18-22-9204 ser for coc rev11 - us department of energy · two lifting lugs and two redundant...

Mr. Gerry van N oordennen Vice President, Regulatory Affairs Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202

Dear Mr. van Noordennen:

Department of Energy Washington, DC 20585

April 2, 2019

In response to your request to Dr. James Shuler of my staff dated June 19, 2018, as supplemented February 26, 2019, enclosed is the U.S. Department of Energy (DOE) Certificate of Compliance (CoC) Number 9204, Revision 11, with its attached Safety Evaluation Report, for the Model 10-160B. Changes to the CoC are indicated by vertical bars in the right page margin.

This CoC is issued by DOE under the authority of 49 CFR 173.7(d) and is conditional upon fulfilling the applicable Operational and Quality requirements of 49 CFR Parts 100-199 and 10 CFR Part 71, and the conditions specified in Item 5 of the CoC.

The expiration date for DOE Certificate Number 9204, Revision No. 11, is December 31, 2020. Please note that DOE will require a consolidated application in accordance with §71.38(c) with a request to renew this CoC.

If you have any questions, please contact me or Dr. James M. Shuler of my staff at (301) 903-5513.

Enclosure

cc: Vic Pearson, ID Kathryn McBride, INL Aleksandr Gelfond, EnergySolutions Robert Watkins, SRNL James Shuler, EM-4.24

Sincerely,

r!J~ Joanne D. Lorence Headquarters Certifying Official Director Office of Packaging and Transportation

DOE Packaging Certification Program

CERTIFICATE OF COMPLIANCE For Radioactive Materials Package

DOE F 5822.1

(5-85 Formerly EV-618)

1 a. Certificate Number 1 b. Revision No. 1 c. Package Identification No. 1d. Page No. 1 e. Total No. Pages

9204 11 USA/9204/B(U)F-96 (DOE) 1 8 2. PREAMBLE

2a. This certificate is issued under the authority of 49 CFR Part 173.7(d).

2b. The packaging and contents described in Item 5 below meet the safety standards set forth in subpart E, "Package Approval Standards" and subpart F, "Package, Special Form and LSA-111 Tests" Title 10, Code of Federal Regulations, Part 71.

2c. This certificate does not relieve the consignor from compliance with any requirement of the regulations of the U.S. Department of Transportation or other applicable regulatory agencies, including the government of any country through or into which the package will be transported.

3. This certificate is issued on the basis of a safety analysis report of the package design or application -(1) Prepared by (Name and Address): (2) Title and identification of report or application:

Energy Solutions Consolidated Safety Analysis Report for

7 40 Osborn Road Model 10-1608 Type B RADWASTE Shipping Barnwell, SC 29812 Cask, Energy Solutions Revision 3, as

supplemented [See 5(e)]

4. CONDITIONS

(3) Date:

I January 2011

This certificate is conditional upon fulfilling of the applicable Operational and Quality Assurance requirements of 49CFR parts 100 - 199 and 1 0CFR Part 71, and the conditions specified in Item 5 below.

5. Description of Packaging and Authorized Contents, Model Number, Transport Index, other Conditions, and References:

(a) Packaging

(1) Model Number: 10-1608

(2) Description:

A cylindrical carbon steel and lead shielded shipping cask, designed to transport radioactive waste material. The cask is transported in the upright position and is equipped with steel encased, rigid polyurethane foam impact limiters on the top and bottom. The package has approximate dimensions, shielding, and weight as follows:

Cask height Cask outer diameter Cask cavity height Cask cavity diameter Overall package height, with impact limiters Overall package diameter, with impact limiters Lead shielding thickness

88 inches 78-1 /2 inches ??inches 68inches 130inches 102inches 1-7/8 inches 72,000 lbs Gross weight (packaging and contents)

Maximum total weight of contents, shoring, secondary containers, and optional shield insert 14,250 lb.

6a. Date of Issuance: 0 L/ 6b. Expiration Date: December 31, 2020 FOR THE U.S. DEPARTMENT OF ENERGY

7a. Address (of DOE Issuing Office)

U.S. Department of Energy Office of Packaging and Transportation (EM-33) 1000 Independence Avenue, SW Washington 1 DC 20585

7b. Signaturep~E Approving Official)

Cence Headquarters Certifying Official Director Office of Packa in and Trans ortation

Certificate Number Revision No. Package Identification No. Page No. Total No. Pages

9204 11 USA/9204/B(U)F-96 (DOE) 2 8

The cask body consists of a 1-⅛-inch thick carbon steel (ASME SA516 or SA537) inner shell, a 1-⅞-inch thick lead gamma shield, and a 2-inch thick carbon steel outer shell (ASME SA516). The inner and outer shells are welded to a 5-½-inch thick carbon steel bottom plate. The cask cavity has an optional 11-gage stainless steel liner. A 12-gage stainless steel thermal shield surrounds the cask outer shell in the region between the impact limiters. The impact limiters are secured to each other around the cask by eight ratchet binders.

The cask lid is a 5-½ inch thick carbon steel plate, and has a 31-inch diameter opening equipped with a secondary lid. The primary lid is sealed with a double elastomer O-ring and 24 equally spaced 1-¾ inch diameter bolts. The secondary lid is 46 inches in diameter, is centered within the primary lid, and is sealed to the primary lid by a double elastomer O-ring and 12 equally spaced 1-¾ inch diameter bolts. The space between the double O-ring seals is provided with a test port for leak testing the primary and secondary lid seals.

The secondary lid is protected by a thermal shield which consists of two polished stainless steel plates separated by a thin air gap. The thermal shield is attached to the secondary lid lifting lugs with hitch-pins. The optional cask drain and vent ports are sealed with a plug and an O-ring seal.

The package is equipped with four tie-down lugs welded to the cask outer shell. Two lifting lugs and two redundant lifting lugs are removed during transport. The lid is equipped with three lifting lugs which are covered by the top impact limiter and rain cover during transport.

An optional carbon steel shield insert may be used within the cask cavity for contents as specified in 5(b)(1)(i) through (v) for contents specified in 5(b)(1)(vii), a source insert (Drawing C-038-145083-004) shall be used. The source insert design weight is 8,000 lbs; it has side walls consisting of 6.0-inch thick lead, sandwiched between an inner 8 inches nominal SCH 60 steel pipe and an outer 24.0-inch SCH steel pipe. The bottom of the source insert also consists of lead supported by a 0.75-inch thick steel base plate. The lid includes a steel encased lead plug, steel bolting plate and flat silicone rubber gasket. Steel or wooden cribbing (Drawings C-038-145083-005 and DWG-4132-ST-0005 respectively) may be used to support the source insert within the 10-160B.

The Argonne National Laboratory (ANL) Source Container Assembly is a two-part, vented, shielded source container specified in Drawing C-038-349097-001 and provides both photon (gamma) and neutron shielding in the forms of lead and steel for photon shielding and a casted neutron shield material, SWX-237. The photon shield has side walls consisting of lead with a total thickness of 6.0 inches, located between an inner 8.0-inch (nominal) SCH 60 steel pipe and an outer 24.0-inch (nominal) SCH 60 steel pipe. The bottom consists of 5.0 inches of lead supported by a 0.75-inch thick steel base plate. The lid includes a steel encased lead plug (nominal lead thickness 8 ⅞ inches), steel bolting plate, and flat silicon rubber gasket. The neutron shield has side walls consisting of SWX-237 with a thickness of 3.0 inches between an inner 26 inch nominal SCH 20 steel pipe and an outer 33 inch OD rolled ½ inch steel plate. There are four vents from the gamma shield cavity through the shield wall. These are aligned with four vents through the neutron shield, which terminate with a HEPA filter. The vents provide a diffusion path to the cask void for hydrogen generated in the gamma shield cavity. The bottom has 3 inches of SWX-237 supported by a ½ inch steel plate. The lid is a 3 inch SWX-237 layer enclosed in steel with a steel bolting plate and flat silicon rubber gasket. The ANL Source Container was designed as a one-time use disposal container for the contents specified in 5(b)(1)(vi) of this Certificate.

