ML103610022

Enclosure 3: Presentation Materials (D. Weaver Memo Summary of December 9, 2010, Meeting with the Department of Energy and Washington Tru Solutions)

ML103610022
Person / Time
Site:	07109212
Issue date:	12/23/2010
From:	US Dept of Energy (DOE), Washington TRU Solutions
To:	Office of Nuclear Material Safety and Safeguards
Staab C, NMSS/SFST 301-492-3321
Shared Package
ML103610019	List: ML103610021 ML103610022
References
TAC L24419
Download: ML103610022 (34)

Text

RH RH-TRU 72 TRU 72--B Packaging B Packaging RH RH--TRU 72 TRU 72--B SAR Revision 5 Amendment B SAR Revision 5 Amendment Request for Supplemental Information dated November 4, 2010 Request for Supplemental Information dated November 4, 2010 Presented to the US Nuclear Regulatory Commission Presented to the US Nuclear Regulatory Commission by Washington TRU Solutions on behalf of the US Department of Energy by Washington TRU Solutions on behalf of the US Department of Energy December 9, 2010 December 9, 2010

RH RH--TRU 72 TRU 72--BB Description Description Overall Length = 187 Overall Length = 187--%, Impact Limiter Diameter = 76, Cask Length = 141

, Impact Limiter Diameter = 76, Cask Length = 141--%,,

Outer Cask OD = 41 Outer Cask OD = 41--., Inner Vessel Length = 130, Inner Vessel OD = 32,

, Inner Vessel Length = 130, Inner Vessel OD = 32, Cask Lead Thickness = 1 Cask Lead Thickness = 1--/, Max. Package Weight = 45,000 lb, Max. Contents

, Max. Package Weight = 45,000 lb, Max. Contents Weight = 8,000 lb Weight = 8,000 lb 2

RH RH--TRU 72 TRU 72--B Gamma Shielding B Gamma Shielding Lead 3

Neutron Shielded Canisters Neutron Shielded Canisters NS15 & NS30 NS15 & NS30 (shown)

(shown) 4

Thermal RSI Thermal RSI--11 Update the NS15 and NS30 thermal analyses presented in the Safety Analysis Report Update the NS15 and NS30 thermal analyses presented in the Safety Analysis Report (SAR) to reflect the recently provided NCT and HAC thermal analyses.

(SAR) to reflect the recently provided NCT and HAC thermal analyses.

The response from the Request for Additional Information (RAI) teleconference The response from the Request for Additional Information (RAI) teleconference (9/27/10) provided three shielded NS15/NS30 thermal analyses that do not use bulk (9/27/10) provided three shielded NS15/NS30 thermal analyses that do not use bulk spatial and temporal spatial and temporal--averaged insolation boundary conditions. As a result of the averaged insolation boundary conditions. As a result of the analyses, the applicant mentions that the RH analyses, the applicant mentions that the RH--TRU 72 TRU 72--B SAR design decay heat limit will B SAR design decay heat limit will be changed from 300 W to 50 W per canister In addition the new modeling be changed from 300 W to 50 W per canister In addition the new modeling be changed from 300 W to 50 W per canister. In addition, the new modeling be changed from 300 W to 50 W per canister. In addition, the new modeling methodology and the higher temperatures of the components found as a result of the methodology and the higher temperatures of the components found as a result of the updated NS15 and NS30 analyses should be incorporated in the appropriate sections of updated NS15 and NS30 analyses should be incorporated in the appropriate sections of the SAR, such as Appendix 5.1 of the RH the SAR, such as Appendix 5.1 of the RH--TRU Payload Appendices.

TRU Payload Appendices.

This information is requested by staff to determine compliance with 10 CFR 71.71 and This information is requested by staff to determine compliance with 10 CFR 71.71 and 71.73.

71.73.

5

Thermal Sensitivity Analysis Thermal Sensitivity Analysis Performed 2 Performed 2--D transient thermal with 400 W/m D transient thermal with 400 W/m2 insolation to insolation to all exposed external surfaces (NS15 Sensitivity A) to compare all exposed external surfaces (NS15 Sensitivity A) to compare with SAR 2 with SAR 2--D steady D steady--state with 127 W/m state with 127 W/m2 (Current SAR)

(Current SAR)

- all component temperatures remain well within the NCT allowable all component temperatures remain well within the NCT allowable temperature limits temperature limits

- even with solar loads applied, the maximum external surface even with solar loads applied, the maximum external surface temperatures remain within the regulatory limits for exclusive temperatures remain within the regulatory limits for exclusive-use use temperatures remain within the regulatory limits for exclusive temperatures remain within the regulatory limits for exclusive-use use shipments shipments

- the NS15 shield insert maximum temperature remains less than its the NS15 shield insert maximum temperature remains less than its 150 150 °F design basis F design basis

- all sensitivity analysis temperatures are below the current SAR 300 all sensitivity analysis temperatures are below the current SAR 300--

watt metallic waste case temperatures that are utilized to establish watt metallic waste case temperatures that are utilized to establish the bounding values for all hot temperature structural component the bounding values for all hot temperature structural component evaluations evaluations

- hot foam structural evaluations are performed using a bulk average hot foam structural evaluations are performed using a bulk average foam temperature of 140 foam temperature of 140 °F, which remains above the bulk average F, which remains above the bulk average foam temperature of 133 foam temperature of 133 °F established by the sensitivity analysis F established by the sensitivity analysis 6

Thermal Sensitivity Analysis (cont.)

