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Nuclear Fuel Services, Inc. ERWIN. TENNESSEE 37650t

+r3'y-Q ; A Subsidiary of Getty Oil Company (615) 743-9141iA J

.i li 43ApSil26,1979

3to

4 /roMr. Charles E. flacDonald, ChiefTransportation Branch p

DOCKnODivision of Fuel Cycle and Material Safety UsNac OU. S. Nuclear Regulatory Commission p-

Washington, D. C. 20555 E- APR 3 01979 c, aNMss-

hy,'SFC7rc.yReference: (1) Docket 70-143, SNM 124 g(2) Letter, C. J. Michel to C. E. MacDonald, - SC

Ndated December 22, 1978 g ' ;' ,,(3) Letter, C. E. MacDonald to C. J. Michel, =-dated February 26, 1979

Dear Mr. MacDonald:

In response to reference 3, NFS submits the attached Safety AnalysisReport for Plutonium Packaging. This Report demonstrates the follow-ing:

1. Compliance with the double containment requirement forplutonium as specified in 10 CFR 71.42 utilizing theSuper Tiger packaging with specification 17H innercon tainers .

2. That the form of the plutonium to be packaged inType A fiberglass reinforced plywood containers with-in the Super Tiger. package is nondispersable andessentially nonrespirable such that it should bedetermined to be exempt from the double containmentrequirement per 10 CFR 71.42(b)(3).

This Report further justifies the amendment to Certificate of Compliance6400 that was requested in our referenced letter.

Your earliest review and approval of this amendment is requested in orderthat we may proceed with the decommissioning plans for our plutoniumf acili ty.

Very truly yours,

79060600d .,

. - . ' 7; < R. . L.' ~ ~ C. J. Michel

Administrative Manager

CJM:kj >

Attachment / ,' [ MMi

2276 .42

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I

SAFETY ANALYSIS REPORT FOR PLUiONIUM PACKAGIdG

I. INTRODUCTI0d

Nuclear Fuel Services proposes to utilize the Super Tiger packaging

presently licensed by the Nuclear Regulatory Commission as Certificate

of Compliance USA /5400/B()F to transport contaminated waste generated

in the decommissioning of its plutonium facility (see NFS Plan for De-

commissioning of Plutonium and Uranium-233 Facilities, dated October 9,

1978). Although the Plan specifies decontamination of equipment prior

to packaging, it is anticipated tnat some packaged objects will contain

residue quantities of plutonium in excess of 20 curies. Since the

Super Tiger is not presently licensad to transport more than 20 curies

of plutonium in oxide form, NFS requested, in a letter dated December 22,

1978, an amendment to the Certificate to pemit the Commission to

specifically authorize shipments in excess of 20 curies of plutonium.

In response to this request for amendment, the NRC requested additional

information in a letter dated February 26, 1979. This Report contains

the infomation requested in tjlat letter.

II. SCOPE

This Report is written to demonstra a: (1) Compliance with the dochie

containment requirement for plutonium, as specified in 10 CFR 571.42,

utilizing the Super Tiger packaging with Specification 17H inner con-

tainers, and (2) that the fom of the plutonium to be packaged in Type

A fiberglass reinforced plywood containers within .the Super Tiger

package is nondispersable and essentially nonrespirable such that it

should be detemined to be exempt from the double containment require-

ment per 10 CFR 71.42(b)(3).

d%Bi2276 .:.43

Page 2 of 6.

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III. SUPER TIGER /17H PACKAGING

A. Description

The Super Tiger has been adequately described in the original

application (see Engineering Evaluation of the Super Tiger Over-

pack Designed for the Shipment of Large Quantities of Hazardous

Materials , Dated flay 4,1970) . Since no changes are proposed to

the Super Tiger, the description is referenced. Similarly, the

17H packaging is well described in 49 CFR 5173.396 and 5178.118.

In addition, NFS proposes to equip each 17H container with a rigid

polyethylene liner. The 17H with the liner is depicted in Figure 2.5.

The polyliner is 0.1 inch thick and closure is accomplished by

using a slip fit poly lid that will be sealed with tape or

adhesive. The 17H with polyliner is also described in RFP 2244

"ATMX-600 Rail Car Safety Analysis Report for Packaging", Rev.1.

B. Testing Analysis

The Super Tiger has already been successfully tested under both

normal and accident conditions. It provides the first barrier

for plutonium containment. The second barrier for containment

is provided by the 17H with the rigid polyliner. The integrity

of the 17H container was demonstrated by the original Super Tiger

tes ts . Two of the forty-two 55-gallon drums contained in the

Super Tiger during testing were Specification 17H drums. As

reported in the original application, these containers experienced

little or no deformation and no liquid was lost from the containers.

This information and other details can be found on pages 63 thru

65 of the Engineering Evaluation. The exact location of the 17H

2276 ;44 N.