The Los Alamos National Laboratory (LANL) Corrugated Metal Box (CMB) is a filter-vented, Department of Transportation (DOT) Spec 7A, Type A container with overall dimensions (in inches) approximately 38-½ (height) x 54 (width) x 68 (length) and authorized gross weight of


9204 11 USA/9204/B(U)F-96 (DOE) 3 8

6,000 lb. The CMB is of a welded construction, fabricated from 14 gage mild steel. The CMB closure is by welding the lid to the container body. The CMB shipping configuration includes three NUCFIL filter-vents installed on the container body to aid hydrogen diffusion to the 10-160B containment system. The CMB requires cribbing to prevent movement of the CMB within the 10-160B cask during NCT and HAC. The estimated weight of the cribbing design is 4,800 lb. The cribbing is a two-piece design, consisting of Lower and Upper Guide Assemblies. The Lower Guide Assembly sits below the CMB and the Upper Guide Assembly is installed after the CMB is loaded in the 10-160B. The Upper Guide Assembly has an adjustable height plate to eliminate axial gaps between the cribbing and the 10-160B cavity. Both the Upper and Lower Guide Assemblies have eight cantilevered guide arms that center the CMB and bear upon the 10-160B containment shell walls through ultra-high molecular weight polyethylene contact guides. The CMB and cribbing design are required to transport the contents specified in 5(b)(1)(viii) of this Certificate.

The Gammacell (GC) configuration consists of previously certified Type B packagings modified to use as source inserts and one-time-use disposal containers. The containers are the GC 200 Irradiator, GC 200 Irradiator with extra shielding band, and the GC 220 Irradiator. Each GC consists of a lead-shielded, cylindrical, steel-encased body welded to a support frame/skid. The skids are 32 inches square by 4 inches tall. The overall height of a GC (with skid) is approximately 34 inches. The GC 200 is 25 ¾ inches in diameter with approximately 9 inches of shielding thickness. The GC 200 with extra shielding band is 28 inches in diameter and has an additional 1-inch-thick band of lead added to the side of the packaging. The GC 220 is 30 inches in diameter with approximately 14 inches of shielding thickness. The components of the modified GCs are as follows: a) shielded body with integral skid, b) top shield plug/lid, c) lower shield plug, and d) source containers (i.e., bucket and spacers/plate configurations). The usable cavity in the GC 200 and 200 with extra shielding band is 6.2 inches tall by 7 inches in diameter; the usable cavity in the GC 220 is 8.5 inches tall by 8.75 inches in diameter. Source containers are designed to fit these respective cavities; there are two source container configurations for the GC 200 and 200 with extra shielding band and two for the GC 220. The GC 200 lids are secured with eight (8) ¾ inch -10 NC bolts; the GC 220 lid is secured using four (4) ¾ inch-10 NC bolts. Only a single GC at a time may be transported in 10-160B. The GCs and wooden cribbing design are required to transport the contents specified in 5(b)(1)(ix) of this Certificate.

The 20WC-5 Shield Insert configuration consists of a previously certified (expired) 20WC-5, Type B(U) packaging, a convenience canister assembly or basket assembly, and a cask cribbing assembly. The 20WC-5 complete packaging consists of an overpack drum and assembly, 2R transport container assembly, and tungsten shield assembly. The drum lid is secured to the drum body by sixteen (16), ½ inch–13 UNC-2B hex nuts. The 20WC-5 drum outer dimensions are 39 ½ inches in diameter and 51 5/16 inches tall. The 2R transport container assembly and tungsten shield assembly are nested in a drum cradle assembly inside the cavity of the drum. The tungsten shield assembly is 11 7/8 inches in diameter and 30 ¼ inches tall, weighs approximately 1,800 pounds, and provides approximately 5 3/8 inches of shielding. The usable internal cavity of the shield assembly is approximately 2 inches in diameter and 17 ¾ inches tall, or 1 inch in diameter if tungsten sleeves are used for additional shielding. The Co-60 targets (nickel coated metal, normal form) and returning Co-60 doubly encapsulated special form contents are loaded in a single convenience canister assembly or basket assembly for loading in the shield assembly. Only a single 20WC-5 may be transported in 10-160B. The 20WC-5 and wooden cribbing design (DWG-4182-ST-0001-01) are required to transport the contents specified in 5(b)(1)(x) of this Certificate.

The IBL-437C Irradiator configuration consists of a single self-shielded Model IBL-437C blood irradiator and wood cribbing assembly (with nylon slings). The overall dimensions of the Irradiator


9204 11 USA/9204/B(U)F-96 (DOE) 4 8

are approximately (length, width, & height) 23.6 in. x 23.3 in x 42.1 in. and it weighs 4,519 lb. The overall dimensions of the cribbing assembly, with Irradiator, are 66 in. diameter x 78 in. in height and estimated weight, without Irradiator, is 1,615 lb. The estimated weights of the lower assembly and top assembly are 1,427 and 188 lb. respectively. The Irradiator shield and wooden cribbing design (DWG-5164319-ST-0001) are required to transport the contents specified in 5(b)(1)(xi) of this Certificate, for disposal. The configuration weighs approximately 6,191 lb., with an addition 58 lb. of nylon slings rigged to the Irradiator and cribbing for ease of removal.

(3) Drawings:

The packaging is constructed and assembled in accordance with EnergySolutions Drawing No. C-110-D-29003-010, sheets 1 through 5, Rev. 16.

The Secondary Lid Thermal Shield is constructed in accordance with EnergySolutions Drawing No. DWG-CSK-12CV01-EG-0002-01, Rev. 3.

An optional shield insert is constructed in accordance with Chem-Nuclear Systems Drawing No. C-119-B-0018, Rev. 2.

Source Insert and Cribbing (i.e., shoring): Drawings C-038-145083-004, Rev. 0 (source insert); C-038-145083-005, Rev. 0 (steel cribbing); and DWG-4132-ST-0005-01 through -07, Rev. 1 (wooden cribbing).

An optional ANL Source Container and Shoring are constructed in accordance with EnergySolutions Drawings No. C-038-349097-005, Rev 0 and No. C-038-349097-001, sheets 1-3, Rev 1.

