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Nuclear Fuel Services, Inc. ERWIN. TENNESSEE 37650t
+r3'y-Q ; A Subsidiary of Getty Oil Company (615) 743-9141iA J
.i li 43ApSil26,1979
3to
4 /roMr. Charles E. flacDonald, ChiefTransportation Branch p
DOCKnODivision of Fuel Cycle and Material Safety UsNac OU. S. Nuclear Regulatory Commission p-
Washington, D. C. 20555 E- APR 3 01979 c, aNMss-
hy,'SFC7rc.yReference: (1) Docket 70-143, SNM 124 g(2) Letter, C. J. Michel to C. E. MacDonald, - SC
Ndated December 22, 1978 g ' ;' ,,(3) Letter, C. E. MacDonald to C. J. Michel, =-dated February 26, 1979
Dear Mr. MacDonald:
In response to reference 3, NFS submits the attached Safety AnalysisReport for Plutonium Packaging. This Report demonstrates the follow-ing:
1. Compliance with the double containment requirement forplutonium as specified in 10 CFR 71.42 utilizing theSuper Tiger packaging with specification 17H innercon tainers .
2. That the form of the plutonium to be packaged inType A fiberglass reinforced plywood containers with-in the Super Tiger. package is nondispersable andessentially nonrespirable such that it should bedetermined to be exempt from the double containmentrequirement per 10 CFR 71.42(b)(3).
This Report further justifies the amendment to Certificate of Compliance6400 that was requested in our referenced letter.
Your earliest review and approval of this amendment is requested in orderthat we may proceed with the decommissioning plans for our plutoniumf acili ty.
Very truly yours,
79060600d .,
. - . ' 7; < R. . L.' ~ ~ C. J. Michel
Administrative Manager
CJM:kj >
Attachment / ,' [ MMi
2276 .42
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SAFETY ANALYSIS REPORT FOR PLUiONIUM PACKAGIdG
I. INTRODUCTI0d
Nuclear Fuel Services proposes to utilize the Super Tiger packaging
presently licensed by the Nuclear Regulatory Commission as Certificate
of Compliance USA /5400/B()F to transport contaminated waste generated
in the decommissioning of its plutonium facility (see NFS Plan for De-
commissioning of Plutonium and Uranium-233 Facilities, dated October 9,
1978). Although the Plan specifies decontamination of equipment prior
to packaging, it is anticipated tnat some packaged objects will contain
residue quantities of plutonium in excess of 20 curies. Since the
Super Tiger is not presently licensad to transport more than 20 curies
of plutonium in oxide form, NFS requested, in a letter dated December 22,
1978, an amendment to the Certificate to pemit the Commission to
specifically authorize shipments in excess of 20 curies of plutonium.
In response to this request for amendment, the NRC requested additional
information in a letter dated February 26, 1979. This Report contains
the infomation requested in tjlat letter.
II. SCOPE
This Report is written to demonstra a: (1) Compliance with the dochie
containment requirement for plutonium, as specified in 10 CFR 571.42,
utilizing the Super Tiger packaging with Specification 17H inner con-
tainers, and (2) that the fom of the plutonium to be packaged in Type
A fiberglass reinforced plywood containers within .the Super Tiger
package is nondispersable and essentially nonrespirable such that it
should be detemined to be exempt from the double containment require-
ment per 10 CFR 71.42(b)(3).
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Page 2 of 6.
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III. SUPER TIGER /17H PACKAGING
A. Description
The Super Tiger has been adequately described in the original
application (see Engineering Evaluation of the Super Tiger Over-
pack Designed for the Shipment of Large Quantities of Hazardous
Materials , Dated flay 4,1970) . Since no changes are proposed to
the Super Tiger, the description is referenced. Similarly, the
17H packaging is well described in 49 CFR 5173.396 and 5178.118.
In addition, NFS proposes to equip each 17H container with a rigid
polyethylene liner. The 17H with the liner is depicted in Figure 2.5.
The polyliner is 0.1 inch thick and closure is accomplished by
using a slip fit poly lid that will be sealed with tape or
adhesive. The 17H with polyliner is also described in RFP 2244
"ATMX-600 Rail Car Safety Analysis Report for Packaging", Rev.1.
B. Testing Analysis
The Super Tiger has already been successfully tested under both
normal and accident conditions. It provides the first barrier
for plutonium containment. The second barrier for containment
is provided by the 17H with the rigid polyliner. The integrity
of the 17H container was demonstrated by the original Super Tiger
tes ts . Two of the forty-two 55-gallon drums contained in the
Super Tiger during testing were Specification 17H drums. As
reported in the original application, these containers experienced
little or no deformation and no liquid was lost from the containers.
This information and other details can be found on pages 63 thru
65 of the Engineering Evaluation. The exact location of the 17H
2276 ;44 N.
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B. Testing Analysis (cont'd)
containers within the Super Tiger was ret gi/en in the Evaluation.
It is important to note that the Super Tiger was subjected to
four 40-inch puncture tests, impacting on three sides of the
package. These tests should have maximized damage to the inner
containers regardless of location. It should also be noted that
the drums were not equipped with polyliners, nor were they banded
or shored. This loose packing of the inner containers was to
maximize impact between the inner containers during testing.
