nrc transmittal letter - revision 7 of the rh-tru 72-b

NRC Transmittal Letter - Revision 7 Of The RH-TRU 72-B Shipping Package Application.TS:14:03021 UFC:5822.00 November 10, 2014 ATTN: Document Control Desk Director, Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Subject: REVISION 7 OF THE RH-TRU 72-B SHIPPING PACKAGE APPLICATION,
DOCKET NO. 71-9212
Dear Sir or Madam: Nuclear Waste Partnership LLC (NWP), on behalf of the U.S. Department of Energy, hereby submits Revision 7 of the application for a Certificate of Compliance (CoC) for the Remote- Handled Transuranic (RH-TRU) 72-B Packaging, U.S. Nuclear Regulatory Commission Docket No. 71-9212. The application consists of the following documents:
• RH-TRU 72-B Safety Analysis Report (SAR), Revision 7 • Remote-Handled Transuranic Waste Authorized Methods for Payload Control
(RH-TRAMPAC), Revision 3 • RH-TRU Payload Appendices, Revision 3.
The primary initiatives included in this application consist of a complete revision to, and consolidation of, historical and licensing basis thermal analyses, addition of new activity-based limits to address Normal Conditions of Transportation dose rate requirements and addition of a new criticality analysis that addresses non-homogeneous Low Enriched Uranium payload configurations. The revision of the thermal analysis also required an update of structural analyses to address revised temperatures and temperature gradients. Appropriate changes to the RH-TRAMPAC and RH-TRU Payload Appendices, consistent with the above discussed items, have also been incorporated. In addition to the above, a limited set of revisions have been incorporated, which provide increased operational flexibility or otherwise improve operability of the package, achieve consistency with certain initiatives that have been implemented in contact-handled transuranic waste package applications and provide a previously omitted RH-TRU waste canister buckling evaluation. Other revisions are generally limited to minor editorial clarifications and conversion of all SAR general arrangement drawings to NWP documents. A key result associated with the revised thermal analysis is that the 50 watt maximum decay heat limit for Removable Lid Canister (RLC) and Fixed Lid Canister (FLC) payloads has now been increased to at least 90 watts. Decay heat values above 90 watts, up to a maximum of 270 watts, are allowed depending on the actual density of the payload. As qualitatively discussed in prior applications, this is reflective of the fact that as payload densities increase, conductivity will also increase and the ability to transfer heat out of the payload will be
P.O. Box 2078 Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 Fax: (575) 234-7083
Document Control Desk -2- TS:14:03021 enhanced. The decay heat limit for neutron shielded canister payload configurations remains at 50 watts, independent of payload density. This limitation on wattage is required to maintain the temperature of the high-density polyethylene neutron shield material within acceptable limits. Additional detail identifying the changes that have been made to the SAR, RH-TRAMPAC, and RH-TRU Payload Appendices is presented in tabular form in Attachment A This letter includes the following attachments:
• Attachment A – Summary of Revisions • Attachment B – Revised Documents • Attachment C – Supplementary References.
All technical changes are indicated by right-bars in the margin of the documents (“|”) and are summarized in Attachment A. The revised documents are provided in Attachment B. Supplementary references in the form of electronic analysis files are provided in Attachment C. To facilitate implementation, it is requested that the current package CoC be valid for use for at least one year from the date of issuance of the revised CoC. If you have any questions regarding this submittal, please contact Mr. R. A. Johnson of my staff at (360) 438-6145. Sincerely, T. E. Sellmer, Manager Packaging TES:clm cc: J. R. Stroble, CBFO J. C. Rhoades, CBFO H. Akhavannik, USNRC
P.O. Box 2078 Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 Fax: (575) 234-7083
ATTACHMENT A – Summary of Revisions
Summary Pg. RH-TRU 72-B SAR, Revision 7 A-2 RH-TRU 72-B SAR Drawing X-106-500-SNP, Revision 6 A-15 RH-TRU Waste Canister, Fixed Lid SAR Drawing X-106-501-SNP, Revision 5 A-17 RH-TRU Waste Canister, Removable Lid SAR Drawing X-106-502-SNP, Revision 3 A-18 Neutron Shielded Canister, NS15 & NS30 SAR Drawing X-106-503-SNP, Revision 1 A-19 RH-TRAMPAC, Revision 3 A-20 RH-TRU Payload Appendices, Revision 3 A-23
October 2014 A-1
RH-TRU 72-B SAR, Revision 7, October 2014
Section Page Change Description Justification
General Revised title page and spine for revision and date. Administrative change. No impact to safety basis.