Thermal Sensitivity Analysis (cont.)

Maximum Temperature (ºF)

NS15 (50W)*

NS30 (50W) 50W 300W Allowable Location/Component Sensitivity A Current SAR Current SAR Current SAR Current SAR Waste Centerline 250 247 234 217 181 302 NS_ _ Shield Insert 149 (142 Avg.)

141 137 N/A N/A 256 Canister Shell 142 133 132 132 167 2,600 IV Shell 140 128 128 127 150 800 IV Void Space Bulk Avg 140 127 127 N/A OC Inner Shell 140 126 126 126 143 800 OC Lead Shield 140 126 126 126 143 620 OC Outer Shell 140 126 126 126 143 800 OC Thermal Shield 145 125 125 125 142 185 OC Upper Ring Forging 134 125 125 126 137 800 IV O-Ring Seal 134 125 126 126 140 225 OC O-Ring Seal 133 125 125 126 137 225 IV Lid 134 125 126 127 141 800 OC Lid 134 125 125 126 137 800 Impact Limiter Foam 150 (133 Avg.)

132 (127 Avg.)

132 (127 Avg.)

132 143 300 Impact Limiter Shell 158 133 133 133 142 185 7

• The NS15 case was chosen since it has the highest waste centerline, shield insert (as applicable), and canister shell temperatures for all 50-watt cases with all other packaging component temperatures within 2 °F of the current NS15 SAR analysis.

Proposed Thermal RSI Proposed Thermal RSI--1 Resolution 1 Resolution Option 1 (preferred)

Option 1 (preferred) -- Rely on RSI response that documents Rely on RSI response that documents the sensitivity analysis to demonstrate that the current SAR the sensitivity analysis to demonstrate that the current SAR analyses are adequate to ensure safety because all limits are analyses are adequate to ensure safety because all limits are met even with the application of 400 W/m met even with the application of 400 W/m2 insolation insolation boundary conditions to all exposed external surfaces boundary conditions to all exposed external surfaces

- All shipments to date << 50 watts (1 @ 13.83 W, 93% < 1 W)

All shipments to date << 50 watts (1 @ 13.83 W, 93% < 1 W)

Shi t

d th 300 Shi t

d th 300 tt t

b di ll d i th RH tt t

b di ll d i th RH

- Shipments under the 300 Shipments under the 300-watt case to be disallowed in the RH watt case to be disallowed in the RH-TRAMPAC to ensure sensitivity results are bounded by existing 300 TRAMPAC to ensure sensitivity results are bounded by existing 300--

watt analysis watt analysis

- SAR Chapter 3 revised under timely renewal process to formally SAR Chapter 3 revised under timely renewal process to formally incorporate currently accepted practice incorporate currently accepted practice Option 2 Option 2 -- Revise SAR Chapter 3 to formalize a currently Revise SAR Chapter 3 to formalize a currently accepted application of insolation boundary conditions accepted application of insolation boundary conditions

- Propose consistency with IAEA guidance to apply a more reasonable Propose consistency with IAEA guidance to apply a more reasonable insolation boundary condition of 400 W/m insolation boundary condition of 400 W/m2 on upward facing curved on upward facing curved surfaces and 200 W/m surfaces and 200 W/m2 on downward facing curved surfaces on downward facing curved surfaces 8

Shielding RSI Shielding RSI--11 Provide an analysis of the effect of lead slump on the HAC dose rates.

Provide an analysis of the effect of lead slump on the HAC dose rates.

The applicant provided some discussion in response to the shielding RAI #1 on this The applicant provided some discussion in response to the shielding RAI #1 on this subject, indicating that slumping will not occur. However, staff does not find the basis for subject, indicating that slumping will not occur. However, staff does not find the basis for this conclusion to be applicable. Thus, a shielding analysis should be provided for lead this conclusion to be applicable. Thus, a shielding analysis should be provided for lead slump, as predicted using the method in the Cask Designers Guide document. The slump, as predicted using the method in the Cask Designers Guide document. The analysis should also account for any void between the top of the lead shielding and the analysis should also account for any void between the top of the lead shielding and the outer cask top flange resulting from package fabrication The analysis should account for outer cask top flange resulting from package fabrication The analysis should account for outer cask top flange resulting from package fabrication. The analysis should account for outer cask top flange resulting from package fabrication. The analysis should account for the assumed 2% of the source escaping the canisters neutron shield insert and lodging the assumed 2% of the source escaping the canisters neutron shield insert and lodging as close to the slump area as allowed by the package HAC configuration. The remainder as close to the slump area as allowed by the package HAC configuration. The remainder of the source should likewise be positioned as near as possible to the slump zone while of the source should likewise be positioned as near as possible to the slump zone while remaining within the canisters neutron shield insert. Using analyses for a few remaining within the canisters neutron shield insert. Using analyses for a few radionuclide contents (e.g., Co radionuclide contents (e.g., Co--60), the applicant may demonstrate that the dose rates 60), the applicant may demonstrate that the dose rates for the puncture HAC configuration bound those for the lead slump configuration.

