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8-120B Cask Book - Energy Solutions

1. eese eese sees ertet nnne et nnnen 5 4 Table 5 3 Material Composition and Density essen eene nnne 5 7 Table 5 4 Gamma Ray Flux To Dose Rate Conversion Factors ANSI ANS 6 1 1 1977 5 10 Table 5 5 Final Payload Source Strength and Source Strength Density Limits 5 11 Table 7 1 Payload Source Strength and Source Strength Density Limits 7 10 Table 8 1 Periodic and Maintenance Leak Test of 8 120B sese 8 8 Table 8 2 Pre Shipment Leak Test of 8 120B Components eee 8 0 1X 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 LIST OF FIGURES FIGURE PAGE Figure 1 1 Features of the 8 120B Cake da 1 2 Figure 2 2 8 120B Cask Containment Boundary eee 2 86 Figure 2 3 Polyurethane Foam Stress Strain Properties Parallel to Rise Direction 2 87 Figure 2 4 Polyurethane Foam Stress Strain Properties Perpendicular to Rise Direction 2 88 Figure 2 5 Lifting Ear Free Body Diagram uie deo ecd eire rete spp 2 80 Ligure 2 6 Latine Ear Detdils ss 2 90 Figure 2 7 Primary Secondary Lid Lifting Lug Orientation eene 2 9 Figure 2 8 Freebody Diagram of Lid Lifting Lug eere 2 92 Figure 2 9 Lid Lifting Lug Eye Tear out ATC aiii 2 93 Figure 2 10 Lid Lifting Lug Net Tensile Area iere iater t tno te e
2. sans bolt and V is the conservative lower bound estimate of volume of the vent port plug i e the 72 hex cap screw head volume calculated as a 23 4 x 5 16 high The volume of the vent plug Stat O Seal is conservatively neglected Vi 1 8 in 2 4 3 8 in 2 54 cm in 0 23 cm V5 3 8 in 1 4 1 25 in 2 54 cm iny 7 54 cm V3 z 5 16 in 1 4 3 4 in 2 54 cm in 2 26 cm Therefore the total vent port test volume including the test manifold volume is calculated to be 15 5 cm i e 10 0 23 7 54 2 26 which is much less than the 37 3 cm limit calculated by the NRC staff The lower vent port test volume limit of 34 4 cm given in the referenced notification was based on a calculation that conservatively neglected the 10 cm manifold volume With the inclusion of the test manifold volume we concur with the NRC staff s calculated vent port test volume limit of 37 3 cm for the 20 minute hold time to be adequate Summary of SAR changes e None Test Manifold St nger Part of V M Cap Screw NN Port Test Flange V N N Stat O Seal NS Va SENS Secondary Lid Top 3 1 4 Plate m LL LZ SECTION A A ELEVATION Figure 1 Vent Port Test Configuration ENERGYSOLUTIONS November 13 2013 ES NRC 13 025 Docket No 71 9168 ATTN Document Control Desk Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety
3. 1m 16 um ENERGYSOLUTIONS September 20 2013 ES NRC 13 019 Docket No 71 9168 ATTN Document Control Desk Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U S Nuclear Regulatory Commission Washington DC 20555 0001 Subject Response to Request for Additional Information for the Model No 8 120B Package Docket No 71 9168 Reference Letter from P Saverot NRC to S Sisley EnergySolutions Request for Additional Information for the Model No 8 120B Package Docket No 71 9168 September 16 2013 ADAMS Accession Number ML13260A396 Dear Sir or Madam By the referenced letter NRC requested that EnergySolutions ES provide additional information needed for NRC staff to complete their review of the application to amend Certificate of Compliance CoC No 9168 for the 8 120B Shipping Package ES hereby provides the additional information requested by NRC in the referenced letter as described in Enclosure 1 Enclosure 2 contains one 1 paper copy of the non public version of the revised 8 120B Safety Analysis Report SAR that contains security related sensitive information that should be withheld under 10 CFR 2 390 Enclosure 3 contains one 1 paper copy of the public version of the revised 8 120B SAR in which all proprietary information and security related sensitive information is redacted A summary of changes included in the 8 120B SAR is provided
4. co e at 2 Solidified Waste Cont General Cs 137 3 15E 11 5 78E 04 Cs 137 2 58E 12 e 2 56E 08 1 22E 01 2 26E 04 2 26E 04 3 Solidified Waste Cont General 0 8348 1 48E 11 2 72E 04 0 9 0 8 63E 11 6 5 54E 07 1 71E 01 4 91E 04 4 91E 04 Sum 6 47E 03 Since the sum is less than 0 95 the container is an acceptable payload 7 16 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Example 3 Dewatered Resin Liner Problem Step 1 Step 2 Step 3 Determine the acceptability of a 100 ft steel secondary container containing dewatered resin The activity is uniformly distributed The measured weight of the filled container is 13 100 Ibs the weight of the empty container is 1 100 Ibs The isotopic activity determined by analysis of samples of the waste is 5 Ci of Co 10 Ci of Cs 50 Ci of Fe 4 Ci of Mn and 30 Ci of Sr Also included is a 100 gram piece of activated metal not shored with an activity of 0 5 Ci of 6Co The activated metal is steel with a density of 8 g cm This differs from Example 2 in that there is more Sr and there is the additional piece of activated metal Characterize Source Given in the problem statement Convert Beta Source to Equivalent Gamma Source Sr emits beta radiation through its own decay plus the decay of its short lived daughter product Y So the total beta production rate is 30 Ci 3 7E 10 d Ci 2
5. 4 11 4 6 Determination of Equivalent Reference Leakage Rate for Helium Gas 4 15 4 7 Determining Time for Pre Shipment Leak Test Using Air or Nitrogen 4 19 4 7 1 Minimum Hold Time for Closure Lid eene 4 19 4 7 2 Minimum Hold Time for Vent Port eese nennen 4 21 4 8 Leakage Rate Tests for Type B Packages oocoonnocccnoncccnonccononcnononanononacnnnnccnnnnaconnnannn 4 22 4 90 Periodic Verification Leak Rate Determination for Leaktight Status 4 24 OLI troduction seeen RT 4 24 AOD Test CODUIGOIIS e s 4 24 4 10 Referentes iii ii arenes 4 25 5 0 SHIELDING EVALUATION giissccssessscdessscessondssestevesssoccscassoocseacsedesdsiqecoesscsscoesssesensesdeoss 5 1 5 1 Description of Shielding Design cgit etr ii 5 1 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 3 1 1 Shielding Design Features aristides dosel ici a nsii 5 1 5 L2 Maximum Radiation BEevels sus deterius aii 5 1 2 4 Source Sp cification i eee eet ROI e E Mes OU eder odo pnt SERRE TS KP Se E Le Ede CUR 5 3 S2 AAMAS OUNCE a niea e eite 5 3 3652 2 Neutron QUEUE o pr tabat a o et ated 5 4 3 2 9 WHC Ciel ED RH O tp eho ae ea ae 5 4 S Model SPECI CALOM nienn a sete o band sectis ct I erase 5 4 5 3 1 Description of Radial and Axial Shielding Configuration sss 5 4 5 3 2 Midterial Propertie AA O 5 6 5 4 Shielding Ev
6. cw ENERGYSOLUTIONS CASK BOOK FOR MODEL 8 120B USA 9168 B U EnergySolutions Suite 100 Center Point II 100 Center Point Circle Columbia South Carolina 29210 Phone 803 256 0450 Please ensure that you are a registered user before using this package refer to Section 3 To verify please contact the NRC Thank you III VI 8 120B Cask Book Rev 41 Table Of Contents US NRC Certificate of Compliance Number 9168 Rev 20 dated November 22 2013 as corrected on December 18 2013 TR OP 035 Rev 25 Handling Procedure for Transport Cask Model 8 120B Certificate of Compliance Number 9168 TR TP 002 Rev 20 Air Pressure Drop Test for Model 8 120B Cask Certificate of Compliance Number 9168 ER 01 002 Rev 1 Conformance of CNS 8 120B Cask with Specifications for Industrial Packaging Type 1 and Type 2 ER 01 004 Rev 1 Conformance of CNS 8 120B Cask with Specifications for DOT 7A Type A Packagings Typical User Registration Letter Safety Analysis Report for Model 8 120 Type B Shipping Package Consolidated Revision 7 November 2013 Drawings C 110 E 0007 Rev 19 Sheets 1 6 withheld as security related sensitive information DWG CSK 12CV01 EG 0001 01 Rev 3 withheld as security related sensitive information References EnergySolutions applications and supplements dated May 23 July 3 August 9 September 20 and November 13 2013 CHEM NUCLEAR SYSTEMS LLC 140 Stoneridge Dr