General Changed all references to 10CFR71 to reflect the current 1/1/14 edition.
Administrative change. No impact to safety basis.
General Changed all references to ANSI N14.5 to reflect the current 2014 edition.
1.0 1.1-3 thru 1.1-5
1.1 1.1-2 Revised last paragraph of section from “Subpart E of 10 CFR 71” to “10 CFR 71.4”. Also reworded to state that the 72-B package is designed as a Type B(M)F-96 package.
1.2.1.1 and 1.2.1.5
1.2-1 and 1.2-5
Revised to refer to the new 270-watt decay heat limit.
Revision reflects newly established 270-watt maximum decay heat allowed in an RH-TRU waste canister. The wattage limit is established in Chapter 3, Thermal Evaluation, and resultant temperatures are shown to be acceptable there and in Chapter 2, Structural Evaluation. No impact to safety basis.
1.2.1.1.1 1.2-1 Revised nomenclature for O-ring compound from “RR0405-70” to “R0405-70”, consistent with manufacturer’s name change for the formulation.
Manufacturer’s name change does not reflect any change in material formulation, but rather is a clarification where “RR” represents a historically used convention for internal tracking and “R” represents a final product available for resale. No impact to safety basis.
October 2014 A-2
1.2.2 1.2-6 Revised to identify that the design details of the lid alignment pins are optional as is the presence of the pins during transportation.
This change is being made only for operational improvement/flexibility. The alignment pins are operational aids only and serve no purpose during transport. No impact to safety basis.
Figures 1.2-1 and
Provides improved/enhanced versions of Figures 1.2-1 and 1.2-2.
Administrative change. Revised only to better clarify which seals are a part of the containment boundary. No impact to safety basis.
1.3.1 Dwg X- 106-500- SNP (Rev 6), Dwg X- 106-501- SNP (Rev 5), Dwg X- 106-502- SNP (Rev
3) and Dwg X-106-503- SNP (Rev
1)
New Packaging General Arrangement Drawings are provided. All drawings have been converted to be NWP controlled documents. All changes are clouded and, with the exception of the conversion to NWP, changes are limited to X-106- 500-SNP sheets 1, 2, 4, 5 and 8 and X-106-503- SNP sheet 1.
SAR drawings have been consistently revised to reflect that they are now NWP documents. Other changes are limited to identification of optional items and/or their optional configurations and to correctly identify the Rainier Rubber butyl compound used for containment seals as R0405- 70. For drawing X-106-503-SNP depicting the Neutron Shielded Canisters, an editorial change is made in the terminology referring to the RH-TRU removable lid waste canister. Specific changes to the SAR drawings identifiable by drawing sheet and zone are provided immediately after this summary of SAR revisions. No impact to safety basis.
1.3.2 1.3.2-4 and 1.3.2-5
Added and defined acronyms for FEM, FGE, LEU, NCT and NSC. Revised definition of “payload” and “payload canister” to be consistent with terminology used throughout the Rev. 7 application.
Administrative change for completeness and consistency. No impact to safety basis.
October 2014 A-3
2.1.2.2.2.1 and
2.1-5 and 2.1-7
1) Updated fatigue analyses to reflect a new maximum normal condition enveloping temperature, 2) revised the approach used to address potential fatigue of bolted fasteners and 3) added a canister buckling evaluation.