for the puncture HAC configuration bound those for the lead slump configuration.

This information is needed to confirm compliance with 10 CFR 71.51 and 71.73.

This information is needed to confirm compliance with 10 CFR 71.51 and 71.73.

9

Lead Slump by Analysis Lead Slump by Analysis Cask Designers Guide Equation 2.16 Cask Designers Guide Equation 2.16

- H = RWH/[

H = RWH/[(R (R2-rr2)(t

)(tSS+R

+RPb Pb)])]

- Utilizes concept of flow stress Utilizes concept of flow stress Pb Pb=5,000 to 10,000 psi

=5,000 to 10,000 psi E

ti i

l bl E

ti i

l bl

- Equation is scalable Equation is scalable

- Specifically applies to bare, unbuffered cask Specifically applies to bare, unbuffered cask geometries where the flow stress of lead is geometries where the flow stress of lead is exceeded exceeded

- Should not have been applied to 72 Should not have been applied to 72--B which is B which is buffered by relatively soft energy absorbing buffered by relatively soft energy absorbing impact limiters where the flow stress is not impact limiters where the flow stress is not exceeded exceeded 10

Lead Slump by Test Lead Slump by Test Avoids undue conservatism of Cask Designers Avoids undue conservatism of Cask Designers Guide formula when addressing buffered casks Guide formula when addressing buffered casks such as 72 such as 72--B and 125 B and 125--BB Scale testing considered to be an acceptable Scale testing considered to be an acceptable b

i b

i basis basis

- Designers Guide formula scales Designers Guide formula scales

- Other references also defend scaling for lead Other references also defend scaling for lead response response Valid testing does require use of prototypic Valid testing does require use of prototypic manufacturing and lead installation techniques manufacturing and lead installation techniques 11

72 72--B Lead Slump B Lead Slump Results obtained from 1/4 Results obtained from 1/4--scale testing of highly scale testing of highly similar 125 similar 125--B are applicable and justifiable B are applicable and justifiable

- 1/4-Scale 125 Scale 125--B very closely simulates 3/8 B very closely simulates 3/8--scale 72 scale 72--BB Physical Parameter of Importance to Lead Slump Full-Size 72-B 38.5%-

Scale 72-B 1/4-Scale 125-B Outer Cask Outer Shell Thickness, in 1.500 0.578 0.500

+15.6%

- 125 125--B and 72 B and 72--B manufacturing and lead installation B manufacturing and lead installation techniques and controls are the same techniques and controls are the same Post Post--test radiographic inspection of the 1/4 test radiographic inspection of the 1/4--scale scale 125 125--B concluded no measurable lead slump B concluded no measurable lead slump Outer Cask Inner Shell Thickness, in 1.000 0.385 0.250

+54.0%

Outer Cask Lead Thickness, in 1.875 0.722 0.969

-25.5%

Outer Cask Lead Column Height, in 124.250 47.836 44.750

+6.9%

12

Lead Installation Process Lead Installation Process Lead installation set Lead installation set--up, preheat, pouring and up, preheat, pouring and cooldown procedures are carefully prescribed cooldown procedures are carefully prescribed and controlled (SAR Section 8.3.1) and controlled (SAR Section 8.3.1)

- Package is inverted for lead fill with open end of outer Package is inverted for lead fill with open end of outer cask facing down cask facing down

- Lead is introduced at lower end Lead is introduced at lower end

- Package is cooled from lower end up Package is cooled from lower end up

- Additional molten lead is added at upper end as lower Additional molten lead is added at upper end as lower end lead solidifies and shrinks end lead solidifies and shrinks

- Result is complete fill of lead cavity and minimal axial Result is complete fill of lead cavity and minimal axial gaps at either end of the lead column following gaps at either end of the lead column following cooldown cooldown 13

Gamma Scan Acceptance Gamma Scan Acceptance To confirm a void free lead fill and the absence To confirm a void free lead fill and the absence of any significant gaps/shine paths at the ends of any significant gaps/shine paths at the ends of the lead column, gamma scan acceptance of the lead column, gamma scan acceptance testing is required (SAR Section 8.1.5) testing is required (SAR Section 8.1.5)

