorDi f-ion of Safeguardsand TransportationOffice of Nuclear Material Safetyand Safeguards

Technical Contact:

A. W. Grella, NMSS(301) 492-3381Attachments:1. NRC Certificates of Compliance for UF6 Overpacks2. 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 Notices6. List of Recently Issued NRC Information Notices

Attachment 1IN 90-27April 30, 1990 U.S. NUCLEAR REGULATORY COMMISSION (NRC)____. _@ _.__ .._ ..rFRTJFIEATIS7FWCOMPLIANCEISUED FOR UF CTIVE OVERPACKSwSWl rw -vfw w , _w." _,.,.,_CERT #REV #8MODEL #REGISTERED USERSCOMMENTSUSA/4909/AFGEr2l-PF-IW-21.PF-1General ElectricWestinghouseMay be equivalentt-S6pec 21-PF-1A or 1B.Authorized grossweight: 8000 lbs.USA/9196/AF2UX-30Nuclear PackagingU.S. Department ofEnergy (DOE)Not equivalent toSpecs. 21-PF-1A or1B: uses different insu-lating media and hasother physical featureswhich differ. Author-ized gross weight:8000 lbs.USA/9234/AF0NCI-21rPF-INuclearInc.ContainersSimilar, but notequivalent toSpec. 21-PF-1B; auth.gross weight: 8700 lbs.AdvanceO NuclearFuelsUSA/6553/AF3 Paducah TigerDOEOverpack for model 48Aand 48X 10-ton cylinders.Authorized grossweight: 37,500 lbs.

Attachment 2IN 90-27April 30 1990 CHRONOLOGY OF UF6RULE-MAKING (DOCKET HM-166V)DateNUMBERMAJOR ACTIONS INVOLVEDApril 11, 1986Nov. 18, 1986Dec. 24, 1986March 12, 1986July 6, 1987July 6, 1987Notice 86-2Amdts. 172-107and 173-198Andt. 173-198Amdt. 173-199Amdt. 173-198Notice 87-7Proposes adding specific requirements, as anew paragraph 173.420, for all UF cylinders,referencing ANSI N14.1-1982 standards; alsowould require UF to be in solid form; andwould impose a volumetric. fill limit of61-percent at 700F; and would require Internalpressure to be less than 14.7 psia at 701F.Adopts the changes as proposed in Notice 86-2,and adds requirement for cleaning of cylindersper App. A of ANSI N14.1-1982.Eff. Date: January 1, 1987.Delays effective required date for applicabilityof ANSI standards to new cylinders to June 30, 1987and references additional applicability of abovechanges to previous editions of ANSI N14.1.Also provides notice of public meeting to beheld on March 2, 1987 to discuss UF6 rule-making.Eff. Date: January 1, 1987.An emergency final rule which amends Nov. 18, 1986final rule by removing the requirement forother than new cy fnders or those undergoingperiodic retesting to be cleaned in accordancewith 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 usecylinders manufactured to U.S. Department ofTransporation (DOT) Class 106A multiunit tank cartanks. (Model 30A cylinders), in addition tothose conforming to ANSI N14.1-1982 (for cylindersmanufactured after May 30, 1987).Eff. Date: June 30, 1987.Proposes to authorize the indefinite continueduse of cylinders which were not made inaccordance with ANSI N14.1-1987 or DOTClass 106A tanks.

Attachment 2IN 90-27April 30, 1990 April 6, 1988April 29, 1989Notice 88-2Amdts 171-103and 173-214Proposes to amend the earlier rule-making topermit use of cylinders manufactured inaccordance with ANSI N14-1-1987; and to permitloading of depleted UF6 to a fill limit of62.percent by volume rather than 61 percentat 70'F.Amends previous final rules by authorizingcontinued use of cylinders manufacturedbefore June 30, 1987, in accordance withSection VIII, Div. I of the ASME Code ineffect at time of manufacture; and alsoauthorizes a fill limit of 62 percent byvolume for depleted UF at 201C.Eff. date: September 29, 1989.