DWG-5063-ME-0100-01, Transport of LANL Corrugated Metal Boxes in the 10-160B Cask, Cribbing General Arrangement, Sheet 1 of 1

DWG-4132-ST-0001-01, -02, and -03, Summary of Field Measurements Modifications and weld Details for Gammacell 200 & 220 Sheet 1 - 3, Rev 1

DWG-4132-ST-0002-01, -02, -03 and -04, Transport of SWRI Gammacells 200, 200 (Extra Shielding Band) & 220 in 10-160B Cask Cribbing Assembly & Details Sheets 1 - 4, Rev 1

DWG-4132-ST-0003-01 and -02, Transport of SWRI Gammacells 200, 200 (Extra Shielding Band) & 220 in 10-160B 220 Dtls of Inner Buckets/Spacers Sheets 1 and 2, Rev 1

DWG-4132-ST-0004-01, Transport of SWRI Gammacells 200, 200 (Extra Shielding Band) & 220 in 10-160B Cask 200 Dtls of Inner Buckets/Spacers Sheet 1 of 1, Rev 1

INIS-DWG-0051, INIS-2/20WC-5 Overpack Drum and Assembly and Details OD 39.5 x51 H, Rev A

INIS-DWG-0007, INIS-2 Tungsten Shield Assembly and Details, Rev C

INIS-DWG-0019, INIS-2R-1 Transport Container Assembly and Details, Rev A

DMP-CICC-100, Cobalt Irradiation Capsule Canister Assembly, Rev 0

INIS-DWG-0049, INIS-SF01.6-13-I Cobalt 60 Calibration Capsule Assembly, Rev B

DWG-4182-ST-0001-01, Transport of 20WC-5 Shield Insert in 10 160B Cask Cribbing Assembly and Details, Rev 2

DWG-5164319-ST-0001, Transport of IBL-437C Irradiator in 10-160B Cask Cribbing Assembly & Details, Sheets 1 through 8, Rev 0


9204 11 USA/9204/B(U)F-96 (DOE) 5 8

(b) Contents:

(1) Type and form of material

(i) Byproduct, source, and special nuclear material, non-fissile or fissile-excepted, as special form, or non-special form in the form of solids, dewatered resins or process solids, or solidified waste, in secondary containers; or

(ii) Dewatered, solid or solidified transuranic-containing wastes (TRU), fissile or non fissile or fissile-excepted, in secondary containers; or

(iii) Plutonium 239 (Pu-239) as PuBe neutron sources meeting the requirements of special form sources; or

(iv) Neutron activated metals or metal oxides in solid form in secondary containers; or

(v) Miscellaneous radioactive solid waste materials, including special form materials and powered solids, in secondary containers; or

(vi) For a shipment of the ANL Source Container specified in Drawing C038-349097-001, and disposal of the Container, byproduct material as dry normal form solids. The Co-60 sources are activated cobalt metal enclosed in stainless steel and/or aluminum. The radium-beryllium sources typically are RaBr2 mixed with Be metal powder in a brass capsule that is sealed with soft solder. Other sources may include RaBr2, RaCl2, or RaSO4 in stainless steel, brass, monel, or nickel tubes that were sealed by welding, brazing, or soft soldering or in flamesealed glass vials. These radium sources may be with or without Be; or

(vii) Byproduct material as Co-60 loaded into the source insert; or

(viii) Solid TRU waste defined as Material Form No. 1 (solids – any particle size), Material Form No. 2 (solids – large particle size only, e.g., sand, debris, concrete, etc.), and Material Form No. 3 (solids – objects with no significant dispersible or removable contamination as defined by 49 CFR 173.433). This CoC authorizes these three waste forms in the LANL CMB; or

(ix) For shipment of a GC, normal form, undamaged, metallic, sealed Co-60 and/or Cs-137 sources; or

(x) For a shipment in the 20WC-5, Co-60 pellets, solid metal, or nickel alloy (plated); or

(xi) For shipment in the Model IBL-437C Irradiator, Cs-137 in special form capsules.

(2) Maximum quantity of material per package

(i) Maximum contents are limited to 0.495 TBq (13.4 Ci) of Co-60; 370 TBq. (10,000 Ci) of Co-60, not to exceed mass of 500 lb., contained in the Source Insert (Drawing C-038-145083-004). For contents other than Co-60, the maximum quantity of radioactive materials is determined by the methodology described in Attachment 1 to Chapter 7 of the SAR. Total quantity of radioactive material is not to exceed 3,000 A2.

(ii) Fissile contents must be limited to the fissile gram equivalent of 325 grams of Pu-239, as determined using the conversion factors in Table 9.1.3, in Chapter 4, Appendix 4.10.2, of the SAR, as supplemented. Plutonium content exceeding 0.74 TBq (20 Ci) must be in solid form.

(iii) TRU exceeding the fissile limits of 10 CFR 71.15 must not be machine-compacted and must have no more than 1% by weight of special reflectors and no more than 25% by volume of hydrogenous material.


9204 11 USA/9204/B(U)F-96 (DOE) 6 8

(iv) Neutron sources as described in 5(b)(1)(iii) are limited to a maximum emission rate of 1.1E+8 neutrons/sec.

(v) Maximum decay heat not to exceed 200 watts.

(vi) Maximum weight of contents: 14,250 pounds including shoring, secondary containers, and optional shield insert. The maximum weight of the ANL Source Container, with contents, is 12,500 pounds. The maximum weight of the LANL CMB, with contents, and cribbing is less than 9,000 lb. The maximum weight of a GC with contents and cribbing is less than 10,000 lb. The maximum weight of the 20WC-5 with contents and cribbing is less than 5,000 lb. The maximum weight of the IBL-437C Irradiator, cribbing, and slings is approximately 6,249 lb.

(vii) Explosives, corrosives, non-radioactive pyrophorics, and compressed gases are prohibited. Pyrophoric radionuclides may be present only in residual amounts less than 1 weight percent.

(viii) The total amount of potentially volatile organic compounds present in the headspace of a secondary container is restricted to 500 parts per million.

(ix) Powdered solid radioactive materials shall not include radioactive forms of combustible metal hydrides or combustible elemental metals (i.e., magnesium, titanium, sodium, potassium, lithium, zirconium, hafnium, calcium, zinc, plutonium, uranium, and thorium), or combustible non-metals (i.e., phosphorus).

(x) Powdered solids contents with neutron emitters are not permitted.

(xi) 4,030 Ci of Co-60 and 3.49 Ci of Ra-226 (as radium-beryllium sources) contained in an ANL Source Container specified in Drawing C-038-349097-001. Radioactive sources in the ANL Source Container shall have a maximum mass of 7.5 kg with not more than 5% by weight of organic material. The total decay shall not exceed 100 watts.

(xii) Each LANL CMB shall contain ≤ 20 aerosol cans and ≤ 4.0 fluid oz. total residual flammable liquids in any aerosol cans to ensure that CMB contents are below the lower flammability limit and < 500ppm volatile organic compound (VOC) content.

(xiii) Each GC 200 or 200 (with extra shielding band) Shielded Insert shall contain no more than 9,000 Ci of Co-60 only, 27,700 Ci of Cs-137 only, or combination of Co-60 and Cs-137 not to exceed 138.5 watts (i.e., thermal limit for the GC 200 and 200 with extra shielding band). Each GC 220 Shielded Insert shall contain no more than 13,000 Ci of Co-60 only, 40,000 Ci of Cs-137 only, or combination of Co-60 and Cs-137 not to exceed 200 watts (i.e., thermal limit for the GC 220).

(xiv) Each 20WC-5 shall contain no more than 10,000 Ci of Co-60.

(xv) Each IBL-437C Irradiator shall contain no more than 5,100 Ci of Cs-137.

(c) Criticality Safety Index: 0.0

(d) Conditions:

(1) In addition to the requirements of Subparts G and H of 10 CFR Part 71:

(i) The package must be prepared for shipment and operated in accordance with the Operating Procedures of Chapter 7, except Section 7.4, of the SAR, as supplemented and


9204 11 USA/9204/B(U)F-96 (DOE) 7 8

(ii) Each packaging must meet the Acceptance Tests and Maintenance Program of Chapter 8 of the SAR, as supplemented.