1) A small increase in maximum temperature from 200 to 210 °F is shown to have no significant impact on fatigue analysis results. Margins remain comfortably positive. 2) Recognizing that bolts are redundant and that cyclic stresses in the bolts are due predominantly to preload, the prior requirement to replace bolts after a pre- established number of operating cycles is not necessary. This is replaced by a new requirement to replace all bolts of a given type used on a packaging in the unexpected event that any single bolt of that type fails during installation. 3) The SAR previously indicated in several places that canister buckling evaluations were included in SAR Appendix 2.10.5. Such evaluations not actually provided there have been added to SAR Section 2.1.2.2.3. It is now demonstrated that a buckling mode of failure is not credible for the canister. No impacts to safety basis.
2.5 2.5-1 thru 2.5-5 and 2.5-8 thru
2.5-13
Lifting and tiedown analyses have been consistently updated to address a slightly higher temperature.
The enveloping temperature now considered for analysis is 153 °F (was 143 °F). The modest reduction in material strength for this temperature change is easily accommodated and margins are shown to remain comfortably positive. No impact on safety basis.
October 2014 A-4
2.6.1 2.6-1 Revised to consider a new maximum decay heat value of 270 watts in the structural evaluation.
Chapter 3.0, Thermal Evaluations, and Chapter 2.0, Structural Evaluations, have both been revised to demonstrate acceptability of new wattage limits and resultant temperatures, which are dependent on payload configuration and/or payload bulk density. A wattage versus density curve is provided for the RLC and FLC RH-TRU waste canisters. For NSCs, the decay heat limit remains at 50 watts. No impact to safety basis.
2.6.1.1, Table 2.6- 1, Table
2.6-2
2.6-42
A new enveloping temperature of 210 °F is identified for the canister. Table 2.6-1 is updated to include material properties at that temperature. Table 2.6-2 is revised to present maximum NCT temperatures for the case of a maximum 270-watt payload decay heat load.
Chapter 2.0, Structural Evaluations, has been revised to address all temperatures and temperature gradients now established by Chapter 3.0, Thermal Evaluations. All margins of safety remain positive. No impact to safety basis.
2.6.1.2 2.6-2 thru 2.6-4
Differential expansion calculations have been updated to address new thermal analysis results.
Chapter 2.0, Structural Evaluations, has been revised to address all temperatures and temperature gradients now established by Chapter 3.0, Thermal Evaluations. All margins of safety remain positive. No impact to safety basis.
2.6.7.1 2.6-17 An editorial correction is made to properly reference a Table number.
Editorial correction only. No impact to safety basis.
2.6.7.1 2.6-23 Updated an end drop canister stress evaluation for a 10 °F increase in canister maximum temperature (from 200 °F to 210 °F).
A 10 °F increase in temperature only modestly reduces canister strength and margin of safety remains comfortably positive. No impact to safety basis.
October 2014 A-5
2.6.7.2 and 2.6.7.3,
2.6-52 and 2.6-55
Updated corner and side drop canister stress evaluations for a 10 °F increase in canister maximum temperature. Tables 2.6-27 and 2.6-33 were both editorially revised to properly indicate use of yield strength for the allowable stress limit. Proper reference is now made to SAR Section 2.1.2.2.3 for canister buckling evaluations.
A 10 °F increase in temperature only modestly reduces canister strength and margins of safety remain comfortably positive. Although not properly identified, yield strength was previously used for the allowable limit. Previously omitted canister buckling evaluations have been added which show buckling is not a credible mode of failure. No impact to safety basis.
2.6.7.2 2.6-32 Revised a previously reported 13.4 inch residual clearance to the correct value of 14.4 inches to agree with the referenced Figure 2.10.3-3.
Although conservatively low, the prior reported value was in error. No impact to safety basis.
2.7.1.1, Table 2.7-1
2.7-2, 2.7-9 and 2.7-38
A new temperature of 210 °F is identified for the payload canister and Table 2.7-1 is updated to include material properties at that temperature for use when evaluating canister stresses.
Material properties at 210 °F are needed as this is the new enveloping temperature used for the canister as determined by the new thermal analysis. Chapter 2 consistently addresses this temperature for the canister and shows that all margins remain positive. No impact to safety basis.