C. Special Considerations
To minimize the impact between the 17H drums within the Super
Tiger under normal and accident conditions, NFS proposes to band
the drums together in groups of four. 'Jooden shoring will also
be provided to minimize move. ment of the drums during transport.
This will reduce drum damage since the banding and sharing will
absorb impact energy.
.
To minimize the possibility of packaged objects piercing the
polyliner and/or the drum, heavy, dense objects such as sheet
metal, pipes, and concrete that have piercing potential will be
tightly packed in drums, and low density waste (plastic, paper,
cardboard, etc.) will be packed between the heavy objects and
the polyliner.
2276 .45
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Page 4 of 6-
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IV. SUPER TIGER / TYPE A FRP PACKAGING
A. Descriotion
A typical FRP box is depicted in Figure 2.6. Box specifications
are detailed in RFP 2460 '' Safety Analysis Report for Packaging -
00T-7A Fiberglass-Coated Plywood Box for Transuranium Solid
llas te" . NFS proposes to use the FRP box as described in RFP 2460
with two exceptions: (1) The inner 0.C51" fiberboard liner and
lid will not be provided, and (2) sizes of the boxes used will
vary from the specified 4' x 4' x 7' dimensions.
The fiberboard liner will be replaced with 1/4" plywood sheets
on four sides of the box. The plywood will provide better
protection from objects piercing to the other FRP box in the
area where piercing is most likely to cccur.
Boxes will be sized specifically for the bulky pieces of-equip-
ment to provide for a tighter fit, thus minimizing internal
movement during transport. The boxes will also be sized to pro-
vide a tight fit within the Super Tigar, again to minimize move-*
ment. It should be noted that the dimensions specified in
RFP 2460 were determined primarily by the size of ATMX railcar.
Sizes of the NFS boxes will vary from 65" x 75" x 162" to
40" x 41" x 61". These variatior,s in sizes will not significantly
affect the integrity of the box.
8. Testing Analysis
The FRP box has been successfully tested to meet the requirements
for a Type A packaging. Details of the test results are presented
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B. Testing Analysis (cont'd)!
in RFP 2460. flo testing has been performed on the Super Tiger /
Type A FRP packaging; however, it is logical to assume that the
Super Tiger would have maintained its integrity independent of
whether it had been loaded with boxes or drums. The integrity
of the boxes, on the other hand, cannot be assumed, so that the
double containment of the plutonium for the Super Tiger / Type A
FRP packaging cannot be assumed under accident conditions.
C. Plutonium Immobilization
flFS proposes to immobilize the plutonium contamination on the
equipment to be placed in FRP boxes in order to render the
plutonium nondispersable and essentially nonrespirable. With the
plutonium in this form, it should be determined that the double
containment requirement of 10 CFR 71.42 is not applicable as
provided for in 10 CFR 71.42(b)(3).
NFS preposes to apply Turco 5931 Stripable Coating, or equivalent,
on all contaminated surfaces of equipment that are packaged in
FRP boxes. This coating will adhere to both stainless steel and
plexiglass surfaces. It has elastic properties that minimize
cracking and chipping during impact. It will easily withstand
temperatures of 150 F that were experienced within the Super Tiger
during the fire test. It is non-flammable and can be applied with a
brush. It also has the property of retaining contamination if it
is removed from the surface.
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Page 6 of 6
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D. Soecial Considerations
Equipment will be packed in the boxes as described in Sections III.C
and IV./. to prevent internal piercing of the containers. NFS also
proposes to remove ail objects that protrude from the large pieces
of equipment so as to eliminate the possibility of these objects
piercing the FRP box. Any force caused by internal movement of
the packaged equipment will be displaced over a large area of the
container, thus minimizing damage, if any, to the container. The
removed protruding objects will be packaged in 17H drums where
better protection is provided against piercing.
The FRP boxes will be shored with wood within the Super Tiger to
insure a close fit and to minimize movement.
When FRP boxes are loaded in the Super Tiger, along with 17H drums,
protection will be provided to prevent the drums from damaging
the boxes. This protection will consist of a sheet of 1/4" plywood
between the box and the drum and inflated o innace bags between the
plywood and the box. Where space permits, these dunnage bags will,
also be utilized between boxes and be:. ween boxes and ca Super Tiger.
2276 ;48
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Adh ive
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Metal ag withEmbossed identity
Number Welded' to Lugs
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\Radio ctive Material White-1,Yelloeil, or Ye:!ow lit Label
as Appropriate. 2 Plans,Approm 180* Apm
FIGURE 2.5 Typical Drum Type Waste P:ckagewith Rigid 0.1 lach Tldek Polyethylene lic.er
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FIGURE 2.6 Construction details of DOT.7A,fiberj;!as:<cated plywood box.
Non-stip Surf ace,
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Construction Adhesivo
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Radioactive Material / . ,. Fluth Panet Box * <.
*Diarnond Labet,2 Places, ''On Opposite Sides of Box , I
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TYPIC AL 00X SECTIO *J
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