7. 2 Checkinterior of cask bolts and bolt holes for foreign material water DU 3 Primary lid o rings and seating surface inspected if lid removed L 4 Secondary lid o rings and seating surface inspected if lid removed E S S 5 Primary lid bolts torqued Torque wrench data Serial Calibration Date Calibration Due Date 6 Secondary lid bolts torqued Torque wrench data Serial Calibration Date Calibration Due Date 5 7 Secondary Lid thermal shield replaced 8 Impact limiter ratchet binders replaced hand tighten and left in the lock position 9 Foraloaded cask both Primary and Secondary Lids and vent port have been air leak tested 10 All 3 test port set screw plugs replaced hand tightened and vent port socket head cap screw with o ring replaced torqued Torque wrench data Serial Calibration Date Calibration Due Date 11 If cask removed from lower impact limiter follow steps 5 4 4 2 through 5 4 4 5 and forward bottom of cask lower impact survey to Energy Solutions CMF 12 Upper impact limiter to cask body security seal installed Seal 13 Other Security Seals on Secondary and Primary lid Cask Body to Lower Impact Upper Impact Man Way and Trailer Tool Box Installed or Verified in place 14 Impact limiter lifting lug covers replaced 15 Cask tie downs hand tighten inspected and taunted 16 Cask labels and marking adhered correctly and legible PLEASE COMPLETE AND INITIAL SHIPPER SUPERVISOR S HEALT
8. ER 01 004 Rev 1 Page 2 of 20 1 0 introduction This report evaluates the CNS 8 120B cask s conformance with 49CFR178 350 Specification 7A general packaging Type A Reference 5 1 This report fulfills the requirement of 8173 415 a Authorized Type A Packages which specifies that Each offeror of a Specification 7A package must maintain on file for at least one year after the latest shipment and shall provide to DOT on re quest complete documentation of tests and an engineering evaluation or comparative data showing that the construction methods packaging de sign and materials of construction comply with that specification 2 0 Discussion The CNS 8 120B is licensed by the US NRC under Certificate of Compliance USA 9168 B U The CNS 8 120B was certified as a Type B package by demonstrat ing compliance with NRC Type B requirements specified in 10CFR Part 71 Therefore the CNS 8 120B should readily meet the requirements for a DOT 7A package Nevertheless this report examines each regulatory requirement individually to assess the package s conformance to DOT 7A specifications However where appropriate references are made to the Safety Analysis Report for the CNS 8 120B Reference 9 2 that was prepared to support certification by the NRC This Engineering Report evaluates the shipment of solid or liquid radioactive material in this cask when used as a DOT 7A packaging While the SAR does not specify liquid form as a permit
9. Not applicable since the beta source is less than 2E 12 f sec Calculate Gamma Source Strengths and Source Strength Densities 100g Activated Metal Payload Item Co emits two gammas per disintegration therefore the total source strength for the small activated metal item is 6 CIA y d 3 7E 10 d sec Ci 4 44E 11 y sec Dividing by the mass of 100 g the source strength density is 4 44E 09 y sec The mass density is assumed to be uniform for the small activated metal item Energy Payload Source Term MeV or Nuclide y seci y sectg 4 44E 11 4 44E 09 7 19 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Remaining Activated Metal Payload Item Co emits two gammas per disintegration therefore the total Co source strength for the activated metal is 30 Ci 2 y d 3 7E 10 d sec Ci 2 22E 12 y sec The remaining nuclides 8Co and Mn were converted to individual energy lines E 0 3 MeV were neglected Sources were divided by 2 72E 06 g i e 6 000 Ib to obtain the y sec g The mass density of the metal is assumed to be uniform The resulting sources are Energy Payload Source Term MeV or Nuclide y sec y secig 2 22E 12 8 16E 05 Crud Payload Item 50 000 dpm is equivalent to 2 25E 08 Ci per 100 cm The total source strength is therefore 2 25E 08 Ci 100cm 500 ft 929 cm ft 1 05E 04 Ci The nuclide breakdown is therefore 5 23E 05 Ci of Fe 3 14E 05 Ci of C
10. Side Side I L 0 5 0 7 0 4 0 5 0 7 0 3 0 5 1 5 0 6 Surface Surface Side body Top 1 1 1 9 0 6 0 4 0 4 1 8 0 3 1 2 8 1 1 8 Surface Bottom Side 1 8 1 8 1 7 1 9 1 2 N A 0 6 1m Bottom 13 N A N A N A N A A N A N A N A A A A A 2 6 5 1 3 3 1 8 N N N N N ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information Allowable Source Derivation for 1 5 MeV or lower photons Transport Condition NCT HAC Source Case Full Cavity 2 5 f 55 gal Centered Pt Corner Pt Side Point Full Cavity Corner Pt MCNP Case NCT 150 NCT 150 NCT 150 NCT 150 pt4 NCT 150 pt4 NCT 150 pt4 HAC 150 HAC 150 pt fullcav 25ft3t 55gal ctr tcor side fullcav tcor Relative Error for Max Response ES Location Side 0 4 0 3 0 3 0 2 2 0 Surface Surface Side I L Side M 0 5 0 9 0 5 0 3 0 5 0 3 0 4 0 2 0 6 7 8 Surface Surface Bottom 1 2 1 3 1 3 0 8 2 0 0 5 Side 1 1 3 1 3 0 9 N A N A N A 0 4 2 8 N A Fe a a ena enemies o IG Allowable Source Derivation for 1 17 MeV or lower photons Transport Condition Source Case Full Cavity 2 5 f 55 gal Centered Pt Corner Pt Side Point Full Cavity C
11. 2 REFERENCES dH 3 3 DEFINITIONS p a EER 3 4 REQUIREMENTS fep ana 4 4 1 A o no 4 4 2 Tools Materials and Equip ii 4 4 3 PSC AMI Sy bin m T 5 44A Acceptance Criteria ndice 5 4 5 BRS pT MSS cesado T T 5 5 DETAILED PROCEDURE vesccsii A ks EK dE denso pc I Clas iat 6 5 1 Pressure Drop Test For Secondary Lid O Ring Seal esse 6 5 2 Pressure Drop Test For Primary Lid O Ring Seal eee 8 5 3 Pressure Drop Test For Vent Portela 9 5 4 Storage of the Ma dd 12 6 RECORD Sisa M 12 Appendix A 8 120B Air Leak Test Inspection Form eese enne 13 Appendix B Troubleshooting Guide for Leak Testing the 8 120B Cask sess 14 Page 2 of 15 Air Pressure Drop Test for 8 120B Cask TR TP 002 Certificate of C onformance USA 9168 B U Revision 20 1 SCOPE 1 1 Purpose This procedure delineates the requirements for performing an air pressure drop test on the Model 8 120B shipping casks This test will prove the integrity of the O rings for the primary and secondary lids and the vent port on the Model 8 120B cask 1 2 Applicability This procedure establishes the method for pre shipment verification air leak testing of the Model 8 120B shipping cask Nuclear Regulatory Commission Certificate of Compliance Numb
12. Attachment 1 Example 5 Step 3 Attachment 1 7 23 and Example 5 7 24 Steps 5 7 July 2012 All Deleted SAR Addendum Consolidated Revision 4 Changes Inadvertent Ommissions Reference 2 7 1 8 7 3 Change section cross reference in Editorial correction second note 7 1 9B 7 3 Step added to address Condition 7 Requirement incorporated in in CoC Revision 19 9 SAR Operating Procedures 7 1 12A Step added to address Requirement incorporated in Revised selected example More pertinent example chosen s e 4 parameters based on revised shielding analysis results 7 23 7 22 and Revised example data Updated based on results of revised shielding evaluation Editorial formatting for two sided printing No longer applicable Condition 11 in CoC SAR Operating Procedures Revision 19 ES NRC 13 026 November 13 2013 Page 5 of 9 Consolidated Summary of Changes 8 120B Consolidated SAR Section Front matter 2 2 1 3 2 2 Chapter 4 4 0 4 2 2 4 2 3 Revisions 4 through 7 Consolidated Revision 5 Changes Reference 3 xiv Added revision control sheet Editorial change 2 5 Replaced reference to Editorial change Appendix 1 specification Section 8 changed to References 3 2 Corrected O ring durometer Editorial correction for specification 1 bullet and consistency with drawing and replaced references to Section 8
13. Discuss the modeling of the impact limiter The comparison of the drawing C 110 E 0007 Rev 19 with the drawing in Appendix 1 of CALC NU 391 shows that nominal dimensions of the impact limiter were used in the shielding calculation Verify if this is correct Table 2 10 of the application indicates that there is some deformation of the impact limiter as a result of NCT drop tests Discuss if the results of the NCT tests were included in the impact limiter models and justify if these are not Discuss the result of the NCT tests on the thermal barrier and if these effects were included in the shielding models This information is required by the staff to determine compliance with 10 CFR 71 47 and 10 CFR 71 51 a 2 Response to 5 6 Yes the nominal un deformed impact limiter dimensions were modeled in the shielding analyses of the CALC NU 391 Rev 6 calculations To ensure that no calculated cask source limits are non conservative due to the effects of the tests conditions defined for NCT all of the NCT shielding analyses have been re performed The revised analyses account for the permanent deformations of the impact limiters under NCT presented in Table 2 10 of the application Specifically the bottom and top impact limiters outer radii are reduced by 1 3 inches from 51 inches to 49 7 inches and the thickness of the bottom and top impact limiter end regions is reduced by 1 3 inches from 22 inches to 21 4 inches For simplic