2.7.1.2 and 2.7.1.3,
2.7-45 and 2.7-48
Updated corner and side drop canister stress evaluations for a 10 °F increase in canister maximum temperature. Tables 2.7-18 and 2.7-24 were both editorially revised to properly indicate use of 70% of ultimate strength for the allowable stress limit. Proper reference is now made to SAR Section 2.1.2.2.3 for canister buckling evaluations.
The 10 °F increase in temperature did not affect ultimate strength and margins of safety remain unchanged. Although not properly identified, 70% of ultimate strength was previously used for the allowable limit. Previously omitted canister buckling evaluations have been added which show buckling is not a credible mode of failure. No impact to safety basis.
2.7.3.6.1 2.7-30 Deleted reference to the RH-TRU 72-B Data package, which is no longer applicable.
This change is editorial in nature. No impact to safety basis.
October 2014 A-6
2.7.4.1 2.7-32 Revised to reflect the newly established, lower HAC fire transient internal pressure.
The approach now being used to establish internal pressure led to a much reduced HAC pressure. However, for conservatism, the prior use of 300 psig is retained in subsequent Section 2.7.4.3 when establishing stress states. No impact to safety basis.
2.7.4.2 and 2.7.4.4
2.7-33 thru 2.7-35
Incorporated results of a new analysis for extreme total stress intensity range. Stress states reflect temperature changes resulting from the new thermal analyses in Chapter 3.0 of the SAR.
The methodology used for analysis remains unchanged and resultant margins remain comfortably positive. No impact to safety basis.
Table 2.7- 28
2.7-50 Updated Table 2.7-28 (presenting stresses due to internal pressure during the HAC thermal event) to reflect new temperature results.
Margins are shown to remain very large. No impact to safety basis.
Table 2.10.1-4
2.10.1-20 Revised Table 2.10.1-4 to correctly identify FEA model element numbers.
Administrative change to specify the correct element numbers as used in the FEA model. No impact to safety basis.
October 2014 A-7
3.0 3.1-1 thru 3.6.4-12
Completely revised Chapter 3.0 except for unchanged Appendix 3.6.3, Polyurethane Foam Performance Tests, and Appendix 3.6.4, Containment O-ring Seal Material Tests, where the only changes made are to consistently identify the R0405-70 Rainier Rubber butyl compound and to properly reference (within Appendices 3.6.4.2, 3.6.4.3 and 3.6.4.4) new temperature values, summary tables and figures available from the new SAR Chapter 3.0 thermal analyses. Although limited introductory and general information has been retained in certain sections of Chapter 3.0, with the exception of Appendices 3.6.3 and 3.6.4, the entire chapter is marked as having been revised.
All thermal analyses have been revised and consolidated within SAR Chapter 3.0. At a high level, although the thermal analyses have been extensively reworked, it is noted that NCT and HAC packaging temperatures previously determined and reported in the SAR for 300 watts of decay heat are somewhat less than the new results associated with a 270-watt maximum allowed decay heat. This increase in temperature for a reduced wattage is indicative of the fact that the replacement analyses are generally more conservative than the prior analyses. The more significant features of and/or reasons for the revised analyses are as follows. 1) The historical evolution of the thermal analyses led to thermal work being located in several different sections of the application and the continued inclusion of results for a 300-watt decay heat case, even though the maximum decay heat was limited to 50 watts. Results of sensitivity analyses used to respond to RAIs on earlier versions of the SAR were also included, but were not optimally integrated into the application. The revised analyses now provide consolidated thermal work in one location (SAR Chapter 3.0) and improve the overall consistency and understandability of the thermal work. 2) As an initial condition for the fire, insolation is now conservatively included. This was not done in prior applications.