(2) Transport by air of fissile material is not authorized.

(3) Flammable gas (hydrogen) concentration is limited to less than 5% in volume. For contents other than TRU waste, inerting is not allowed to limit the concentration of flammable gases. For TRU waste, compliance with the 5% hydrogen concentration limit is determined by the methods discussed in Appendix 4.10.2 of the SAR as supplemented. For contents with a radioactivity concentration not exceeding that for Low Specific Activity material, the hydrogen concentration can be assumed to be less than 5% provided the package is shipped within 10 days of preparation, or within 10 days after venting of the drums or other secondary containers.

(4) Payload containers authorized for shipment of TRU waste are the 30-gallon and 55-gallon drums. TRU waste characteristics are determined and limited in accordance with Appendix 4.10.2 of the SAR as supplemented.

(5) The non-homogeneity of the package contents may lead to elevated levels of radiation on the package surfaces. Radiation surveys must be performed to obtain measurements from all surfaces of the package, and from outer surfaces of the vehicle enclosure, unless process knowledge or survey history indicates that elevated radiation levels are not likely to be encountered.

(6) Appropriate devices or measures must secure contents in the secondary container, if necessary.

(7) The Shoring design shall be fabricated and inspected per drawing C-038-349097-005, Rev 0, prior to a shipment of the ANL Source Container in the 10-160B.

(8) The 10-160B package shall be shipped “exclusive use”, per 10 CFR Part 71.

(9) The transport limit for the ANL Source container and contents in the 10-160B package is 60 days, starting when the 10-160B lid is set in place, and conservatively accounts for hydrogen buildup within the package even when not fully sealed (lid bolts torqued, etc.)

(10) Revision 10 of this certificate may be used until March 31, 2020.

(11) The cribbing design for the LANL CMB shall be fabricated and inspected per the drawings specified in Reference 3 (Addendum).

(12) The LANL CMB shall be prepared and loaded as specified in Reference 3 (Addendum).

(13) The modified GCs shall meet the acceptance criteria specified in Reference 4 (Addendum).

(14) The GC source container requirements are as follows: a) for the GC 200 and 200 with extra shielding band, the “bucket” configuration is used only for Cs-137 sources, and the “spacer and tungsten plate” is used for all other source combinations (Ref DWG-4132-ST-0004-01); b) for the GC 220, a “large spacer” and “bucket” configuration is used for any combination of sources, and a “small spacer”, “carousel”, and “bucket” are used for Co-60 pencil sources in the “carousel” and any combination of sources in the “bucket” (Ref DWG-4132-ST-0003-01 and DWG-4132-ST-0003-02).

(15) The cribbing design for the GCs shall be fabricated and inspected per the drawings specified in Reference 4 (Addendum).

(16) The GC Shielded Inserts shall be prepared, loaded, and closed as specified in Reference 4 (Addendum).


9204 11 USA/9204/B(U)F-96 (DOE) 8 8

(17) The steel and wood cribbing designs for the Source Insert shall be fabricated and inspected per the drawings specified in Reference 5 (Addendum).

(18) The cribbing design for the 20WC-5 shall be fabricated and inspected per the drawings specified in Reference 7 (Addendum).

(19) The 20WC-5 shall be prepared, loaded, and closed as specified in Reference 7 (Addendum). The user must perform a radiation survey of the 20WC-5 after the contents are loaded, prior to loading the 20WC-5 in the 10-160B (Reference 7, Addendum, Section 8.1.5).

(20) The package authorized by this certificate is hereby approved for use under the provisions of 49 CFR 173.7(d).

(21) Only DOE or persons working under contract to DOE shall consign the package for shipment.

(22) NRC or Agreement State licensees shall not consign a DOE certified package for shipment, but can transfer the material on-site to DOE or persons working under contract to DOE, for consignment of the package.

(23) The cribbing design for the IBL-437C Irradiator authorized for shipment under 5(b)(2)(xv) shall be fabricated and inspected per the drawings specified in Reference 8 (Addendum) and this Certificate.

(24) The average surface dose rate of the IBL-437C Irradiator authorized for shipment under 5(b)(2)(xv) shall not exceed 2.5 mrem/hr. The Irradiator meeting the average surface dose rate requirement shall be prepared, loaded, and closed as specified in Reference 8 (Addendum)

(e) References:

(1) Source Container Addendum to 10-160B, EnergySolutions, December 2011.

(2) Consolidated Safety Analysis Report For Model 10-160B Type B Radwaste Shipping Cask, Revision 4, July 2012 (includes Source Insert Addendum For Model 10-160B Type B Radwaste Shipping Cask, July 2012). As amended by revised Chapter 7 submitted to NRC on July 26, 2012, and by drawing DWG-CSK-12CV01-EG-0002-01, Rev 3 “Cask Secondary Lid Thermal Shield Details submitted to NRC on August 26, 2012.

(3) Corrugated Metal Box Inner Container Addendum for Model 10-160B Type B Radwaste Shipping Cask, dated September 2013, transmitted with Letter from C.H. Keilers to Dr. James M. Shuler, Transmittal of Q1 Responses and Final SARP Addendum for Type B Packaging Model 10-160B for Corrugated Metal Box Content dated September 27, 2013.

(4) Gammacell 200, Gammacell 200 (Extra Shielding Band) and Gammacell 220 Inserts Addendum for Model 10-160B Type B Radwaste Shipping Cask, Revision 1, February 28, 2014.

(5) Source Insert Addendum for Model 10-160B Type B Radwaste Shipping Cask, Revision 2, May 22, 2014.

(6) EnergySolutions letter to James M. Shuler, dated August 31, 2015

(7) 20WC-5 Shield Insert Shipping Addendum for Model 10-160B Type B RADWASTE Shipping Cask, Revision 1, June 6, 2016.

(8) IBL-437C Irradiator Shipping Addendum for Model 10-160B Type B RADWASTE Shipping Cask, Revision 1, February 2019

Safety Evaluation Report for

Certificate Amendment for Shipment of IBL-437C

Irradiator in the 10-160B Package

Docket No. 18-22-9204

Prepared by: ______________________________ Date: _______________

James M. Shuler

Manager, Packaging Certification Program

Office of Packaging and Transportation

Approved by: ______________________________ Date: _______________

Joanne D. Lorence

DOE Headquarters Certifying Official

Director

Office of Packaging and Transportation

SER for Certificate Amendment for Shipment of IBL-437C Irradiator in the 10-160B Package

Docket 18-22-9204

Page 2 of 14

SUMMARY

This Safety Evaluation Report (SER) documents the independent technical review by the

Department of Energy (DOE) Packaging Certification Program (PCP) staff for compliance with

10 CFR Part 71 of the Addendum to the 10-160B Safety Analysis Report for Packaging (SARP).

The Addendum was prepared and submitted by EnergySolutions (ES or applicant) for the Idaho

Operations Office (ID) to amend DOE Certificate of Compliance (CoC) Number 9204, Rev 10.

The CoC amendment is needed to support the Cesium Irradiator Replacement Program.