Starting at bottom inside of outer cask an iridium Starting at bottom inside of outer cask an iridium

- Starting at bottom inside of outer cask, an iridium Starting at bottom inside of outer cask, an iridium-192 or cobalt 192 or cobalt--60 source is raised in increments, while 60 source is raised in increments, while measuring and recording dose rates on the entire measuring and recording dose rates on the entire exterior surface of the package exterior surface of the package All twelve 72 All twelve 72--Bs fabricated to date and now in Bs fabricated to date and now in service have successfully passed required service have successfully passed required gamma scans gamma scans 14

Lead Slump Position Summary Lead Slump Position Summary The following are technically appropriate and The following are technically appropriate and utilized by multiple NRC utilized by multiple NRC--certified Type B certified Type B packages, including the currently certified RH packages, including the currently certified RH--

TRU 72 TRU 72--B:

B:

- Dependence upon scale drop testing to ascertain lead slump Dependence upon scale drop testing to ascertain lead slump

- Controlled lead installation and post Controlled lead installation and post--pour gamma scan pour gamma scan inspection to ensure shield integrity inspection to ensure shield integrity Fabrication and/or slump induced gaps at the Fabrication and/or slump induced gaps at the ends of the 72 ends of the 72--B lead column are negligible and B lead column are negligible and HAC activity limits are adequately and properly HAC activity limits are adequately and properly established by considering only the side established by considering only the side puncture location puncture location 15

Proposed Shielding RSI Proposed Shielding RSI--1 Resolution 1 Resolution Option 1 (preferred)

Option 1 (preferred) -- Rely on RSI response that Rely on RSI response that provides additional detail regarding the basis and provides additional detail regarding the basis and justification for use of the 125 justification for use of the 125--B 1/4 B 1/4--scale drop testing, scale drop testing, lead installation procedure, and post lead installation procedure, and post--pour gamma scan pour gamma scan to ensure that lead gaps are negligible to ensure that lead gaps are negligible

- SAR Chapter 2 revised under timely renewal process to formally SAR Chapter 2 revised under timely renewal process to formally remove Cask Designers Guide based lead slump calculations and remove Cask Designers Guide based lead slump calculations and incorporate detailed 125 incorporate detailed 125--B 1/4 B 1/4--scale test data and correlations scale test data and correlations Option 2 Option 2 -- Revise SAR Chapter 2 to formalize the 125 Revise SAR Chapter 2 to formalize the 125--B B

1/4-scale drop test data and correlations scale drop test data and correlations 16

Shielding RSI Shielding RSI--22 Provide sufficient detail regarding the pre Provide sufficient detail regarding the pre--shipment dose rate measurements and results shipment dose rate measurements and results of previous measurements to demonstrate the acceptability of this method, for the of previous measurements to demonstrate the acceptability of this method, for the current amendment only, for use to meet the requirements of 10 CFR 71.35(a) and current amendment only, for use to meet the requirements of 10 CFR 71.35(a) and 71.47.

71.47.

Per 10 CFR 71.35(a), an application for a Part 71 Certificate of Compliance (CoC) must Per 10 CFR 71.35(a), an application for a Part 71 Certificate of Compliance (CoC) must include a demonstration that the package containing the proposed contents at the include a demonstration that the package containing the proposed contents at the proposed quantity limits satisfies among other things the requirements in 10 CFR 71 47 proposed quantity limits satisfies among other things the requirements in 10 CFR 71 47 proposed quantity limits satisfies, among other things, the requirements in 10 CFR 71.47.

proposed quantity limits satisfies, among other things, the requirements in 10 CFR 71.47.

The current amendment application seeks to use pre The current amendment application seeks to use pre--shipment dose rate measurements shipment dose rate measurements to meet this requirement. While pre to meet this requirement. While pre--shipment measurements are normally not accepted shipment measurements are normally not accepted as fulfilling this requirement, they may be found acceptable in the current case for only as fulfilling this requirement, they may be found acceptable in the current case for only the current amendment only with certain additional conditions and the provision of the current amendment only with certain additional conditions and the provision of further information to justify that the packages compliance with 10 CFR 71.47 will be further information to justify that the packages compliance with 10 CFR 71.47 will be ensured for the proposed contents at the proposed quantities. Package operations ensured for the proposed contents at the proposed quantities. Package operations descriptions in Chapter 7, Package Operations, of the SAR should also be modified to descriptions in Chapter 7, Package Operations, of the SAR should also be modified to incorporate (by reference is acceptable) these conditions.

incorporate (by reference is acceptable) these conditions.

17

Shielding RSI Shielding RSI--2 (cont.)

2 (cont.)