October 2014 A-8
3.0 (continued)
3) All thermal properties were revisited and reconfirmed and also compared to the properties used in CH-TRU package applications. The net result was adoption of a generally more conservative set of properties for use in the 72-B thermal analyses as compared to those used in prior applications. 4) Consistent with changes that have been made to Section 2.4 of the RH-TRAMPAC (associated with the operating temperature range for filter vents) and Section 4.6 of the RH-TRU Payload Appendices (associated with payload decomposition temperatures), new allowable temperature limits have been established for the lid end of the payload canister and for the waste within the canister. 5) A revised method for establishing internal pressure within the packaging has been adopted, which demonstrates that large margins of safety exist under both NCT and HAC conditions. Using upper bound values for total gas generation (based on maintaining the 5% limit on flammable gas) and for air and condensing surface temperatures within the packaging as established by the new thermal analyses, worst case pressure build-up is shown to be very small and well within the 150 psig MNOP and 300 psig HAC pressures historically and still considered in the structural analyses.
October 2014 A-9
3.0 (continued)
6) The revised thermal analyses were also used to establish new decay heat limits for RLC and FLC waste canisters. The net result is a payload density dependent, decay heat limit ranging from 90 watts (for densities less than or equal to 12 pcf) to 270 watts (for densities greater than or equal to 100 pcf), with 90 watts being a default value for any density. This replaces the previous density independent decay heat limit of 50 watts for RLCs and FLCs. Details of this and all other changes noted above are more fully documented in the revised Chapter 3.0. No impact to safety basis.
Figure 4.1- 1 and
Provides improved/enhanced versions of Figures 4.1-1 and 4.1-2.
Administrative change. Used only to better clarify which seals are a part of the containment boundary. No impact to safety basis.
4.3 4.3-1 Revised nomenclature for O-ring compound from “RR0405-70” to “R0405-70”, consistent with manufacturer’s name change for the formulation.
October 2014 A-10
5.0 5.1-1 thru 5.7.1-28
Completely revised Chapter 5.0. Revision replaces the previous qualitative shielding evaluation, based on preshipment dose rate surveys of the package, with a comprehensive quantitative shielding evaluation that establishes a methodology for implementing activity limits to satisfy Normal Conditions of Transport and Hypothetical Accident Condition dose rate requirements. The net result is a more conservative safety basis.
October 2014 A-11
6.0 6.1-1 thru 6.1-5, 6.2-1, 6.2-2, 6.2-4, 6.2-5,
6.3-1, 6.3-3 thru 6.3-8, 6.3-15 thru
6.3-20, 6.3-27 thru
6.3-29, 6.4-1 thru
6.4-13, 6.4-29 thru
6.4-40, 6.5-2 thru
6.5-4, 6.5-6, 6.5-7,
and 6.6.1-15
Revised Chapter 6.0 to add a Case E criticality evaluation.
Addition of Case E is to augment the previously authorized Case D analysis for homogeneous Low-Enriched Uranium (LEU) waste to address heterogeneity within the waste matrix. Both Case D and E are applicable to not machine compacted LEU with no restriction on special reflector materials. Evaluation of heterogeneous waste configurations in the form of spheres and cylinders in a lattice arrangement results in the Case D enrichment limit of 0.96 wt% U-235 FEM applying to all LEU waste forms with either a particle/lump characteristic dimension that is small (i.e., less than 0.039 inches) and/or large (i.e., greater than 2.36 inches). Case E applies to waste forms without a particle/lump size restriction, but limits the net contents weight to 3,100 pounds at a reduced enrichment limit of 0.84 wt% U-235 FEM. Rather than addressing the difficult concept of defining when a waste form is or is not “homogeneous” and/or “heterogeneous”, the differentiator was chosen to enable waste forms to be readily characterized as meeting either the Case D or Case E requirements. As such, all authorized LEU payloads are shown to be safely subcritical. No impact to safety basis.
October 2014 A-12
7.1.2 7.1-2 and 7.1-3
Revised to allow for the option of lid alignment pins not being present during transport.
This change is being made only for operational improvement/flexibility. The alignment pins are operational aids only and serve no purpose during transport. No impact to safety basis.
7.1.2.27 7.1-4 Revised wording to specifically identify use of a nut when rendering impact limiter lift devices inoperable as tiedowns and to be consistent with SAR drawing note 40.