The radioactive contents requested by ES for shipment in the Model 10-160B Type B Radwaste

Shipping Cask (10-160B) are Cs-137 sealed sources permanently installed in a self-shielded

Model IBL-437C Irradiator. The non-radioactive contents consist of one IBL-437C Irradiator, a

two-piece cribbing assembly, and nylon slings for loading and unloading the Irradiator and

cribbing in the 10-160B. The cribbing assembly was designed by ES to protect and minimize

movement of the Irradiator within the 10-160B containment body.

The 10-160B will be used by DOE to collect Model IBL-437C Irradiators for intra-site shipment

or shipment for disposal at the Nevada National Security Site (NNSS).

The safety performance of the 10-160B with the Model IBL-437C Irradiator content

configuration and conditions described in this SER, meet the applicable requirements of

10 CFR Part 71.

1. GENERAL INFORMATION AND DRAWINGS

By email [1] dated January 24, 2018, the Idaho Operations Office (ID) requested an amendment

to DOE CoC 9204, Revision 10 to authorize use of the 10-160B package for shipment of IBL-

437C Irradiators containing up to 5,100 Ci of Cs-137. The application supporting the ID request,

IBL-437C Irradiator Shipping Addendum for Model 10-160B (Addendum to the SARP), was

prepared by ES and submitted to DOE PCP on June 20, 2018.[2] This Addendum was

subsequently revised and supplemented by ES. Revision 1[3] of the Addendum was submitted by

ES to DOE on February 26, 2019 and supersedes the initial issue dated June 20, 2018 in its

entirety.

There are no changes to the existing components of the 10-160B package design; consequently,

PCP staff’s review focused on the internal configuration required to use the package to ship an

IBL-437C Irradiator (hereinafter referred to in this SER as “Irradiator,” unless otherwise

specified). The internal configuration was evaluated as package contents and also as important

to safety packaging components.

The IBL-437C Irradiator was previously authorized by the US Department of Transportation

(DOT) Competent Authority Certification (CAC) number USA/0370/B(U), for import/export

shipment in Package Model COQUE CC 30. The DOT CAC was based on their revalidation of

the French Certificate of Competent Authority F/302/B(U). The IBL-437C is currently

authorized by DOT for CAC USA/0674/B(U)-96 for import/export shipment in Package Model


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F430. This DOT CAC is based on their revalidation of the Canadian Certificate of Competent

Authority CDN/2076/B(U)-96. The information in these CACs was used by the applicant and

PCP staff to fill information gaps about the IBL-437C.

DOE PCP staff performed a review of the general information and drawings provided in the

Addendum for compliance with applicable sections of 10 CFR Part 71, Subpart D.

Package

The package consists of the 10-160B loaded with: one IBL-437C Irradiator, a two-piece

cribbing assembly, and nylon slings. The radioactive contents, Cs-137 sources, are permanently

installed in the Irradiator.

Packaging

There are no changes to the existing components of the 10-160B package design for the

Irradiator shipment configuration. However, the Irradiator provides supplemental shielding to

meet package dose rate requirements for Normal Conditions of Transport (NCT) and

Hypothetical Accident Conditions (HAC). The cribbing assembly provides structural protection

for the Irradiator and 10-160B containment boundary during NCT and HAC.

Irradiator

The applicant did not include engineering or fabrication drawings (in English) of the Irradiator,

but was able to consolidate information from legacy drawings, the Operator’s Manual, DOT

CACs, and other references, and supplemented this documentation with field measurements from

a disassembled Irradiator to provide a sufficient description and sketches with dimensions for

structural and shielding analysis.

Addendum Figure 1-1 is a cross-sectional view of the Irradiator with its components identified.

Figure 1-2 is an isometric view of the Irradiator without external cosmetic housings. This figure

represents the shipping configuration. Figure 1-3 is a top view (cut-away) of the irradiation

position and loading positions of the product canister (i.e., blood specimens).

The approximate material thicknesses of key components are: 6 mm (0.24 in. steel jacket for the

lead), 173 mm (6.8 in. lead at its thinnest location), and 15 mm (0.6 in. top plate). The applicant

assumed lead thickness of 6 inches in the shielding evaluation for NCT.

The applicant measured the following key components of the load path in response to PCP Staff:

the lower support plate as well as the bolts holding the lower support plate to the Irradiator and

the bolts joining the lower support plates to the irradiator legs.

The overall nominal dimensions of the Irradiator evaluated in the Addendum are (length, width,

& height): 60 cm (23.6 in.) x 59.2 cm (23.3 in.) x 107 cm (42.1 in.) and the weight is 2,050 kg

(4,519 lb.).


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Cribbing Assembly

The cribbing assembly design is defined by Drawing No. DWG-5164319-ST-0001, IBL-437C

Wood Cribbing Wood Base and Cap to hold the Irradiator at the approximate center of the

package cavity and to protect the Irradiator and package from damage.

The cribbing assembly consists of a top and bottom assembly which is constructed from

construction-grade timber and exterior plywood. The wood is joined with commercial glue and

fasteners. The bottom assembly houses the Irradiator. Once the packaging is loaded with the

bottom assembly and Irradiator, the top assembly is inserted in an opening at the top of the lower

cribbing assembly used to cap the Irradiator in the bottom assembly. The top assembly is not

fastened to the lower assembly.

The maximum overall dimensions of the cribbing assembly, are 66 in. diameter x 78 in. in height

and estimated weight is 1,615 lb. The estimated weights of the lower assembly and top assembly

are 1,427 and 188 lb. respectively. Addendum Figure 1-4 is an illustration of the Irradiator in the

cribbing assembly.

Contents

The radioactive contents consist of three double encapsulated Cs-137 capsules. The sources are

certified by the French Competent Authority as “special form” radioactive material [F/037/S-

96(Ik)], but were not subsequently certified by the DOT. Based on the French special form

certificate, the source material is a solid form of cesium chloride and double encapsulated in

stainless steel casing 1 mm thick (for each encapsulation) and the overall dimensions of a source

is 20 mm in diameter and 308.5mm in length. Each source contain a maximum of 1,700 Ci of

Cs-137 for a total payload of 5,100 Ci. The sources are permanently installed in the self-shielded

Irradiator.

The maximum content decay heat is 24.7 watts. The applicant’s explanation of how the decay

heat value was derived is located in the footnote of Addendum Table 1-2,

Non-radioactive contents consist of the self-shielded Irradiator, wooden cribbing, steel lifting

eyes (part of wooden cribbing), and nylon slings (for loading/removing the payload).

The location and position of the radioactive contents within the Irradiator is illustrated in

Addendum Figures 1-1, Cross-Sectional View of IBL-437C Irradiator and 1-3 Top View (cut

away) IBL-437C in Irradiation Position and Loading Position. The location and position of the

Irradiator within the cribbing is illustrated in Figure 1-4, Quarter Cut-Away of IBL-437C in

Wooden Cribbing.

The maximum weight of the Irradiator and wooden cribbing is 6,191 lb., with an addition 58 lb.

of nylon slings.


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Based on the PCP staff review of the statements and representations in the Addendum, staff

concludes that it provides an adequate basis for the evaluation of the package against 10 CFR

Part 71 requirements for each technical discipline that follows in this SER.

2. STRUCTURAL

PCP staff performed a review of the structural evaluation in the Addendum for compliance with

10 CFR Part 71. The review focused primarily on the structural effects on the Irradiator during

NCT and HAC drop impacts as well as interactions between the Irradiator and its associated

wood cribbing during HAC.