14. are LSA or SCO and the unshielded material has a dose rate less than or equal to 1 rem hr at 3 meters If you have any questions or comments please call me at 803 541 5012 Sincerely Chem Nuclear Systems LLC doa UA Es Kevin Lee Licensing Engineer KL jtg CHEM NUCLEAR SYSTEMS LLC 140 Stoneridge Drive Columbia South Carolina 29210 e 03 256 0450 8 July 7 1999 CHEM NUCLEAR SYSTEMS INFORMATION NOTICE POTENTIAL PROBLEMS ASSOCIATED WITH CASK SHIELD INSERTS Dear Customer For many years cask shield inserts have been approved for use in certified Low Level Waste Transportation Casks as supplemental shielding or shoring Several models of Chem Nuclear Systems Chem Nuclear casks use approved full height shield inserts of varying thicknesses from Y inch to 2 inches Cask users have experienced normal fit and function with these inserts which typically allow for a radial clearance of inch between the insert and the packaging liner However specific applications can produce close fitting contents packaging liners with minimal dimensional clearances Recent experience has shown that if not properly handled and stored during routine use cask shield inserts may experience some distortion such as ovalization This is more pronounced in thinner inserts i e inch thick This ovalization may however not be readily discernable and may occur by laying the shield insert down on its side without proper reinfor
15. regarding exemption from pre shipment leak testing requirement for LSA material and SCO shipments Revised 6 bullet in section to reflect current drain configuration Deleted note regarding exemption from pre shipment leak testing requirement for LSA material and SCO shipments Revised to clarify that the allowable pressure drop is 0 1 psig and that the maximum graduation not sensitivity of the pressure guage shall be 0 1 psig All shipments made in the 8 120B package now require pre shipment leak testing Editorial clarification All shipments made in the 8 120B package now require pre shipment leak testing Editorial correction Consolidated Revision 7 Changes Reference 5 8 3 2 1 8 6 8 7 Revised last paragraph of section to reference Section 8 3 2 1 for the leak test requirements for powdered solid shipments Added word every before shipment and added footnote 2 New requirement added Revised to include leak testing requirements for powdered solid shipments Editorial correction Leak test requirements for leaktight status from Section 4 9 are added to Chapter 8 Added clarification and basis for requirement Requirement added to assure cask has received the required periodic leak testing prior to shipment Leak test requirements for leaktight status from Section 4 9 are added to Chapter 8 ES NRC 13 026 November 13 2013 Page 9 of 9 Consolidated Summary of C
16. shield Follow Steps 5 1 2 1 through 5 1 2 2 2 5 1 4 2 Remove secondary cask lid 5 1 4 2 1 Prior to removing the cask secondary lid the inspection tag attached to the primary or secondary lid shall be reviewed to verify none of the maintenance inspection or testing activities have passed the due dates recorded on the tag If no tag is present or if any dates have expired or will expire prior to the cask reaching the Page 19 of 41 Handling Procedure for Transport Cask Model 8 120B C of C Number 9168 Note 3 1 422 Caution 5 1 4 2 3 Note 5 1 4 2 4 Note Caution 5 1 4 2 5 Warning TR OP 035 Revision 25 destination where it will be unloaded EnergySolutions CMF shall be contacted prior to proceeding Contact EnergySolutions CMF for further directions if no inspection tag is present or if any of the due dates on the inspection tag have expired or will expire prior to unloading the cask Remove the security seals Properly dispose of removed seals Use of impact wrenches to remove cask lid bolts is limited to breaking initial torque on the bolt Once the bolt is free to rotate stop using impact wrench Final removal of lid bolts is to be done by hand Loosen and remove the twelve 12 2 inch bolts from the secondary lid Do not leave bolts in lid during removal Pneumatic or hydraulic torque wrenches non impacting may be used to remove the bolts Attach crane hook to secondar
17. 2 22E 12 betas sec Since this is above the threshold of 2E 12 betas sec the beta production must be considered Using the procedure to convert beta into equivalent gamma radiation described in Attachment 1 the SY betas will be treated as follows Emaxsr 0 54 MeV Eavgsr 0 19 MeV Emaxy 2 27 MeV Eaygy 0 93 MeV ZResin 5 6 Zsteel 26 Zw 26 the higher of the resin Z and the liner wall Z Sys U 11E 12 3 5E 04 26 0 19 1 92E 08 y s 0 54 MeV Syy 1 11E 12 3 5E 04 26 0 93 9 39E 09 y s 2 27 MeV Calculate Gamma Source Strengths and Source Strength Densities This payload must be broken into two payload items due to the physical and radiological differences between the resins and the activated metal Cember H Introduction to Health Physics Pergamon Press 2 Eg 7 17 8 120B Safety Analysis Report Consolidated Revision 7 Step 4 Steps 5 7 November 2013 Resin Payload Item Like Example 2 the following source data are to be used for qualification of the gamma emitters The mass density is assumed to be uniform for the resin portion of the payload Energy Payload Source Term MeV or Nuclide y sectg y sectg Co 60 3 70E 11 6 80E 04 Cs 137 3 15E 11 5 78E 04 0 8348 1 48E 11 2 72E 04 Activated Metal Payload Item Co emits two gammas per disintegration therefore the total source strength for the activated metal is 0 5 Ci 2 y d 3 7E 10 d sec
18. 2 40 Stress Intensity Plot 30 ft End Drop Cold Condition No Heat Load 2 124 Figure 2 41 Load Distribution on the Model During Side Drop sess 2 125 Figure 2 42 Stress Intensity Plot 30 ft Side Drop Hot Condition 2 126 Figure 2 43 Stress Intensity Plot 30 ft Side Drop Cold Condition Max Heat Load 2 127 Figure 2 44 Stress Intensity Plot 30 ft Side Drop Cold Condition No Heat Load 2 128 Figure 2 45 Load Distribution on the Model During Corner Drop sess 2 129 Figure 2 46 Stress Intensity Plot 30 ft Corner Drop Hot Condition 2 130 Figure 2 47 Stress Intensity Plot 30 ft Corner Drop Cold Condition Max Heat Load 2 131 Figure 2 48 Stress Intensity Plot 30 ft Corner Drop Cold Condition No Heat Load 2 132 xi 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Figure 2 49 Cask Oriented for Oblique Drop seen 2 133 Figure 2 50 Lead Slump During the 30 ft End Drop Test seen 2 134 Figure 3 1 8 120B Cask Design Features Important to Thermal Performance 3 17 Figure 3 2 Finite Element Model of the 8 120B Cask Used for the Thermal Analyses 3 18 Figure 3 3 Materials Used in the Finite Element Model eese 3 19 Figur
19. 3 8 drive socket verify the torque on the vent port socket head cap screw to be 20 ft lbs Ensure that the o ring on the adapter test manifold is in good condition and lubricated Replace if necessary Attach manifold to vent port by placing the manifolds trunk down into test port Next hand tighten the threaded bushing until it is snug If needed a wrench may be used to tighten the bushing but only 1 4 turn or less until snug Note Over tightening can cause damage to the test manifolds o ring and the test port threads Use caution and proceed slowly to ensure test manifold bushing is not over tighten Ensure the Air Regulator Inlet Valve located on the inlet side of the Air Regulator and the Leak Test Supply Valve located on the inlet side of the Test Pressure Gauge are closed Connect the adaptor test manifold to the vent test port Note Use extreme caution when connecting adapter test manifold to test port to prevent damage to test port threads Set the Air Regulator located on the manifold to 0 psig or OFF and connect the air supply to the manifold Caution A very small volume is being pressurized Use extreme care and do not exceed 20 psig Slowly open the Air Regulator Inlet Valve Slowly open the Leak Test Supply Valve After the Leak Test Supply Valve is open slowly adjust the Air Regulator to obtain 18 psig 1 0 psig on the Test Pressure Gauge Use extreme care so the Test Pressure Gauge is not over pressurize