Administrative change for consistency. No impact to safety basis.
7.4.1.2 7.4.1-1 and 7.4.1-2
Modestly revised pressure rise leakage rate test for added operational flexibility.
Changes are for operational flexibility only. No impact to safety basis.
8.1.3.8, 8.2.2.6
8.1-8, 8.2-6 Revised title of ANSI N14.5 Section 6.3.2 to agree with now referenced 2014 edition of N14.5.
8.2.1.3 8.2-1 and 8.2-2
Clarified which components constitute the entire IV interior surface. Component names previously used were an inadvertent carryover from CH package terminology. Terminology is now consistent with the RH drawings and other text in the RH SAR. A requirement that non- conformances be recorded and dispositioned in accordance with the cognizant quality assurance program has also been added.
These changes are strictly editorial in nature. No impact to safety basis.
8.2.3.1 8.2-7 Replaced the prior, cyclic based bolt replacement requirement with a requirement to replace all fasteners of a given type currently in use on a packaging in the unanticipated event that any single bolt of that type was to fail during installation.
The basis for this being acceptable has been provided in SAR Section 2.1.2.2.2.1 as discussed above. No impact to safety basis
October 2014 A-13
9.2.2 9.2-1 Revised reference from DOE Order 460.1B to currently applicable 460.1C.
DOE Order 460.1C has replaced 460.1B. No impact to safety basis.
9.3.3 9.3-1 Revised to include Procurement in the list of activities performed under a QA Program verified to satisfy 10CFR71, Subpart H.
Procurement was inadvertently not mentioned in prior SAR revisions and has now been added for completeness. No impact to safety basis.
October 2014 A-14
RH-TRU 72-B SAR Drawing X-106-500-SNP, Revision 6
Sheet Zone Change Description Justification
General Revised title block for company name, revision and date.
1 C/5 Flag note 35 updated to reflect revision in nomenclature for O-ring compound from “RR0405-70” to “R0405-70”, consistent with manufacturer’s name change for the formulation.
1 C/3-4 Flag note 57 added to identify optional items and/or optional configurations.
Change is for operational flexibility only. Optional features (lid alignment pins, bolt hole access rings, threaded inserts, plating) and/or their optional configurations have no safety significance. No impact to safety basis.
2 D/7 Impact limiter bolt hole access debris ring now overtly identified as optional.
Administrative change only. Feature has always been optional but previously this was not indicated on this particular drawing sheet. No impact to safety basis.
2 B/6 New flag note 57 added to lid alignment pins. Change is for operational flexibility only. No impact to safety basis.
4 D/8 Flag note 31 for optional plating added to the OC closure bolt optional threaded inserts.
Plating option has always been called out for other threaded inserts, but was missed for this particular insert. No impact on safety basis.
4 B/1 and D/3
New flag note 57 added to OC lid alignment pins. Change is for operational flexibility only. No impact to safety basis.
5 C/1 and A/3
New flag note 57 added to IV lid alignment pins. Change is for operational flexibility only. No impact to safety basis.
October 2014 A-15
RH-TRU 72-B SAR Drawing X-106-500-SNP, Revision 6
8 C/3 and D/5-6
New flag note 57 added to IV and OC alignment pins making their configuration details and their use during transport optional.
Change is for operational flexibility only. Features have no safety significance during transport. No impact to safety basis.
October 2014 A-16
RH-TRU Waste Canister, Fixed Lid SAR Drawing X-106-501-SNP, Revision 5
October 2014 A-17
RH-TRU Waste Canister, Removable Lid SAR Drawing X-106-502-SNP, Revision 3
October 2014 A-18
Neutron Shielded Canister, NS15 & NS30 SAR Drawing X-106-503-SNP, Revision 1
1 D/5-6 Terminology changed for consistency with flag note 1 change.
1 D/1-2 Flag note 1 terminology changed. Administrative change. No impact to safety basis.
October 2014 A-19
RH-TRAMPAC, Revision 3, October 2014
General Changed all references to 10CFR71 to reflect the current 1/1/14 edition.