The applicant used the g-loading evaluation from the 10-160 Consolidated Safety Analysis

Report (CSAR) from the NCT and HAC free-drop tests for end, side, and corner drop

orientations of the package with 14,250 lb. payload, and scaled these g-loadings for the Irradiator

configuration payload weight of 6,191.5 lb. The resulting scaled g-loading values were used by

to the calculate impact forces applied to the Irradiator configuration for NCT and HAC in the

same drop orientations of the package as the CSAR, to determine the amount of lead slump in

the Irradiator shield, and a top-down drop orientation to evaluate the 10-160B lid bolts for

tension and shear.

There are no modifications required to the existing 10-160B packaging components for the

Irradiator configuration. However, the Irradiator and cribbing assembly are both package

contents and important to safety packaging components for this shipment configuration. The

radioactive material is three special form Cs-137 capsules permanently installed in the Irradiator.

The Irradiator shielding is an important to safety packaging component required to supplement

the 10-160B package shielding to the meet the dose rate requirements during NCT and HAC.

The wood cribbing assembly is an important to safety packaging component required to protect

the Irradiator and 10-160B containment system performance under HAC. The crush depth of the

cribbing must not reach the lockup depth, in order for the cribbing to protect the package

(i.e., absorb impact).

PCP staff reviewed the applicant’s structural calculation (CALC-5164319-ST-0001, Revision 0)

relative to quantifying structural integrity and damage states of the wood cribbing and the

Irradiator contents for applicable NCT and HAC loadings. The calculation was revised several

times (CALC-5164319-ST-0001, Revision 3) during the course of the review to resolve staff’s

comments to include: 1) a lead slump analysis of the Irradiator shield body, 2) a finite element

analysis of the support structure that holds the Irradiator shield drum in place, and 3) an

evaluation of the bolts holding the 10-160B secondary lid in place in a top-down free-drop.

Mechanical Properties of Materials

There are no codes or standards referenced in the Addendum for the materials or construction of

the Irradiator shield. Instead, the applicant assumed that the lead is ASTM B29 and the shield


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jacket is composed of mild steel no stronger than American Society for Testing and Materials

(ASTM) grade A36 and, and determined allowable stress intensities assuming a material

temperature of 300°F. The 300°F temperature bounds the bulk average gas temperature for NCT

(188°F) and HAC (290°F) used the CSAR. The applicant did not perform a detailed thermal

analysis to more accurately determine the Irradiator configuration temperature for NCT and

HAC because the heat load of the contents, 24.7 watts, are much lower than the 200 watts heat

load used in the CSAR to determine these bulk average gas temperatures. PCP staff concurs that

the assumptions of the materials properties and allowable stresses at 300°F is acceptable without

a detailed thermal analysis.

Based on NUREG/CR 6407, Classification of Transportation Packaging and Dry Spent Fuel

Storage System Components According to Importance to Safety, gamma shield components

should be Quality Category B (QL2) components. The applicant classified only the lead and

shield drum support plate as QL2 components, and the steel skin surrounding lead shielded body

and lead shielded drum components Quality Category C (QL3) components. PCP staff’s opinion

is that the steel skin should be QL2; however, the applicant does not have material test reports

for the steel to meet the Quality Assurance (QA) requirements for QL2. Nevertheless, given that

DOT has certified several Type B packages (CACs 0370 and 0674) that credit only the Irradiator

shielding design to meet the NCT and HAC dose rate requirements, and that the 10-160B design

includes gamma radiation shielding, staff accepts the applicant’s QL-3 classification. The yield

strength of lead, used by the applicant in the slump analysis, is taken as the plastic flow stress

documented in the Cask Designers Guide: A Guide for the Design, Fabrication, and Operation

of Shipping Casks for Nuclear Applications, ORNL NSIC-68 (Addendum Reference 2.10.1.5).

For the structural properties of the wood cribbing, the applicant used eastern white pine with a

maximum crushing strength of 4.8 ksi. The cribbing is constructed of white pine (or similar)

lumber, in combinations of both ½ and ¾ inch exterior grade plywood and common grade

dimensional lumber (e.g., 2×6s, 2×8s, and 4×4s). The cribbing is used as a compression only

component, with the load path oriented parallel to the grain of the wood.

NCT

Heat, cold, internal and external pressure, water spray, compression, and penetration are stated to

have no significant effect on the performance of the shielding function of the Irradiator

configuration. The applicant refers to the appropriate standards and the long shipping history of

Irradiators to demonstrate compliance with vibration and low temperature brittle fracture are

addressed using the shipment history of the IBL-437C and reference to appropriate standards.

The applicant performed a lifting analysis calculation to demonstrate that the cribbing holds

together during lifting of the wood cribbing assembly. The lifting arrangement for the Irradiator

was previously evaluated by the manufacturer, and remains unchanged and was therefore not

evaluated by the applicant or reviewed by PCP staff.

The applicant evaluated NCT free-drops of the package from 1 ft. in the following drop

orientations: end, side, and corner. Because the NCT free-drop height and payload impact


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velocity are significantly less than for the HAC free-drop test, the forces the Irradiator exerts on

the wood cribbing during NCT and the minimum wood area required to resist crushing of the

cribbing by the Irradiator for each NCT free-drop orientation is less than the wood area for HAC

drop orientations, the applicant’s HAC drop analysis is bounding for NCT. The same reasoning

applies to lead slump in the Irradiator shield; that is, NCT drops will result in negligible lead

slump in the shielded drum due to significantly lower decelerations. The package will not be

significantly damaged due to impact of the Irradiator configuration during an NCT free-drop.

HAC

The applicant evaluated HAC free-drops of the package, from 30 ft. in the following drop

orientations: end (bottom) and side. According to the CSAR, the end drop imparts the largest

force (e.g., 2,508,000 lbf) and the corner drop the smallest (e.g., 1,014,600 lbf); therefore, the

corner drop was omitted from the applicants’ analysis because it is bounded by the end drop.

The scaled g-loadings in the applicant’s structural analysis for HAC impacts are appropriately

amplified and used for the Irradiator configuration. In addition, the applicant evaluated the 10-

160B lid bolts in a top-down free-drop orientation because of the concentrated load on the

secondary lid.

The puncture test, §71.73(c)(3), was omitted because of the minor effect on the package contents

compared to free-drops.

The scope of applicant’s structural calculation for HAC included the wood cribbing that protects

the package containment and Irradiator, the packaging secondary lid bolts, lead slump in the

Irradiator shield, and deflection of the Irradiator drum.

Cribbing

The only area in the cribbing assembly where significant wood crushing is expected is the under

the Irradiator feet during the end drop orientation. The applicant compared the crush depth in the

cribbing from free-drop impacts with the wood lockup depth (i.e., the point the wood effectively

no longer crushes, that is, absorbs impact). For the package containment and Irradiator to be

protected during impact, the cribbing components must not reach lockup depth. Given the large

margin to lockup depth and the typical crush strength of the common dimensional lumber, PCP

staff concurs that the Addendum and its structural calculation demonstrate that lockup will not

occur given the weight of the Irradiator and the design of the cribbing.

10-160B Lid Bolts

The applicant demonstrated, by calculation, that the lid bolt stresses in a top-down drop

orientation are within their stress criteria limits, for the 6,200 lb. load applied to the secondary lid

over an area defined by the upper cribbing assembly. PCP staff concurs with the applicant’s

results.