The applicant has provided some information regarding performance of pre The applicant has provided some information regarding performance of pre--shipment shipment measurements; however, this information does not completely satisfy the RAI. In measurements; however, this information does not completely satisfy the RAI. In addition to the measurement descriptions currently provided by the applicant, addition to the measurement descriptions currently provided by the applicant, descriptions should be included that explicitly state that the neutron and gamma dose descriptions should be included that explicitly state that the neutron and gamma dose rate measurements are performed on the package surface and at 2 meters from the rate measurements are performed on the package surface and at 2 meters from the package surface. This ensures clarity as to which surfaces are being referenced. A package surface. This ensures clarity as to which surfaces are being referenced. A statement should be added that clearly states that both gamma and neutron dose rate statement should be added that clearly states that both gamma and neutron dose rate measurements are always performed and that they are done with appropriate measurements are always performed and that they are done with appropriate y p y

pp p

y p y

pp p

instruments of appropriate/adequate dose rate ranges. The descriptions should also instruments of appropriate/adequate dose rate ranges. The descriptions should also include that a grid is established for the entire package surface with squares no larger include that a grid is established for the entire package surface with squares no larger than a few inches (4 inches for example) on a side, with measurements taken at every than a few inches (4 inches for example) on a side, with measurements taken at every grid location. Similarly, a description of how the 2 grid location. Similarly, a description of how the 2--meter dose rate measurements meter dose rate measurements are/will be comprehensive is also needed.

are/will be comprehensive is also needed.

To justify the use of measurements in this case, the applicant should provide the results To justify the use of measurements in this case, the applicant should provide the results of representative cases from the measurements performed on previous shipments under of representative cases from the measurements performed on previous shipments under the current CoC. The information should demonstrate the comprehensive nature of the the current CoC. The information should demonstrate the comprehensive nature of the measurements.

measurements.

18

Shielding RSI Shielding RSI--2 (cont.)

2 (cont.)

The applicant should provide the maximum measured surface and 2 The applicant should provide the maximum measured surface and 2--meter dose rates for meter dose rates for the package radial side and axial end surfaces, the contents descriptions (including Curie the package radial side and axial end surfaces, the contents descriptions (including Curie quantity(ies) and the form of the contents) for each result case included in the quantity(ies) and the form of the contents) for each result case included in the information. Results should be provided that cover the range of contents forms that are information. Results should be provided that cover the range of contents forms that are (to be) shipped in the RH (to be) shipped in the RH--TRU 72 TRU 72--B package. Also, if the cases are not for the maximum B package. Also, if the cases are not for the maximum allowed Curie quantity(ies) of the radionuclides present in the given cases, the applicant allowed Curie quantity(ies) of the radionuclides present in the given cases, the applicant should also provide an evaluation of the dose rates for a package containing the should also provide an evaluation of the dose rates for a package containing the maximum allowed quantities. A conservative approach to this task would be to take the maximum allowed quantities. A conservative approach to this task would be to take the q

pp q

pp highest dose rate contributor (both for gamma sources and neutron sources) present in highest dose rate contributor (both for gamma sources and neutron sources) present in the particular case and scale up its quantity to the maximum allowed by the CoC. Then, the particular case and scale up its quantity to the maximum allowed by the CoC. Then, because the NS15 and NS30 differ from the current waste canisters, justification should because the NS15 and NS30 differ from the current waste canisters, justification should be provided as to why the supplied results are sufficient to demonstrate that the higher be provided as to why the supplied results are sufficient to demonstrate that the higher quantities in the NS15 and NS30 canisters will meet 71.47 limits. The justification should quantities in the NS15 and NS30 canisters will meet 71.47 limits. The justification should be quantitative as well as qualitative, noting effects of geometry and shielding differences be quantitative as well as qualitative, noting effects of geometry and shielding differences between the proposed canisters and the currently approved canisters.

between the proposed canisters and the currently approved canisters.

The applicant should modify the application to include the requested information.

The applicant should modify the application to include the requested information.

This information is needed to confirm compliance with 10 CFR 71.35(a) and 71.47.

This information is needed to confirm compliance with 10 CFR 71.35(a) and 71.47.

19

RH RH--TRU Waste Dose Rates TRU Waste Dose Rates Dose rates from RH Dose rates from RH--TRU waste vary on a container by TRU waste vary on a container by container basis as a function of:

container basis as a function of:

- Mixture and quantity of gamma and neutron emitting Mixture and quantity of gamma and neutron emitting radionuclides radionuclides

- Physical and chemical composition of source matrix and Physical and chemical composition of source matrix and associated self associated self-shielding properties (internal material shielding properties (internal material associated self associated self-shielding properties (internal material shielding properties (internal material attenuation) attenuation)

- Distribution of radionuclides in the source matrix (distance Distribution of radionuclides in the source matrix (distance attenuation) attenuation) 20

Radionuclide Mixture Radionuclide Mixture RH RH-TRU waste inventory identifies the presence of TRU waste inventory identifies the presence of possible isotopes possible isotopes