20. 8 0 2 1 0 8 8 1 0 Bottom Side Surface 1 8 1 8 1 9 1 8 1 1 N A 0 6 1m Bottom 12 N A N A N A N A A N A N A N A A A A A 1 8 4 5 3 5 3 1 N N N N N ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information Allowable Source Derivation for 2 25 MeV or lower photons Transport Condition NCT HAC Source Case Full Cavity 2 5 f 55 gal Centered Pt Corner Pt Side Point Full Cavity Corner Pt MCNP Case NCT 225 NCT 225 NCT 225 NCT 225 pt4 NCT 225 pt4 NCT 225 pt4 HAC 225 HAC 225 pt fullcav 25ft3t 55gal ctr tcor side fullcav tcor Relative Error for Max Response ES Location Side 0 4 0 3 0 3 0 2 1 2 Surface Surface Side I L Side M 0 5 0 8 0 5 0 3 0 5 0 3 0 4 0 2 0 5 7 8 Surface Surface Bottom 1 4 1 4 1 4 0 9 1 4 0 6 Side 3 1 3 1 5 0 9 N A N A N A 0 4 1 9 EIUS eae M RC NER Rm N A Allowable Source Derivation for 1 83 MeV or lower photons Transport Condition Source Case Full Cavity 2 5 f 55 gal Centered Pt Corner Pt Side Point Full Cavity Corner Pt MCNP Case Location NCT 183 fullcav NCT 183 25ft3t NCT 183 55gal ctr tcor side Relative Error for Max Response RE Surface
21. C 122 F for 28 days in accordance with Test Method 2 in appendix B of this part or C 60 C 140 F for 14 days in accordance with Test Method 3 in appendix B of this part ili Alternative procedures or rates of permeation are permitted if they yield a level of safety equivalent fo or greater than that provided by paragraph e 3 ii of this section and are specifically approved by the Associate Admin istrator for Hazardous Materials Safety ER 01 002 Rev 1 Page 6 of 15 4 Mixed contents Hazardous materials may not be packed or mixed together in the same outer packaging with other hazardous or nonhazardous materials if such materials are capable of reacting dangerously with each other and causing i Combustion or dangerous evolution of heat ii Evolution of flammable poisonous or asphyxiant gases or iii Formation of unstable or corrosive materials 5 Packagings used for solids which may become liquid at temperatures likely to be encountered during transportation must be capable of containing the hazard ous material in the liquid state This section contains specifications that must be met by the shipper f Closures 1 Closures on packagings shall be so designed and closed that under conditions including the effects of temperature and vibration normally incident to transportation i Except as provided in paragraph g of this section there is no identifiable re lease of hazardous materials to the envir
22. Chapter 7 of the SAR During transport the cask is tied ER 01 004 Rev 1 Page 9 of 20 down to the trailer deck The tiedown system is evaluated structurally in Section 2 4 4 of the Safety Analysis Report SAR b Each lifting attachment that is a structural part of the package must be designed with a minimum safety factor of three against yielding when used to lift the package in the intended manner and it must be designed so that failure of any lifting attach ment under excessive load would not impair the ability of the package to meet other requirements of this subpart Any other structural part of the package which could be used to lift the package must be capable of being rendered inoperable for lifting the package during transport or must be designed with strength equivalent to that required for lifting attachments Section 2 4 3 of the SAR demonstrates that the structural requirements of the lifting attachments are met Failure of the lifting attachment will not impair the ability of the package to meet other requirements of this subpart There are no other structural parts of the package that could be used to lift it c The external surface as far as practicable will be free from protruding features and Will be easily decontaminated The external surfaces of the package are free of protruding features except those necessary for the package to perform its function The external surfaces are hard and smooth and therefore easily
23. Ci 3 7E 10 y sec Dividing by the mass of 100 g the source strength density is 3 7E 08 y sec The mass density is assumed to be uniform for the 100 gram piece of metal Select the Limits Resin Payload Item Since this payload item does not meet the definitions of either of the two discrete shored configurations 2 5 ft or 55 gal it is a general type payload The limits in columns O and apply for y sec and y sec g respectively Activated Metal Payload Item This payload item is small and fits within the defined envelope for the 2 5 fc payload however it is not shored and so the activated metal is also a general type payload item Columns O and apply for the y sec and y sec g limits respectively Sum the Fractions For this example there are six lines 1 3 are for the resin gamma emitters 4 5 are for the bremsstrahlung gammas produced by Sr and Y and one line for the activated metal Co Shape Energy Payload Source Term Discrete MeV or Fin Only Nuclide y sec y secig Energy y sec y secig y sec y secig __ 08348 148E 11 2 72E 04 09 0 8 63E 11 0 5 54E 07 1 71E 01 4 91E 04 4 91E 04 192E 08 3 53E 01 0 7 0 2 13E 12 0 1 89E 08 9 01E 05 1 87E 07 1 87E 07 227 939E 09 1 73E 03 275 0 1 29E 10 6 51E 05 7 30E 01 2 65E 03 2 65E 03 Co 60 3 70E 10 3 70E 08 Co 60 0 1 39E 11 1 18E 07 2 66E 01 3 13E 01 2 66E 01 Sum 2 75E 01 Since the sum is less
24. DOT and IAEA regulatory requirements 1 2 1 2 Configurations There are three configurations of the 8 120B cask e Configurations 1 and 2 were fabricated per the previously approved drawing Rev 13 and differ mainly in the inclusion Configuration 1 or lack Configuration 2 of the optional drain port Configuration 1 now includes sealing the drain port with the insertion and welding of a rod in the drain port Acceptance Testing of Configurations 1 and 2 are described in Section 8 1 Fabrication of Configurations 1 or 2 after April 1 1999 are not permitted e Configuration 3 does not have a drain port and the base plate is fabricated differently than Configurations 1 and 2 Acceptance Testing of Configuration 3 is described in Section 8 2 e Configurations 1 2 and 3 have the same Operations and Maintenance requirements and are described in Sections 7 0 and 8 3 respectively All configurations have the same structural thermal containment shielding and criticality evaluations 1 4 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 1 2 2 CONTENTS OF PACKAGING 12 21 Type form of material e Byproduct source or special nuclear material in the form of dewatered resins solids including powdered or dispersible solids or solidified material contained within secondary container s or e Radioactive material in the form of neutron activated metals or metal oxides in solid form contained within secondary co
25. Lift the primary lid and lower onto the cask and position using alignment marks and alignment pins Replace and hand tighten the twenty 20 2 inch primary lid bolts Tighten all the bolts hand tight before starting the torque sequence The use of impact wrenches for the installation of cask lid bolts is not permitted Torque all bolts to 250 25 ft Ibs lubricated using a star pattern It is recommended that the bolts be torqued a second time to 250 25 ft Ibs repeating the star pattern Page 30 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 Note 5 2 12 9 5 2 12 10 Note 5 2 12 11 Note 5 2 12 12 5 2 12 13 Pneumatic or hydraulic torque wrenches non impacting may be used to install the bolts Re torque all bolts to 500 50 ft Ibs lubricated using a star pattern It is recommended that the bolts be torqued a second time to 500 x 50 ft Ibs repeating the star pattern Check torque on all bolts at least once using a circular pattern to 500 50 ft Ibs If any bolts move go back to step 5 2 12 9 Start torque at the same start bolt used in Step 5 2 12 9 Torque the vent port socket head cap screw to 20 2 ft lbs If the vent port socket head cap screw is removed the vent port seal shall be inspected if damaged contact EnergySolutions CMF Prior to installation the vent port seal shall be installed on the vent port socket head c