General The entire RH-TRAMPAC was reviewed and changes made as necessary to ensure consistent use of the terms used to reference the payload container/canister (including specific types of payload canisters) and inner containers. Section 2.1.1 has been revised to better define the payload canister terminology.
Administrative change to achieve consistency of terminology. No impact to safety basis.
2.4.1 2.4-2 Revised Section 2.4.1, Requirements, to expand the operating temperature range for the filter vent housing and element for the RH-TRU canister from (-40 °C to +70 °C) to (-40 °C to +100 °C).
The filter vent temperature range was originally selected for consistency with the operating temperature range required in 49 CFR §173.412(c) for DOT Type A packages. Based on the actual materials of construction for the filter vents, the allowable operating temperature capability of the filter vents utilized in RH-TRU waste containers is significantly higher than 158 °F. The common materials of construction for the filter vents include stainless steel, sintered stainless steel or carbon filter media, silicone adhesive, and neoprene. A new maximum required operating temperature of 212 °F has been chosen to take advantage of the thermal characteristics and capabilities of the filter vent materials while still providing a comfortable margin. No impact to safety basis
October 2014 A-20
3.1.1, 3.1.2, Table 3.1-1, 6.2.1, Table
6.2-1
3.1-2, 3.1-3, 3.1-7, 6.2-2, 6.2-7
Revised requirements for U-235 FEM Mass Limit and Table 3.1-1 to redefine the particle/lump size conditions for compliance with the 0.96% U-235 FEM limit and to add a 0.84% U-235 FEM limit for payloads up to 3,100 pounds net weight. Incorporated consistent changes into the procedure and Table 6.2-1 documentation for certification of individual RH-TRU waste canisters.
The previous evaluation for homogenous (Case D) LEU payloads was augmented to consider heterogeneous (Case E) payloads. The evaluation conclusions provide for distinguishing between the two cases through specific fissile mass particle/lump size criteria to qualify heterogeneous payloads as safely subcritical under the previously established 0.96% U-235 FEM enrichment limit. Additionally, heterogeneous payloads not meeting the fissile mass particle/lump size criteria are safely subcritical when shipped at a lower (0.84%) U-235 FEM enrichment when also limited in payload net weight. No impact to safety basis.
3.1.2, 5.1.4, Table 5.1-1
5.1-14
Revised RH-TRAMPAC Table 5.1-1 and related citations to update the specific activity and decay heat values summarized for the listed radionuclides according to a more current reference source.
Revisions reflect current and consistent references. No impact to safety basis.
3.2.1, 3.2.2, New 3.3,
6.2.1, 6.2.2, Table 6.2-1
3.2-1, 3.2-3, 3.3-1, 6.2-3, 6.2-8
Revised to apply the new methodology for implementing activity limits to satisfy Normal Conditions of Transport and Hypothetical Accident Condition dose rate requirements. The previous RH-TRAMPAC Section 3.2.2.2 has been deleted. Table 6.2-1 footnotes have been revised and renumbered to incorporate the compliance documentation for the new activity limits.
Revisions implement new methodology described in RH-TRU 72-B SAR Chapter 5.0. No impact to safety basis.
October 2014 A-21
RH-TRAMPAC, Revision 3, October 2014
5.0 5.1-1 Revised to refer to RH-TRU 72-B SAR analysis that shows all payloads authorized for transport in the RH-TRU 72-B will comply with the design pressure limit. The previous RH-TRAMPAC Section 5.3 has been deleted and replaced with a new Section 5.3, Design Decay Heat.
Revision reflects the revision of the maximum normal operating pressure calculation and its relocation from RH-TRAMPAC Section 5.3 to the RH-TRU 72-B SAR Chapter 3.0. No impact to safety basis.
New 5.3, Table 6.2-1
5.3-1, 6.2-8
Revised to clarify design decay heat limits for the RH-TRU 72-B package and to specify the design decay heat limit for the RH-TRU Waste Canister and the Neutron Shielded Canisters.