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B. Testing Analysis (cont'd)

containers within the Super Tiger was ret gi/en in the Evaluation.

It is important to note that the Super Tiger was subjected to

four 40-inch puncture tests, impacting on three sides of the

package. These tests should have maximized damage to the inner

containers regardless of location. It should also be noted that

the drums were not equipped with polyliners, nor were they banded

or shored. This loose packing of the inner containers was to

maximize impact between the inner containers during testing.

C. Special Considerations

To minimize the impact between the 17H drums within the Super

Tiger under normal and accident conditions, NFS proposes to band

the drums together in groups of four. 'Jooden shoring will also

be provided to minimize move. ment of the drums during transport.

This will reduce drum damage since the banding and sharing will

absorb impact energy.

.

To minimize the possibility of packaged objects piercing the

polyliner and/or the drum, heavy, dense objects such as sheet

metal, pipes, and concrete that have piercing potential will be

tightly packed in drums, and low density waste (plastic, paper,

cardboard, etc.) will be packed between the heavy objects and

the polyliner.

2276 .45

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Page 4 of 6-

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IV. SUPER TIGER / TYPE A FRP PACKAGING

A. Descriotion

A typical FRP box is depicted in Figure 2.6. Box specifications

are detailed in RFP 2460 '' Safety Analysis Report for Packaging -

00T-7A Fiberglass-Coated Plywood Box for Transuranium Solid

llas te" . NFS proposes to use the FRP box as described in RFP 2460

with two exceptions: (1) The inner 0.C51" fiberboard liner and

lid will not be provided, and (2) sizes of the boxes used will

vary from the specified 4' x 4' x 7' dimensions.

The fiberboard liner will be replaced with 1/4" plywood sheets

on four sides of the box. The plywood will provide better

protection from objects piercing to the other FRP box in the

area where piercing is most likely to cccur.

Boxes will be sized specifically for the bulky pieces of-equip-

ment to provide for a tighter fit, thus minimizing internal

movement during transport. The boxes will also be sized to pro-

vide a tight fit within the Super Tigar, again to minimize move-*

ment. It should be noted that the dimensions specified in

RFP 2460 were determined primarily by the size of ATMX railcar.

Sizes of the NFS boxes will vary from 65" x 75" x 162" to

40" x 41" x 61". These variatior,s in sizes will not significantly

affect the integrity of the box.

8. Testing Analysis

The FRP box has been successfully tested to meet the requirements

for a Type A packaging. Details of the test results are presented

2276 c.46

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B. Testing Analysis (cont'd)!

in RFP 2460. flo testing has been performed on the Super Tiger /

Type A FRP packaging; however, it is logical to assume that the

Super Tiger would have maintained its integrity independent of

whether it had been loaded with boxes or drums. The integrity

of the boxes, on the other hand, cannot be assumed, so that the

double containment of the plutonium for the Super Tiger / Type A

FRP packaging cannot be assumed under accident conditions.

C. Plutonium Immobilization

flFS proposes to immobilize the plutonium contamination on the

equipment to be placed in FRP boxes in order to render the

plutonium nondispersable and essentially nonrespirable. With the

plutonium in this form, it should be determined that the double

containment requirement of 10 CFR 71.42 is not applicable as

provided for in 10 CFR 71.42(b)(3).

NFS preposes to apply Turco 5931 Stripable Coating, or equivalent,

on all contaminated surfaces of equipment that are packaged in

FRP boxes. This coating will adhere to both stainless steel and

plexiglass surfaces. It has elastic properties that minimize

cracking and chipping during impact. It will easily withstand

temperatures of 150 F that were experienced within the Super Tiger

during the fire test. It is non-flammable and can be applied with a

brush. It also has the property of retaining contamination if it

is removed from the surface.

2276 .:47

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Page 6 of 6

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D. Soecial Considerations

Equipment will be packed in the boxes as described in Sections III.C

and IV./. to prevent internal piercing of the containers. NFS also

proposes to remove ail objects that protrude from the large pieces

of equipment so as to eliminate the possibility of these objects

piercing the FRP box. Any force caused by internal movement of

the packaged equipment will be displaced over a large area of the

container, thus minimizing damage, if any, to the container. The

removed protruding objects will be packaged in 17H drums where

better protection is provided against piercing.

The FRP boxes will be shored with wood within the Super Tiger to

insure a close fit and to minimize movement.

When FRP boxes are loaded in the Super Tiger, along with 17H drums,

protection will be provided to prevent the drums from damaging

the boxes. This protection will consist of a sheet of 1/4" plywood

between the box and the drum and inflated o innace bags between the

plywood and the box. Where space permits, these dunnage bags will,

also be utilized between boxes and be:. ween boxes and ca Super Tiger.

2276 ;48

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