26. MS 3WFN 14A44 North Bethesda MD 20852 Subject Inadvertent Omissions from Amendment Request for Certificate of Compliance No 9168 for the EnergySolutions 8 120B Type B Shipping Package Reference Letter from EnergySolutions S Sisley to NRC Subject Amendment Request for Certificate of Compliance No 9168 for the EnergySolutions 8 120B Type B Shipping Package Letterbook No ES NRC 13 010 May 23 2013 Dear Mr Saverot Per the referenced letter EnergySolutions submitted a request to NRC to amend Certificate of Compliance CoC for the Model 8 120B Shipping Package The request included both public and non public versions of Consolidated Revision 4 of the Safety Analysis Report SAR for the Model 8 120B Type B Shipping Packaging Subsequent to the submittal inadvertent omissions were identified in Chapter 7 of the SAR Enclosed is an electronic copy of the SAR change pages that should be substituted in both the public and non public versions of Consolidated Revision 4 of the Safety Analysis Report for the Model 8 120B Type B Shipping Packaging In addition a list of requested changes to the CoC amendment is included in the Attachment Should you or your staff have questions please contact the undersigned Sincerely Steven E Sisley Cask Licensing Manager EnergySolutions Products and Technology Group 408 558 3509 E Mail ssisley energysolutions com Attachment Requested Changes to CoC Amendment 2 pages Enclosure E
27. and Cs but it will be necessary to do the qualification by energy line for the remaining nuclides After converting the Ci data to gamma energy lines for the remaining nuclides neglecting any gamma energy lines 0 3 MeV the following source data are to be used for qualification The y sec g source strength densities are based on 12 000 Ibs the actual weight of the radioactive material The mass density is assumed to be uniform for the payload Energy Payload Source Term MeV or Nuclide y sec y secig Co 60 3 70E 11 6 80E 0 Cs 137 3 15E 11 5 78E 0 0 8348 1 48E 11 2 72E 0 Select the Limits Since this payload does not meet the definition of either of the two discrete shored configurations 2 5 ft or 55 gal it is a general type payload The limits in columns O and apply for y sec and y sec g respectively Sum the Fractions For this example there are three lines a Co line PICS line and one energy line 5 representing Mn Fe and Sr are disregarded because Fe gammas are below 0 3 MeV and the Sr betas are below 2E 12 f sec 7 15 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Discrete MeV or F min Only Nuclide y sec y sec g Energy y sec y secig y sec v sec g Shape Energy Payload Source Term Payload Item Type Solidified Waste Cont General Co 60 3 70E 11 6 80E 04 Co 60 0 1 39E 11 1 18E 07 2 66E 00 5 75E 03 5 75E 03
28. and Safeguards U S Nuclear Regulatory Commission Washington DC 20555 0001 Subject Additional Information for Amendment Request for Certificate of Compliance No 9168 for the Energy Solutions 8 120B Type B Shipping Package Docket No 71 9168 Dear Sir or Madam EnergySolutions hereby submits to NRC the enclosed Safety Analysis Report SAR for Model 8 120B Type B Shipping Package Consolidated Revision 7 dated November 2013 This SAR revision includes changes that address recent discussions with NRC regarding the draft Certificate of Compliance CoC for the amendment request Enclosure 1 contains one 1 paper copy of the non public version of the revised 8 120B Safety Analysis Report SAR that contains security related sensitive information that should be withheld under 10 CFR 2 390 Enclosure 2 contains one 1 paper copy of the public version of the revised 8 120B SAR in which all security related sensitive information is redacted A summary of changes included in the 8 120B SAR is provided in Attachment 1 of this letter Should you or any member of your staff have questions please contact the undersigned at 408 558 3509 Sincerely Steven E Sisley Cask Licensing Manager EnergySolutions Attachments 1 Summary of Changes 8 120B Consolidated SAR Revision 7 1 page 2105 South Bascom Ave Suite 230 Campbell California 95008 408 558 3500 Fax 408 558 3518 www energysolutions com ES NRC 13 025 November 13 2
29. c and d or evaluated against these tests by any of the methods author ized by 8173 461 a must prevent i Loss or dispersal of the radioac tive contents and ii A significant increase in the radiation levels re corded or calculated at the external surfaces for the condition before the test Therefore in addition to 178 350 the requirements for IP 2 packagings are given in the following sections of 8173 ER 01 002 Rev 1 Page 3 of 15 Subpart A General Subpart B Preparation of Hazardous Materials for Transportation 173 403 Definitions 173 410 General Design Requirements 173 465 Type A Packaging Tests The CNS 8 120B is assessed in Section 3 0 below of this report against each of the above requirements The requirements of 173 403 are not evaluated since it contains only definitions rather than specifications The methods for demonstrating compliance with the test requirements of 173 465 are given in 173 461 These are 1 performance of tests 2 reference to a previous satisfactory demonstration of compliance 3 performance of tests with models or 4 calculations or reasoned evaluation The primary method used in this report is method number 4 or reference to the cask SAR which also primarily uses method 4 This report evaluates the CNS 8 120B for meeting applicable IP 2 requirements By meeting IP 2 requirements the package will also meet the requirements for an IP 1 package 3 0 Results 49C
30. considering the possible migration of source material up into this region and up into the cask lid annulus the staff placed Condition 7 in the Revision 19 of the CoC that states that two independent physical verifications shall be performed to ensure proper closure This double verification provides reasonable assurance that material cannot migrate into this annulus during NCT In the application for Revision 20 to the CoC the applicant proposed to remove this condition from the CoC and add itto the operating procedures The applicant proposed modification to the language of this condition to waive the double verification requirement for contents that are too big to migrate into that region or for resins that are uniformly distributed and that occupy a significant volume of the cask such that if a small amount of this material were to migrate into this region that its impact on dose rates would be insignificant The staff used engineering judgment assuming that resins would be transported using a significant volume of the cask otherwise it would not be economically feasible for a user to ship and although a small amount of resins could migrate into the cask lid annulus the staff used engineering judgment to conclude that the amount of activity able to migrate into this region would be negligible The staff found that the proposed modification would still provide adequate assurance that material could not migrate up into the cask lid annulus to the ext
31. crud or powder source component must be qualified using only the y sec limits Gamma sources below 0 3 MeV may be neglected Any sources with gamma energies above 3 5 MeV are not qualified at this time Table 7 1 has two special rows for the common radioactive nuclides Co and Cs and so their fractions may be calculated directly without breaking them down into their separate energy lines Pure beta emitters e g 3H 3p TS sr y can affect package exterior gamma dose rates due to bremsstrahlung radiation These emitters must therefore be qualified by converting the beta source strength into an equivalent bremsstrahlung gamma source and entering the equivalent gammas like any other gamma source line in the sum of fractions Beta sources with maximum beta energies below 0 3 MeV or payload source strengths less than 2E 12 B sec may be neglected Beta sources with peak beta energies over 3 5 MeV are not qualified at this time Beta source strength from isotopes with significant gamma source strength may also be neglected The method for converting betas is presented in the procedure below and the methodology is discussed in Chapter 5 of the SAR Payload items with densities between 0 0 and 9 0 g cc are within the range of validity for Table 7 1 y sec g limits Most materials fall within this range with the exception of lead and some exotic metals Do not consider liner or other secondary container materials when calculating density Densit