Revisions clarify design decay heat limits for payloads and implement new methodology described in RH-TRU 72-B SAR Chapter 3.0. No impact to safety basis.
6.2.3, Table 6.2-2
6.2-4, 6.2-9
Corrected references to shipping site and receiving site for consistency with Table 6.2-2 and Table 6.2-3. Title for Table 6.2-2 changed to properly state “shipping site” instead of “site”.
October 2014 A-22
RH-TRU Payload Appendices, Revision 3, October 2014
General The entire RPA document was reviewed and changes made as necessary to ensure consistent use of the terms used to reference the payload container/canister (including specific types of payload canisters) and inner containers.
2.5 2.5-4 Revised to clarify the definition of layers of confinement. Per RH-TRAMPAC Section 2.7, sealed containers greater than four liters in size are not allowed. As clarified by text revisions to RH-TRU Payload Appendix 2.5, “a confinement layer is any boundary around a volume greater than 4 liters that restricts, but does not prohibit, the release of hydrogen gas across the boundary.” Container or bag layers greater than four liters in size are layers of confinement.
Revisions clarify and make consistent the definition of layers of confinement with respect to payload container inner packaging configurations and CH-TRU Payload Appendix 3.8. No impact to safety basis.
2.5 2.5-12, 2.5-15
thru 2.5- 20, 2.5- 23 thru 2.5-25, 2.5-27, 2.5-28, 2.5-30
Revised RH-TRU Payload Appendix 2.5, Compliance Methodology for Gas Generation Requirements, to specify the relationships (represented by parabolic equations) between the average payload temperatures as functions of the decay heat as revised in Table 3.4-4 of the SAR. Revised Section 2.5.5, Example Flammable Gas Generation Rate Limit Calculation, to use the revised equation for the RH-TRU Waste Canister for average payload temperature as a function of payload decay heat. Updated reference citation for the Radcalc software (Version 4.1).
Changes are consistent with the updated thermal analysis presented in Chapter 3.0 of the SAR. No impact to safety basis.
October 2014 A-23
RH-TRU Payload Appendices, Revision 3, October 2014
4.6 4.6-2 and 4.6-3
Revisions to update the appendix based on additional literature review.
Revisions reflect current and consistent references. No impact to safety basis.
5.1.3.2.1.3.2 5.1-12 The justification for drop testing of NSCs at a hot temperature of at least 150 °F was revised to address new temperatures obtained from the revised thermal analyses.
Revisions demonstrate that testing was performed at a temperature greater than the average NCT temperature of the HDPE neutron shielding material. Somewhat greater, localized peak temperatures are also addressed and shown to be acceptable. No impact to safety basis.
5.1 5.1-12, 5.1-29
and 5.1- 30
Detailed thermal and shielding analyses addressing the NSCs have been removed from Sections 5.1.4 and 5.1.5. These analyses have been replaced by corresponding new analyses now located in SAR Chapter 3.0, Thermal Evaluation, and Chapter 5.0, Shielding Evaluation. Section 5.1.7 has been revised to reflect the revision to and relocation of the shielding analysis.
Changes are administrative to accommodate SAR modifications. No impact to safety basis.
October 2014 A-24
ATTACHMENT B – Revised Documents
(One Hard Copy and One CD1 – Document Control Desk) (Five Hard Copies and One CD1 – H. Akhavannik)
• RH-TRU 72-B SAR, Revision 7, October 2014 • RH-TRAMPAC, Revision 3, October 2014
• RH-TRU Payload Appendices, Revision 3, October 2014
1 CD contains a PDF version of the complete documents listed in Attachment B.
October 2014 B-1
• Thermal Analysis – Thermal Desktop files • Shielding Analysis – MCNP files • Criticality Analysis – KENO files
2 CD contains electronic analysis files.
October 2014 C-1
Attachment B - Revised Documents
RH-TRAMPAC, Revision 3
Attachment C - Supplementary References
Shielding Analysis - MCNP Files
Criticality Analysis - KENO files