Attachment 3IN 90-27April 30, 1990 CHRONOLOGY OF UFg PROTECTIVE OVERPACK RULEMAKING (HM-190)DateAug. 16. 1984Sept. 20, 1908NUMBERNotice # 84-7Amdts. 171-96,173-206, and178-90ACTION INVOLVEDProposal to modify design of Spec. 21-PF-1overpacks to alleviate problems resultingfrom water in-leakage, retention and sub-sequent leaking out. Based on U.S. Depart-ment of Energy (DOE) petition. Containedproposals for required physical modificationsto existing overpacks and requirements fornewly constructed overpacks. Major changeswould be the use of stainless rather thancarbon steel and reversal of steps joints onshell closure interfaces.Final rule based on earlier notice. Revisionsessentially as proposed. Modified overpacksto be designated as Spec. 21-PF-1A and newlyconstructed overpacks as Spec. 21-PF-1B.Eff. date: April 1, 1991 for requiredmodITYTaTions as Spec. 21-PF-1A; andApril 1, 1989, for new construction asSpec. 21-PF-1B.

Attachment 4IN 90-27April 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 ofU.S. Department of Transportation (DOT) Spec. 21PF-1 Overpacks. It hascurrently been implemented by DOE enrichment plants.This procedure is quoted below.]"INTERIM INSPECTION AND SEALINGPROCEDURES FOR DOT-21PF-1 OVERPACKS"21PF- Overpack ConferenceThe U.S. Department of Energy and Martin Marietta Energy Systems, Inc., hostedthe first conference on the DOT-21PF-1 Overpack at the DOE Gaseous DiffusionPlant in Piketon, Ohio on November 14-15, 1989. The conference was attendedby representatives from the DOT, NRC, DOE, U.S. and non-U.S. industrialfirms. One of the primary concerns of conference attendees was theestablishment of criteria for acceptance of overpacks in the interium betweennow and the deadline (April 1991) for the full implementation of theprovisions of 49CFR278.121. Accordingly, a working group was formed torecommend procedures that could be adopted by industry prior to April 1991.The procedures described in this report were recommended to the conference atthe end of the morning session.IntroductionIt has been known for a long time that the foam insulation in the 21PF-1Overpack will pick up water due to its open cell structure, and that the watermay subsequently leak out of the foam through the vent holes in the outershell. Although numerous studies have shown that the water does not adverselyaffect the thermal and impact protection capabilities of the foam, the publicperceives a leaking overpack as hazardous. This public perception is reasonenough to take whatever steps are necessary to preclude leaking overpacks.49CFR178.121 requires that all existing overpacks be dried and modified tomeet the 21PF-1A standards by April 1991.

Attachment 4IN 90-27April 30, 1990 The 21PF-1A standards required that neither the top half nor the bottom halfof the overpack contain more than 25 pounds of water. This amount of waterwill be absorbed by the foam and will not leak out even when the foam issubjected to the compressive loading imposed by a full UF cylinder. Theproblem with this requirement is that accurate initial taWe weights were notobtained when the existing overpacks were manufactured, such that water pickupcannot be determined by simply weighing the overpacks. This will not be aproblem in the future because the packages will be accurately weighed whenthey are dried and modified, and the new dry tare weight will be engraved onthe modified overpack's stainless steel nameplates.Between now and April 1991, there is a need for some method for satisfactorilydetermining that no leaking overpack will be used in public transportationwithout prematurely implementing 49CFR178.121. The following procedures weredeveloped by the working group and recommended to the conference as oneworkable answer to this problem.ProcedurePrior to shipping an overpack to a USDOE enrichment facility, the overpackwill be prepared and inspected as follows to ensure that water leakage willnot 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 UF6cylinder or a dummy cylinder which is the same diameter and weight as aloaded 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 abovefreezing.4. Inspect for leakage while under load.5. If any leakage is found; remove the overpack from service to be dried andrefurbished, or to be discarded.6. If no leakage is found:(a) Use Silicone RTV Caulking to seal the metal/wood interface at theclosure plane step joint.(b) Use Silicone RTV Caulking to seal the spaces between skip welds onall external reinforcements.(c) Reseal the bottom vent holes using i" plastic capplugs set inSilicone RTV Caulking.