32. defects and that the vent port seal o ring is properly installed on the socket head cap screw Obtain a replacement socket head cap screw from EnergySolutions CMF if defective Note If the vent port seal o ring is damaged contact EnergySolutions CMF The cask shall receive an annual leak test anytime the vent port seal is replaced 5 3 14 3 Visually inspect the vent port sealing surface to ensure that it is satisfactory and clean sealing surface if needed 5 3 14 4 Lubricate the threads of the socket head cap screw with anti seize Lubricate the vent port seal o ring with vacuum grease or petroleum jelly Carefully reinstall the socket head cap screw and seal o ring into the vent port and torque to Page 11 of 15 Air Pressure Drop Test for 8 120B Cask TR TP 002 Certificate of C onformance USA 9168 B U Revision 20 5 4 20 ft lbs in accordance with the cask handling procedure Reference 2 1 5 3 15 In the event of subsequent air pressure drop test failures refer to Appendix B for troubleshooting and contact EnergySolutions CMF for assistance 1f needed 5 3 16 After successfully completing the required air pressure drop test of the vent port seal o ring remove the air test manifold and all associated parts treating all parts as potentially contaminated and inspect the set screw plug to ensure that there are no defects i e cracks deformed or stripped threads etc If the set screw plug is defective obtain a repla
33. due to large uncertainties associated with calculating small dose rate responses discuss the process used to ensure that the dose rate response used to control the source limit is an accurate or conservative value See also RAI 5 4 This information is required by the staff to determine compliance with 10 CFR 71 47 and 10 CFR 71 51 a 2 Response to 5 5 The changes are not due to large calculational uncertainties As discussed in the response to RAI 5 2 we applied plate and sheet tolerances in these models since we took credit for the additional steel When we looked at how to apply the tolerances for the cask flange area we concluded that it would be non conservative to use the minimum thicknesses for drawing items 4 and 9 because that would move the lid lower pushing the source lower with respect to the top of the lead for the point source cases So we instead used maximum material thicknesses for items 4 and 9 This actually moved the lid point source upwards slightly resulting in more streaming over the top of the lead This drove the responses up for Cs 137 and the softer gamma energies whose peaks occur up above the edge of the lead Higher energy gammas peak at the cask midplane and were therefore not similarly affected ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information 5 6 Summary of SAR changes e None Discuss the effects of NCT on the thermal barrier and impact limiter models
34. effort and expense in generating equivalent information c Inorder to acquire such information a competitor would also require considerable time and inconvenience d The information consists of detailed descriptions properties and test data The availability of such information to competitors would enable them to modify their product to better compete with EnergySolutions take marketing or other actions to improve their product s position or impair the position of EnergySolutions product and avoid developing fabrication data in support of their processes methods and or apparatus e In pricing EnergySolutions products and services significant research development engineering analytical licensing fabrication quality assurance and other costs must be included The ability of EnergySolutions competitors to utilize such information without similar expenditure of resources may enable them to sell their product at prices reflecting significantly lower costs Further the deponent sayeth not I declare under penalty of perjury that the forgoing is true and correct Executedon OF Auquet Z013 Date Steven E Sisley Cask Licensing Manager EnergySolutions Page 4 of 4 ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information The responses to the NRC Request for Additional Information RAI associated with the EnergySolutions request to amend the Certificate of Compliance
35. increase in the radiation levels recorded at the external surfaces if they are subjected to the tests specified in ISO 1496 1 1995 E and iv For international transportation have a safety approval plate in conformance with 49 CFR 451 21 through 451 25 Not Applicable The CNS 8 120B Cask is not a freight container c Except for IP 1 packagings each offeror of an industrial package must maintain on file for at least one year after the latest shipment and shall provide to the Assoc ate Administrator for Hazardous Materials Safety on request complete documentation of tests and an engineering evaluation or comparative data showing that the construction methods packaging design and materials of construction comply with that specification ER 01 002 Rev 1 Page 12 of 15 This report will meet the requirements of this paragraph 173 465 c and d Type A packaging tests c Free drop test The specimen must drop onto the target so as to suffer maximum damage to the safety features being tested and 1 The height of the drop measured from the lowest point of the specimen to the upper surface of the target may not be less than the distance specified in Table 12 for the applicable package mass The target must be as specified in 173 465 c 5 Table 12 is as follows p Table 12 Free Drop Distance for Testing Packages to Normal Conditions of Transport Packaging mass Free drop distan
36. inspected within twelve months prior to use to verify that the welds specified by the applicable cask drawing are present and that no obvious weld defects are visible If paint is covering these welds the inspection may be completed without removing the paint 8 3 4 THERMAL TESTS No periodic or routine thermal testing will be performed on the 8 120B packaging 8 3 5 MISCELLANEOUS TESTS 8 3 5 1 Repair of Bolt Holes Threaded inserts may be used for repair of bolt holes The following steps shall be performed for each repair using a threaded insert a Install threaded insert s sized per manufacturer s recommendation per the manufacturer s instructions b Ata minimum each repaired bolt hole s will be tested for proper installation by assembling the joint components where the insert is used and tightening the bolts to their required torque value Note If the repair is to bolt holes for lifting components then a load test will also be performed to the affected components equal to 150 of maximum service load c Each threaded insert shall be visually inspected after testing to insure that there is no visible damage or deformation to the insert 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 84 REFERENCES 8 4 1 EnergySolutions Specification ES M 175 Polyurethane Foam Specification 8 4 2 EnergySolutions Specification ES C 038 8 120B Seal Specification 8 120B Safety Analysis Report Consoli
37. lid after positioning lid within guide pins approximately 1 inch above cask body start threading each of the 20 bolts by hand Once all bolts have been started clear the area and slowly place the lid onto the cask body Replace and hand tighten the twenty 20 2 inch primary lid bolts Tighten all the bolts hand tight before starting the torque sequence The use of impact wrenches for the installation of cask lid bolts is not permitted Torque all bolts to 250 25 ft Ibs lubricated using a star pattern It is recommended that the bolts be torqued a second time to 250 x 25 ft Ibs repeating the star pattern Pneumatic or hydraulic torque wrenches non impacting may be used to install the bolts Re torque all bolts to 500 50 ft Ibs lubricated using a star pattern It is recommended that the bolts be torqued a second time to 500 50 ft Ibs repeating the star pattern Check torque on all bolts at least once using a circular pattern to 500 50 ft Ibs If any bolts move go back to step 5 5 1 9 Start torque at the same start bolt used in Step 5 5 1 9 Torque the vent port socket head cap screw to 20 2 ft lbs If the vent port socket head cap screw is removed the vent port seal shall be inspected If the vent port seal is damaged contact EnergySolutions CMF Prior to installation the vent port seal shall be installed on the vent port socket head cap screw and a thin layer of anti seize should be applied