- 169 gamma 169 gamma

- 37 neutron 37 neutron

- 31 of the above are combined gamma/neutron 31 of the above are combined gamma/neutron Radionuclide content is determined via measurement or Radionuclide content is determined via measurement or records records 21

Chemical Composition Chemical Composition 39 different basic material and chemical constituents in 39 different basic material and chemical constituents in quantities >1% by weight are defined in the chemical quantities >1% by weight are defined in the chemical lists for 88 TRUCON codes generated to date lists for 88 TRUCON codes generated to date Chemical and material content is determined via records, Chemical and material content is determined via records, procurement controls, or sampling procurement controls, or sampling 22

Radionuclide Distribution Radionuclide Distribution Distribution of radionuclides throughout a TRU payload Distribution of radionuclides throughout a TRU payload canister is dependent upon the waste production, canister is dependent upon the waste production, processing, and packaging operations leading to an processing, and packaging operations leading to an indeterminate number of distribution configurations indeterminate number of distribution configurations Radionuclide distribution cannot be directly determined Radionuclide distribution cannot be directly determined 23

HAC Shielding Analysis HAC Shielding Analysis Bounding Configuration Bounding Configuration

- Each radionuclide individually Each radionuclide individually analyzed under conditions of:

analyzed under conditions of:

maximum shield damage (puncture) maximum shield damage (puncture) minimum distribution/distance minimum distribution/distance (point source aligned with puncture (point source aligned with puncture (p

g p

(p g

p at inner surface of payload canister) at inner surface of payload canister) no credit for self no credit for self--shielding shielding assume iron build assume iron build--up factor for up factor for composite lead composite lead--steel shield steel shield

- Sum of partial fractions utilized to Sum of partial fractions utilized to apply individual analyses to each apply individual analyses to each unique mixture of radionuclides unique mixture of radionuclides 24

NCT Shielding Analysis NCT Shielding Analysis Bounding Configuration Bounding Configuration

- Would unnecessarily reduce shipping efficiency by disallowing Would unnecessarily reduce shipping efficiency by disallowing shipments (67 or 15%) that have been historically shown (435 shipments (67 or 15%) that have been historically shown (435 evaluated) to satisfy NCT dose rate requirements via a evaluated) to satisfy NCT dose rate requirements via a comprehensive preshipment survey, surveys at points of entry, and comprehensive preshipment survey, surveys at points of entry, and surveys during receipt at WIPP surveys during receipt at WIPP Shipments would fail due to the bounding analyses not crediting the Shipments would fail due to the bounding analyses not crediting the actual waste matrix properties (distribution, self actual waste matrix properties (distribution, self-shielding); properties shielding); properties p

p

(

p p

(

g); p p

g); p p

are real and present, yet vary on a canister by canister basis are real and present, yet vary on a canister by canister basis

- Could significantly reduce future shipments as 64% of historical Could significantly reduce future shipments as 64% of historical shipments would have been more limited by NCT activity than NCT shipments would have been more limited by NCT activity than NCT dose rate measurement dose rate measurement Reasonable Configuration Reasonable Configuration

- Would require monte Would require monte--carlo evaluation of all radionuclides to credit carlo evaluation of all radionuclides to credit radionuclide distribution, waste matrix self radionuclide distribution, waste matrix self--shielding, and accurately shielding, and accurately calculate build calculate build--up in the composite shield up in the composite shield

- A A meaningful meaningful reasonable configuration cannot be defined due to the reasonable configuration cannot be defined due to the variations in chemical/materials, distribution, self variations in chemical/materials, distribution, self--shielding, etc.

shielding, etc.

- Purpose is unclear from a regulatory compliance perspective Purpose is unclear from a regulatory compliance perspective 25

0.1000 1.0000 10.0000 100.0000 0.00 0.10 0.20 0.30 0.40 0.50 0.60 0.70 0.80 0.90 1.00 and/or Activity Limit Fraction RH Shipments - Dose Rate Compliance Preshipment Measurement vs NCT and HAC Activity Limits

>1.0 = not shippable above this line = limited by analysis, not by measurement 0.0000 0.0001 0.0010 0.0100 Dose Rate Measurement a Dose Rate Measurement Fraction Dose Frac SPF HAC SPF NCTvol SPF NCTpt 26

NCT Dose Rate Survey NCT Dose Rate Survey Same procedures employed by shipping sites for all Same procedures employed by shipping sites for all radioactive material shipments (e.g., Type A, Type B, ) to radioactive material shipments (e.g., Type A, Type B, ) to ensure that maximum measured dose rates are in compliance ensure that maximum measured dose rates are in compliance with regulatory requirements (e.g., 49CFR with regulatory requirements (e.g., 49CFR§§173.441, 173.441, 10CFR 10CFR§§71.47, )

71.47, )

Procedures and equipment are qualified under a DOE Procedures and equipment are qualified under a DOE d QA t

t d

d (

ANSI d QA t

t d

d (

ANSI N323A)

N323A) approved QA program to standards (e.g., ANSI approved QA program to standards (e.g., ANSI-N323A)

N323A)

Dose rate emanating from a Type A package does not Dose rate emanating from a Type A package does not fundamentally differ from a Type B package fundamentally differ from a Type B package

- The limits are the same, the potential safety consequences are the The limits are the same, the potential safety consequences are the same, so why not the compliance method?

same, so why not the compliance method?