Lead Slump

The applicant evaluated the Irradiator shielding as a simple solid cylinder of lead: 4,730 lb., 5.83

in. in radius and 30.2 in. in length, and dropped from a height of 30 feet. Slump in this analysis


Docket 18-22-9204

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is calculated using a lead slump flow stress threshold of 5,000 psi, for the expected strain rates in

a regulatory drop, based on the Cask Designers Guide: A Guide for the Design, Fabrication, and

Operation of Shipping Casks for Nuclear Applications, ORNL NSIC-68 (Addendum Reference

2.10.1.5). The applicant evaluated a side drop only and obtained a slump value of 1.93 in. This

value bounds the slump calculated using equation 2.11b of Cask Designers Guide.

The real effective impact area of the lead in an end drop is greater than the area used in the side

drop (176.7 in2), so that the side drop result of lead slump should be bounding. Although no

evaluation of the actual shield body steel stresses and strains is included in this simplified

analysis, the evaluation does establish a basis for the 2 inches of lead loss assumed in in the

shielding evaluation for HAC is conservative. For NCT, given the results of the shield drum

support plate evaluation below, damage of the Irradiator shield for NCT should be negligible.

Irradiator Drum Deflection

The only portion of the Irradiator shielding body in which stresses and strains are calculated by

the applicant is for the shield drum support plate during a bottom-down drop of the package.

PCP staff concurs this drop orientation is the most critical for retaining the shield drum. Staff

concurs that the analysis demonstrates the cumulative NCT and HAC deformation will not

produce a streaming path that will result in higher dose rates than assumed in the shielding

evaluation.


concludes that the addition of these contents has no adverse impact on the structural safety

performance of the 10-160B. The requirements of 10 CFR Part 71 for NCT and HAC are

satisfied, provided that the Irradiator and cribbing configuration are loaded in the 10-160B as

described and evaluated in the Addendum.

3. THERMAL

PCP staff performed a review of the thermal evaluation in the Addendum for compliance with

10 CFR Part 71. The review focused on the decay heat in the packaging from the Irradiator

configuration. Gas generation and pressure calculations are included in the Containment

sections of the Addendum and this SER.

There are no changes to the thermal design of the current 10-160B packaging. The CSAR only

credits conduction through air in the package cavity so that the wood cribbing assembly housing

the Irradiator has little effect on the heat transfer properties.

The CSAR provides the thermal analysis of the package with a generic heat load of 200 watts.

The maximum heat load of Irradiator configuration contents is only 24.7 watts and is described

in Addendum Section 3.1 of the Addendum.

The Irradiator is constructed with a lead core is encased in steel. There are no seals in the

Irradiator. The sources installed in the Irradiator are in special form. Since the contents are not

sensitive to the maximum bulk air temperature evaluated for the original package design and the


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temperature and the decay heat load for the Irradiator configuration is significantly less that the

maximum heat load for the package design, no further thermal analysis was necessary.


concludes that the addition of these contents has no adverse impact on the thermal safety


satisfied, provided that the Irradiator and cribbing configuration are loaded in the 10-160B as


4. CONTAINMENT

PCP staff performed a review of the containment evaluation in the Addendum for compliance

with 10 CFR Part 71. The review focused on the Irradiator configuration with respect to the

material at risk, and gas generation and pressure calculations.

There are no changes to the containment design or boundary of the current 10-160B packaging.

The 10-160B containment is a Category II design, which allows up to 3,000 A1 or A2 of normal

form or special form radioactive materials and no more than 30,000 Ci [see NUREG 1815,

Recommendations for Protecting Against Failure by Brittle Fracture in Ferritic Steel

Shipping Containers Up to Four Inches Thick and Regulatory Guide 7.11, Fracture Toughness

Criteria of Base Material for Ferritic Steel Shipping Cask Containment Vessels with a Maximum

Wall Thickness of 4 Inches (0.1 m)]. The Irradiator configuration included 5,100 Ci of Cs-137 in

special form; therefore this content is bounded by the CSAR containment evaluation.

The applicant performed a gas generation and pressure calculation (CALC-5164319-PR-0001,

Revision 1) of the Irradiator configuration to demonstrate that flammable gases are less than 5%

by volume in any void space in the containment within 1 year, and that maximum normal

operating pressure and maximum pressure under HAC are within design limits and CSAR

evaluation.

The applicant addressed combustible gas generation in Addendum Section 4.8 and a supporting

calculation.

The wood cribbing and nylon slings are the sole hydrogenous materials available for radiolytic

hydrogen generation. Based on the applicant’s calculation results, it would take at least

3.64E+05 years to reach 5% volume of hydrogen in the package void; therefore flammable gas

generation is not a safety issue for the Irradiator configuration. PCP staff reviewed the gas

generation calculation and noted that the Irradiator does contain rubber, insulation on wiring, and

likely a small amount of grease in bearings; however, these materials and the wood cribbing are

not likely to outgas from thermal degradation at maximum temperatures for NCT or HAC, or

produce a flammable gas mixture in the package cavity. PCP staff concurs that the time to

generate a flammable gas mixture under worst case conditions is lengthy enough that no shipping

window is required.


Docket 18-22-9204

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The maximum normal operating pressure (MNOP) calculated for the Irradiator configuration is

to 8.25 psig. This pressure is bounded by the MNOP of 31.2 psig for the package design, and is

therefore acceptable to PCP staff.

The maximum pressure for HAC calculated for the Irradiator configuration is to 11.2 psig. This

pressure is bounded by the pressure limit of 94.3 psig for the package design, and is therefore

acceptable to PCP staff.


concludes that the addition of these contents has no adverse impact on the containment


satisfied, provided that Irradiator and cribbing configuration are loaded in the 10-160B as


5. SHIELDING

PCP staff performed a review of the shielding evaluation in the Addendum for compliance with

10 CFR Part 71. The review focused on package dose rates with the Irradiator configuration of

5,100 Ci of Cs-137, for NCT and HAC.

There are no changes to the shielding design of the current 10-160B packaging. The Irradiator

shielding design was sufficient to ship the Irradiator in un-shielded Type B packages certified by

DOT for import/export (e.g., CACs 0370 and 674).

The applicant’s shielding analysis demonstrates compliance with the radiological requirements in

§71.47 for NCT and §71.51 for HAC, for shipment by exclusive use.

The applicant performed a shielding analysis of the Irradiator configuration in the 10-160B for

NCT and HAC by computer model (MCNP6.1). The Irradiator is supported and centered axially

and vertically in the containment cavity by the wood cribbing assembly. The applicant assumed

an initial lead thickness of 6 in. (i.e., the minimal chord length from any Cs-137 capsule through

the lead shielding) for the Irradiator shield for NCT and a final shield thickness of 4 in. after

HAC, based on the structural calculation supporting the Addendum.

Table 5-1 in the Addendum summarizes the NCT dose rates for the 10-160B loaded with the

Irradiator configuration. The maximum NCT dose rates from this case are 1.49 E-4 mrem/hr. at

contact on the bottom of the 10-160B and 6.00 E-06 mrem/hr. at 2 meters from the top of the

10-160B. The maximum NCT dose rates for this content in the 10-160B are significantly below

the allowable limits of 10 CFR 71.47(b).

Table 5-2 in the Addendum summarizes the dose rates for HAC with the Irradiator in the

worst-case geometric configuration following an accident with the loss of 2 in. of lead thickness

in the shield. The maximum HAC dose rate of 0.46 mrem/hr. at 1 meter from the package

surface is measured from the top of the package with the Irradiator positioned against the edge of


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the inner top surface of the containment cavity and sidewall. The maximum HAC dose rate for

this content in the 10-160B is well within the allowable limit of 10 CFR 71.51.