38. n o s d Specification packagings and UN standard packagings manufactured outside the U S 1 Specification packagings A specification packaging including a UN standard packaging manufactured in the United States must conform in all details to the applicable specification or standard in part 178 or part 179 of this subchapter 2 UN standard packagings manufactured outside the United States A UN stan dard packaging manufactured outside the United States in accordance with na tional or international regulations based on the UN Recommendations on the ER 01 002 Rev 1 Page 5 of 15 Transport of Dangerous Goods may be imported and used and is considered to be an authorized packaging under the prov sions of paragraph c 1 of this sec tion subject to the following conditions and limitations i The packaging fully conforms to applicable provisions in the UN Recommen dations on the Transport of Dangerous Goods and the requirements of this subpart including reuse provisions ii The packaging is capable of passing the prescribed tests in part 178 of this subchapter applicable to that standard and ii The competent authority of the country of manufacture provides reciprocal treatment for UN standard packagings manufactured in the U S Not applicable e Compatibility 1 Even though certain packagings are specified in this part it is nevertheless the responsibility of the person offering a hazardous material for tra
39. not have to be checked on bolts with security seals Remove cask lifting lugs from storage rack on trailer Visually inspect the cask lift lug bolts for defects and obtain replacement bolts from EnergySolutions CMF for any bolts that show cracking or other visual defects Lubricate bolt threads if required Visually inspect lid bolt holes for damage defects and accumulation of debris Remove debris if required Contact Page 33 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 5 3 3 7 5 3 3 8 Note Caution Note 5 3 3 9 Note 5 3 3 10 5 3 3 11 CMF for any bolt holes that show signs of cracking or visual signs of distress Install lifting lugs on cask and torque bolts to 200 20 ft Ibs lubricated Connect lifting equipment to the two 2 cask lifting lugs Adequate lifting and handling equipment is the responsibility of and will be provided by the user Do not use primary lid or secondary lid lifting lugs to lift cask The cables used to lift the cask must have a true angle of not less than 60 with respect to the horizontal Lift cask out of bottom impact limiter using suitable lifting equipment Empty weight of the cask with lids is approximately 49 640 pounds or as stated on cask nameplate Total gross design weight of loaded cask is approximately 63 000 pounds Position the cask on a firm level supported area Remove the cask li
40. of contents 14 150 Ibs including shoring and secondary containers iv Powdered or dispersible solid materials must have a mass of at least 60 grams or a specific activity of 50 A2 g or less v Explosives corrosives and non radioactive pyrophorics are prohibited Pyrophoric radionuclides may be present only in residual amounts below 1 weight per cent vi Materials that may auto ignite or change phase at temperatures below 350 F not including water shall not be included in the contents Also contents shall not include any materials that may cause any significant chemical galvanic or any other reaction vi Powdered radioactive materials shall not include radioactive forms of combustible metal hydrides or combustible element metals i e magnesium titanium sodium potassium lithium zirconium hafnium calcium zinc plutonium uranium and thorium or combustible non metals e g phosphorus viii Contents may only include quantities of boron lithium or beryllium such that these materials do not constitute quantities sufficient to be considered as a bulk material for a payload item or a portion of that payload item 6 In addition to the requirements of Subpart G of 10 CFR Part 71 i The package must be prepared for shipment and operated in accordance with the Operating Procedures of Chapter 7 of the application ii The packaging must be tested and maintained in accordance with the acceptance tests and maintenan
41. point source without credit for shoring Table 5 1 in the application provides the maximum NCT and HAC dose rates for these two cases The applicant has incorporated a 596 margin into the package operations to offset uncertainties in the shielding evaluation method and thus ensuring that the package dose rates do not exceed the regulatory limits The staff found that the package meets the regulatory dose rate limits in 10 CFR 71 47 for exclusive use shipments and the dose rate limits for HAC specified in 10 CFR 71 51 for these two nuclides 5 2 Radiation Source Contents proposed for transport include byproduct source or special nuclear material in the form of dewatered resins solids powdered or dispersible solids solidified materials or radioactive materials in the form of activated metals or metal oxides in solid form All these contents are to be contained within a secondary container s As described the proposed contents may contain gamma sources neutron sources and beta sources i e gamma emitting neutron emitting and beta emitting materials The proposed contents limits are 3 000 times a Type A quantity with further limits Gamma emitting contents are limited to materials with gamma energies up to 3 5 MeV and limited by the procedure in Attachment 1 to Chapter 7 of the application The limits for gamma sources are in terms of specific gamma energies There are also specific limits proposed for Co 60 and Cs 137 In the applicatio
42. primary lid test port by placing the manifolds trunk down into test pot Next hand tighten the threaded bushing until it is snug If needed a wrench may be used to tighten the bushing but only 1 4 turn or less until snug Note Over tightening can cause damage to the test manifolds o ring and the test port threads Use caution and proceed slowly to ensure test manifold bushing is not over tighten Ensure the Air Regulator Inlet Valve located on the inlet side of the Air Regulator and the Leak Test Supply Valve located on the inlet side of the Test Pressure Gauge are both closed Connect the adaptor test manifold to the primary lid test port Note Use extreme caution when connecting adapter test manifold to test port to prevent damage to test port threads Set the Air Regulator located on the manifold to 0 psig or OFF and connect the air supply to the manifold Caution A very small volume is being pressurized Use extreme care and do not exceed 20 psig Slowly open the Air Regulator Inlet Valve Slowly open the Leak Test Supply Valve After the Leak Test Supply Valve is open slowly adjust the Air Regulator to obtain 18 psig 1 0 psig on the Test Pressure Gauge Use extreme care so the Test Pressure Gauge is not over pressurized Page 8 of 15 Air Pressure Drop Test for 8 120B Cask TR TP 002 Certificate of C onformance USA 9168 B U Revision 20 Note Dueto temperature changes it may be necessary to adju
43. seals are provided for the closures Installation of these prior to shipment is required by Chapter 7 of the SAR b The smallest external dimension of the package i is nor less than 10 centimeters 4 inches The smallest external dimension exceeds 4 c Containment and shielding is maintained during transportation and storage in a temperature range of 40 C 40 F to 70 C 158 F Special attention shall be given to liquid contents and to the potential degradation of the packaging materials within the temperature range ER 01 004 Rev 1 Page 11 of 20 As discussed in Sections 2 6 1 2 6 2 3 4 2 3 4 3 3 4 4 and 4 2 2 of the SAR the components of the package are designed to maintain containment and shielding during transportation and storage in the temperature range specified in this paragraph Special attention to liquid contents is specified in 49CFR173 412 k In the event that liquids are being shipped it is the responsibility of the shipper to verify the liner s ability to perform in the referenced temperature range d The packaging must include a containment system securely closed by a positive fastening device that cannot be opened unintentionally or by pressure that may arise within the package during normal transport Special form Class 7 radioactive material as demons rated in accordance with 173 469 may be considered as a component of the containment system If the containment system forms a separate unit of the