Measurement is the best and most direct method to ensure Measurement is the best and most direct method to ensure compliance with NCT dose rate limits for TRU waste compliance with NCT dose rate limits for TRU waste Measurement is the compliance method for the vast majority Measurement is the compliance method for the vast majority of nuclear material shipments of nuclear material shipments 27

SFST SFST--ISG ISG--20 20 Transportation Package Design Changes Authorized Under 10 Transportation Package Design Changes Authorized Under 10 CFR Part 71 Without Prior NRC Approval CFR Part 71 Without Prior NRC Approval

- Regulatory Basis Regulatory Basis The application must include a description of the contents in sufficient The application must include a description of the contents in sufficient detail to provide an adequate basis for evaluation of the packaging detail to provide an adequate basis for evaluation of the packaging design. [10CFR design. [10CFR§§71.31(a)(1) and 71.31(a)(1) and §§71.33(b)]

71.33(b)]

Before each shipment, the licensee must ensure that the package Before each shipment, the licensee must ensure that the package p

p g

p p

g meets the routine determination requirements of 10 CFR Part 71.

meets the routine determination requirements of 10 CFR Part 71.

[10CFR

[10CFR§§71.87]

71.87]

- Section 2 Section 2 specificity of the contents description may be different for different specificity of the contents description may be different for different package types and the safety significance of the contents.

package types and the safety significance of the contents.

- Appendix B Appendix B typical examples of what a reviewer should look for in a package typical examples of what a reviewer should look for in a package design and operations in a well design and operations in a well--prepared package application from the prepared package application from the applicant. Examples are provided for the major package types, and applicant. Examples are provided for the major package types, and represent actual experience with package approvals.

represent actual experience with package approvals.

28

SFST SFST--ISG ISG--20 20 -- Example #1 Example #1 Package Type -

Feature Examples of How Flexibility Can be Provided Radiography Radiography Package Package -

supplemental supplemental gamma shielding gamma shielding in drawings in drawings Drawings should show a general arrangement for using Drawings should show a general arrangement for using supplemental shielding, if needed to meet normal condition supplemental shielding, if needed to meet normal condition dose rate limits. The materials of construction, maximum dose rate limits. The materials of construction, maximum weight and thickness, and method of attachment should be weight and thickness, and method of attachment should be shown The specific details are not needed because the shown The specific details are not needed because the in drawings in drawings shown. The specific details are not needed, because the shown. The specific details are not needed, because the supplemental shielding is intended for the maximum supplemental shielding is intended for the maximum strength source to meet the normal conditions dose rate strength source to meet the normal conditions dose rate limit. If the radiation survey does not confirm that the limit. If the radiation survey does not confirm that the shielding is adequate, the source may not be shipped. The shielding is adequate, the source may not be shipped. The shielding evaluation should show that the package can meet shielding evaluation should show that the package can meet the accident conditions dose rate limit without the the accident conditions dose rate limit without the supplemental shielding, so its attachment is not critical to supplemental shielding, so its attachment is not critical to the safe performance of the package.

the safe performance of the package.

Interpretation: supplemental shielding is equivalent to waste self-shielding such that a preshipment survey satisfies NCT and an analysis not crediting self-shielding satisfies HAC = Current 72-B SAR Methodology 29

SFST SFST--ISG ISG--20 20 -- Example #2 Example #2 Package Type -

Feature Examples of How Flexibility Can be Provided Type B Waste Type B Waste Package Package -

contents contents specification specification The exact isotopic distribution of the contents is often not The exact isotopic distribution of the contents is often not known for these packages. The contents may be identified known for these packages. The contents may be identified in terms of the number of A in terms of the number of A2 2 values for containment values for containment considerations. For shielding considerations, a representative considerations. For shielding considerations, a representative loading along with normal conditions dose rates could be loading along with normal conditions dose rates could be loading, along with normal conditions dose rates could be loading, along with normal conditions dose rates could be used. The radiation analysis should show that a reasonable used. The radiation analysis should show that a reasonable rearrangement of contents under accident conditions would rearrangement of contents under accident conditions would result in a dose rate less than the accident condition limit.

result in a dose rate less than the accident condition limit.