Attachment 4AN j90-2 g opr 3 ,1990 (d) Inspect to ensure that the overpack is in sound condition and thegaskets are acceptable and in place.(e) Use matching paint to touch up old indications of water leakage sothat enrichment facility inspectors will not treat them as indica-tions of fresh new leaks.(f) Accompany each overpack shipment with a certification that theoverpack has been inspected, sealed, and painted as describedabove and that the overpack is in sound condition and free ofwater leaks when loaded.Enrichment Facility AcceptanceThe purpose of providing overpacks with the above described certificationto the enrichment facilities is to provide the means for the overpack to beloaded and shipped from the enrichment facility with no more than the routineinspection for soundness and for absence of water leakage. With such userprovided certification and with physical evidence that the overpacks have beensealed as described above and are not leaking, a DOE enrichment facility wouldpermit shipment of UF in such an overpack without accurate water weight dataon the overpack. Thi4 provision will not apply to overpacks which have beenmodified and certified as meeting DOT-21PF-1A specifications and will notapply to any overpacks after April 1991.

Attachment 5IN 90-27April 30, 1990 LIST OF RECENTLY ISSUEDNMSS INFORMATION NOTICESInformation Date ofNotice No. Subject Issuance Issued to:90-2490-2090-1690-15Transportation of ModelSPEC 2-T RadiographicExposure DevicePersonnel InjuriesResulting from ImproperOperation of RadwasteIncineratorsCompliance with NewDecommissioning RuleReciprocity: Notificationof Agreement State RadiationControl Directors beforeBeginning Work in AgreementStatesAccidental Disposal ofRadioactive MaterialsExtended Interim Storage ofLow-Level Radioactive Wasteby Fuel Cycle and MaterialsLicenseesImportance of ProperResponse to Self-IdentifiedViolations by Licensees04/10/9003/22/9003/07/9003/07/9003/06/9002/05/9001/12/90All NRC licenseesauthorized to use,transport, or operateradiographic exposuredevices and sourcechangers.All U.S. NRC licenseeswho process or incinerateradioactive waste.All materials licensees.All holders of NRCmaterials licenses thatauthorize use of radio-active material attemporary job sites.All NRC byproductmaterials licensees.All holders of NRCmaterials licenses.All holders of NRCmaterials licenses.90-1490-0990-01**Correct Number for 90-01 should be 90010145.

Attachment 6IN 90-27April 30, 1990 LIST OF RECENTLY ISSUEDNRC INFORMATION NOTICESInformation Date ofNotice No. Subject Issuance Issued to89-70,Supp. 190-2690-2590-24Possible Indications ofMisrepresented VendorProductsInadequate Flow ofEssential Service Waterto Room Coolers and HeatExchangers for EngineeredSafety-Feature SystemsLoss of Vital AC Powerwith Subsequent ReactorCoolant System Heat-UpTransportation of ModelSpec 2-T RadiographicExposure DeviceImproper Installation ofPatel Conduit SealsUnanticipated EquipmentActuations FollowingRestoration of Powerto Rosemount TransmitterTrip UnitsPotential Failure of Motor-Operated Butterfly Valvesto Operate Because ValveSeat Friction was Under-estimatedPersonnel Injuries Resultingfrom Improper Operation ofRadwaste Incinerators4/26/904/24/904/16/904/10/904/4/903/23/903/22/903/22/90All holders of OLsor CPs for nuclearpower reactors.All holders of OLsor CPs for nuclearpower reactors.All holders of OLsor CPs for nuclearpower reactors.All NRC licenseesauthorized to use,transport, or operateradiographic exposuredevices and sourcechangers.All holders of OLsor CPs for nuclearpower reactors.All holders of OLsor CPs for nuclearpower reactors.All holders of OLsor CPs for nuclearpower reactors.All NRC licenseeswho process orincinerate radio-active waste.90-2390-2290-2190-20OL = Operating LicenseCP = Construction Permit