The energy deposition rate in Addendum Section 5.3.3 from the contents to the wood cribbing

and nylon straps was used to calculate the time to reach 5 vol. % hydrogen in the 10-160B cavity

in the Addendum Containment Evaluation.


concludes that the addition of these contents has no adverse impact on the radiation shielding

safety performance of the 10-160B. The requirements of 10 CFR Part 71 for NCT and HAC are

satisfied, provided that Irradiator and cribbing configuration are loaded in the 10 160B as


6. CRITICALITY

Not applicable. The Irradiator contents, Cs-137are non-fissile.

7. PACKAGE OPERATIONS

PCP staff performed a review of the package operations evaluation in the Addendum for

compliance with 10 CFR Part 71. The review focused on the loading and unloading the

Irradiator and cribbing assemblies in the packaging.

There are no changes to the operation procedures of the current 10-160B packaging (e.g.,

closure, leakage testing, etc.) The operations procedure in Addendum Chapter 7 are required to

supplement the package loading and unloading instructions in the CSAR.

The procedures for loading and unloading the Irradiator and its cribbing were reviewed by PCP

staff and are consistent with the CSAR and sufficiently clear.

Based on the PCP review of the statements and representations in the Addendum, staff concludes

that the addition of these contents has no adverse impact on the safety performance of the

10-160B. The requirements of 10 CFR Part 71 for NCT and HAC are satisfied, provided that the

provided that Irradiator and cribbing configuration are loaded in the 10 160B as described and

evaluated in the Addendum and Operating Procedures in Chapter 7 of the CSAR, as

supplemented by Addendum Chapter 7

8. ACCEPTANCE TESTS AND MAINTENANCE PROGRAM

PCP staff performed a review of the acceptance tests and maintenance evaluation in the

Addendum for compliance with 10 CFR Part 71. The review focused on the new important to

safety packaging components for the Irradiator configuration.

There are no additional acceptance tests and maintenance activities required for the 10-160B for

this Addendum to the CSAR.


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The acceptance criteria for the Irradiator and cribbing is visual examination in accordance with

Addendum Section 8.1.1; a structural check of the cribbing for loose joints in Section 8.1.2; and

Irradiation shielding integrity measurement in Section 8.1.5. If the average gamma does rate

measured at the surface of the Irradiator exceeds 2.5 mrem/hr., then the Irradiator is not

acceptable for shipment in the 10-160B. Dose rates above this 2.5 mrem/hr. indicate failure of

the Irradiator shield or special form capsule.

The Irradiators were previously fabricated and are retired from service. The Irradiator shielding

does not require maintenance.


concludes that the addition of these contents has no adverse impact on the safety performance of

the 10-160B. The requirements of 10 CFR Part 71 for NCT and HAC are satisfied, provided that

the Irradiator and cribbing are accepted for shipment in the 10-160B as described and evaluated

in the Addendum. Irradiators with an average surface doss rate greater than 2.5 mrem/hr. shall

not be accepted for shipment in the 10-160B.

9. QUALITY ASSURANCE

PCP staff performed a review of the quality assurance (QA) evaluation in the Addendum for

compliance with 10 CFR Part 71, Subpart H. The review focused on the new important to safety

packaging components for the Irradiator configuration.

The Addendum supplements the QA requirements for the 10-160B, for the Irradiator and

cribbing assembly.

The roles and responsibilities of the organizations performing QA related activities are defined in

the Addendum, Section 9.3.1. The applicant, EnergySolutions, has a Subpart H QA program

approved by the DOE Headquarters Certifying Official (HCO), Approval No. 0001. The

Addendum, drawings, and supporting calculations were prepared for the applicant by their

subcontractor, Atkins (Richland WA). Atkins worked under the applicant’s QA program for this

work, since they do not have a QA program approved by the DOE HCO.

The Quality Levels of the Irradiator configuration components are defined in Addendum, Table

9-2.



the 10-160B. The requirements of 10 CFR Part 71, Subpart H, are satisfied, provided that the

provided that the Irradiator and cribbing are procured, fabricated, used, maintained, and loaded

in the 10-160B as described and evaluated in the Addendum.


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Condition of Approval

The following changes to the CoC are required to implement the conditions in this SER:

• Section 5(a)(2) add the following description: The IBL-437C Irradiator configuration

consists of a single self-shielded Model IBL-437C blood irradiator and wood cribbing

assembly (with nylon slings). The overall dimensions of the Irradiator are approximately

(length, width, & height): 23.6 in. x 23.3 in x 42.1 in. and it weighs 4,519 lb. The overall

dimensions of the cribbing assembly, with Irradiator, are 66 in. diameter x 78 in. in height

and estimated weight, without Irradiator, is 1,615 lb. The estimated weights of the lower

assembly and top assembly are 1,427 and 188 lb. respectively. The Irradiator shield and

wooden cribbing design (DWG-5164319-ST-0001) are required to transport the contents

specified in 5(b)(vvi) of this Certificate, for disposal. The configuration weighs

approximately 6,191 lb., with an additional 58 lb. of nylon slings rigged to the Irradiator and

cribbing for ease of removal.

• Section 5(a)(3), add drawing: DWG-5164319-ST-0001, Transport of IBL-437C Irradiator in

10-160B Cask Cribbing Assembly & Details, Sheets 1 through 8, Rev 0

• Section 5(b)(1), add content information: (xi) For shipment in the Model IBL-437C

Irradiator, Cs-137 in special form capsules.

• Section 5(b)(2):

o (vi), add content information: … The maximum weight of the IBL-437C Irradiator,

cribbing, and slings is approximately 6,249 lb.

o (xv) Each IBL-437C Irradiator shall contain no more than 5,100 Ci of Cs-137.

• Section 5(d):

o Revise (10) as follows: Revision 10 of this certificate may be used until March 31,

2020.

o Add (23) as follows: The cribbing design for the IBL-437C Irradiator shall be

fabricated and inspected per the drawings specified in Reference 8 (Addendum) and

this Certificate.

o Add (24) as follows: The average surface dose rate of the IBL-437C Irradiator shall

not exceed 2.5 mrem/hr. The Irradiator meeting the average surface dose rate

requirement shall be prepared, loaded, and closed as specified in Reference 8

(Addendum)

• Section 5(e), add: IBL-437C Irradiator Shipping Addendum for Model 10-160B Type B

RADWASTE Shipping Cask, Revision 1, February 2019.

•

Conclusion



the 10-160B, and will provide reasonable assurance that the regulatory requirements of 10 CFR

Part 71 have been met, subject to the conditions above.


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REFERENCES

[1] Email, Victor Pearson (ID) to James M. Shuler, Subject: Docket Number Request,

January 24, 2018

[2] IBL-437C Irradiator Shipping Addendum for Model 10-160B Type B Radwaste Shipping

Cask, Doc. No.: ATKINS/DOE 18-001, Attachment 1, Initial Issue: June 2018

[3] IBL-437C Irradiator Shipping Addendum for Model 10-160B Type B Radwaste Shipping

Cask, Doc. No.: ATKINS/DOE 19-001, Attachment 1, Updated February 2019 (Rev. 1)

18-22-9204 ser for coc rev11 - us department of energy · two lifting lugs and two redundant...

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