Interpretation: 105 A2, HAC activity limits, FGE limits,, and leaktight containment criteria provide sufficient definition of contents; full reconfiguration of activity under HAC = Current 72-B SAR Methodology 30

SFST ISG SFST ISG--20 Applicability to 72 20 Applicability to 72--BB Contents limits are defined utilizing multiple methodologies Contents limits are defined utilizing multiple methodologies per the RH per the RH--TRAMPAC to ensure compliance with the TRAMPAC to ensure compliance with the regulations and regulations and provide a sufficient basis for evaluation of the provide a sufficient basis for evaluation of the package package.

Dose Rate Compliance Dose Rate Compliance

- NCT activity limits are not specified directly, but rather limited via NCT activity limits are not specified directly, but rather limited via preshipment radiological surveys to provide a preshipment radiological surveys to provide a sufficient basis for sufficient basis for ll evaluation evaluation Insignificant damage to the shield under NCT, blocking and bracing of Insignificant damage to the shield under NCT, blocking and bracing of contents, no credit for supplemental ALARA shielding, significant contents, no credit for supplemental ALARA shielding, significant handling of the contents in multiple orientations prior to, during, and handling of the contents in multiple orientations prior to, during, and after loading in the package along with historical verification of no after loading in the package along with historical verification of no significant reconfiguration of the contents under NCT ensure measured significant reconfiguration of the contents under NCT ensure measured dose rates are maintained and do not exceed 200 dose rates are maintained and do not exceed 200 mrem mrem/hr @ surface

/hr @ surface and 10 and 10 mrem mrem/hr @ 2 meters

/hr @ 2 meters

- HAC activity limits are determined via analysis and enforced via use HAC activity limits are determined via analysis and enforced via use of sum of partial fractions to provide a of sum of partial fractions to provide a sufficient basis for evaluation sufficient basis for evaluation The most extreme and conservative HAC analysis conditions ensure a The most extreme and conservative HAC analysis conditions ensure a large margin against the dose rate exceeding 1 large margin against the dose rate exceeding 1 rem rem/hr @ 1 meter from

/hr @ 1 meter from the package surface the package surface 31

NCT Dose Rate Position Summary NCT Dose Rate Position Summary Current measurement approach has a proven track record Current measurement approach has a proven track record and is the currently approved compliance method for all NRC and is the currently approved compliance method for all NRC--

certified Type B packages utilized by WIPP (TRUPACT certified Type B packages utilized by WIPP (TRUPACT--II, II, HalfPACT, TRUPACT HalfPACT, TRUPACT--III, RH III, RH--TRU 72 TRU 72--B, CNS 10 B, CNS 10--160B) 160B)

Analysis Analysis--based NCT activity limits for TRU waste either:

based NCT activity limits for TRU waste either:

- unnecessarily restrict safe shipments (including those previously unnecessarily restrict safe shipments (including those previously made under an NRC CofC) when using a bounding analytical made under an NRC CofC) when using a bounding analytical h

approach, or approach, or

- dont enhance the safety basis of the package (due to not providing dont enhance the safety basis of the package (due to not providing activity limits that are bounding for all TRU waste) when using a activity limits that are bounding for all TRU waste) when using a reasonable analytical approach reasonable analytical approach A survey method that continuously scans the package surface A survey method that continuously scans the package surface and at 2 meters from the package surface to ascertain the and at 2 meters from the package surface to ascertain the maximum gamma and neutron dose rates effectively ensures maximum gamma and neutron dose rates effectively ensures compliance with 10CFR compliance with 10CFR§§71.47 71.47

- Use of discrete grid spacing and recording of non Use of discrete grid spacing and recording of non--bounding values bounding values is onerous is onerous 32

Proposed Shielding RSI Proposed Shielding RSI--2 Resolution 2 Resolution Augment RH Augment RH--TRAMPAC Section 3.2.2 to add the TRAMPAC Section 3.2.2 to add the following:

following:

Radiation dose rates shall be obtained through the Radiation dose rates shall be obtained through the implementation of site implementation of site--specific procedures that direct the specific procedures that direct the measurement of measurement of both both gamma and neutron dose rates for the gamma and neutron dose rates for the package at the surface and at 2 meters from the surface.

package at the surface and at 2 meters from the surface.

package at the surface and at 2 meters from the surface.

package at the surface and at 2 meters from the surface.

Contact dose rate surveys shall be performed on all exposed Contact dose rate surveys shall be performed on all exposed external surfaces (full external surfaces (full--length circumferential and ends) of the length circumferential and ends) of the package and the highest value recorded. Two package and the highest value recorded. Two--meter dose rate meter dose rate surveys from the outer lateral surfaces of the package surveys from the outer lateral surfaces of the package (excluding the top and underside of the package) shall be (excluding the top and underside of the package) shall be performed and the highest value recorded. Radiation monitoring performed and the highest value recorded. Radiation monitoring instruments shall be maintained and calibrated at least annually instruments shall be maintained and calibrated at least annually in accordance with national standards (e.g., American National in accordance with national standards (e.g., American National Standards Institute [ANSI]

Standards Institute [ANSI]--N323A).

N323A).

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Comments Comments 34