44. surfaces 5 2 8 1 Attach crane hook to the pallet lifting ring Page 27 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 5 2 8 2 Lift pallet straight up out of cask 5 2 8 3 Position the pallet for disposal or future handling 5 2 8 4 Empty the pallet Warning Treat all materials removed from the pallet as potentially radiologically contaminated 5 2 8 5 Recover pallet for reuse Clean and decontaminate the pallet if necessary Detach the crane hook 5 2 8 0 Repeat Steps 5 2 8 through 5 2 8 5 to remove and empty the other pallet from the cask 5 2 9 The Health Physics Technician shall survey the interior of the cask for radiation and contamination levels Decontaminate if acceptable levels as per Site procedures are exceeded Warning Treat any liquid in the cask or used in decontamination process as potentially radiologically contaminated Warning Radioactively contaminated liquids may be pumped out or removed by use of an absorbent material Removal of any material from inside the cask shall be performed under the supervision of qualified Health Physics personnel with the necessary H P monitoring and radiological health safety precautions and safeguards 5 2 10 Visually inspect the inside of the cask for damage foreign materials or liquid accumulation If the interior surfaces of the cask are damaged remove the cask from service and report any noted defects to En
45. that do not pass all 10 statistical checks performed by MCNP Table 5 5 5 11 Updated to reflect results of Revised in response to RAI 5 6 Figure 5 3 thru revised shielding analysis and 5 7 Figure 5 4 5 13 7 1 9B 7 3 Revised step and added footnote Revised in response to RAI 7 1 to clarify when the requirement is waived ES NRC 13 017 August 9 2013 Attachment 1 Page 3 Summary of Changes 8 120B Consolidated SAR Revision 5 Section Page s Change Purpose Table 7 1 and 7 10 Updated to reflect results of Revised in response to RAI 5 6 examples in 7 14 revised shielding analysis and 5 7 Attachment 1 7 16 of Chapter 7 7 18 7 21 thru 7 24 8 2 5 8 5 Revised to clarify required testing Revised to address issue for containment seals M bullet identified during inspection of and replaced reference to fabrication activities and specification 3 bullet editorial change 8 4 8 11 Changed section from an appendix Specifications which were not to references included in the appendix are references The section has been revised to reflect this AFFIDAVIT PURSUANT TO 10 CFR 2 390 State of California SS County of Santa Clara I Steven E Sisley depose and say as follows 1 I am Licensing Manager of EnergySolutions Products and Technology Group and have been delegated the function of review
46. the 2 meter NCT dose rate limits were only applied to the package s radial side These calculations were performed for each of several gamma energies in the range of 0 5 to 3 5 MeV see Table 5 5 of the SAR and for the two common source nuclides Co 60 and Cs 137 The results of these calculations were used to create Table 5 5 of the SAR and Table 1 of Attachment 1 to Chapter 7 of the SAR the package operations The quantity limits for distributed sources are in terms of source strength density instead of source strength To allow some flexibility in this regard for the package contents the applicant has limits for three distributed source volumes the entire package cavity 55 gallon drum and 2 5 ft The applicant compared the source strengths point sources and source strength densities distributed sources that were calculated to meet each dose rate limit NCT and HAC for the locations described above for each of the selected gamma energies and nuclides The smallest source strength or source strength density that resulted in dose rates at a regulatory limit is the most limiting for the contents and is used in the tables as the limit for the contents source strength or source strength density for each gamma energy or nuclide for each contents configuration For the smaller distributed sources the comparison includes NCT cases with sources having the respective volumes and HAC cases for the full cavity volume The staff found the appro
47. the ratchet binders hand tight and return ratchet handles to storage position leaving flip block in the lock position Tools wrenches pipes etc are not permitted to be used on any cask ratchet binder Using these tools will cause damage to ratchet binders Place security seals on the impact limiter Install impact limiter lifting lug covers Inspect the cask tie down cables for tightness Tighten if necessary The Health Physics Technician shall survey all exterior surfaces of the cask for contamination and radiation levels Decontaminate as required to meet the limits set in Site radiation and contamination release procedures and Reference 3 2 Before the empty cask leaves the shipper s facility the following shall be confirmed Page 39 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 6 0 7 0 5 5 7 1 5 5 7 2 5 5 1 3 5 5 7 4 5 5 7 5 5 5 7 6 5 5 7 7 Cask verified to be empty of radioactive waste For foreign material exclusion concerns cask internals must also be verified clean and clear of all non radioactive debris Cask internal and external removable contamination does not exceed Site Release Limits 49 CFR 173 428 49 CFR 173 443 and 10 CFR 71 87 as applicable see References 3 2 and 3 5 The cask lid bolts and vent port socket head cap screw are properly torqued Trailer placarding and cask labeling and marking meet D O T specifica
48. to cask or lid seal surfaces Inspect the bolts holes for defects Contact EnergySolutions for any bolt holes that show signs of cracking or visual signs of distress 7 2 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 7 1 8 Inspect cask interior for damage loose materials or moisture Clean and inspect seal surfaces Replace seals when defects or damage is noted which may preclude proper sealing Contact EnergySolutions if damage is present NOTE Radioactively contaminated liquids may be pumped out or removed by use of an absorbent material Removal of any material from inside the cask shall be performed under the supervision of qualified health physics personnel with the necessary H P monitoring and radiological health safety precautions and safeguards NOTE When seals are replaced leak testing is required as specified in Section 8 3 2 1 NOTE Verify intended contents meet the requirements of the Certificate of Compliance NOTE Ensure the contents secondary container and packaging are chemically compatible i e will not react to produce flammable gases 7 1 9 Place disposable liner drums or other containers into the pre positioned shoring and install additional shoring or bracing if necessary to restrict movement of contents during normal transport 7 1 9A Process liner as necessary and cap using standard capping devices Provide shoring if necessary to limit movement during transport or
49. to include modeling minimum steel plate thicknesses Table 5 5 5 Changed table to report results of Updated based on results of revised shielding evaluation revised shielding evaluation Figure 5 3 5 Changed figure to report results of Updated based on results of revised shielding evaluation revised shielding evaluation Figure 5 4 5 Changed figure to report results of Updated based on results of revised shielding evaluation revised shielding evaluation 6 2 Added blank page Editorial formatting for two sided printing 11 12 13 ES NRC 13 026 November 13 2013 Page 4 of 9 Consolidated Summary of Changes 8 120B Consolidated SAR Revisions 4 through 7 Table 7 1 7 10 Changed table to report results of Updated based on results of revised shielding evaluation revised shielding evaluation Attachment 1 1 4 Example 1 Steps 5 7 4 Attachment 1 6 Example 2 ad Steps 5 7 7 7 Attachment 1 7 1 Example 3 Steps 5 7 7 1 8 Attachment 1 21 26 Updated based on results of revised shielding evaluation Revised example data 4 Revised example data Updated based on results of revised shielding evaluation 4 Revised example data Updated based on results of revised shielding evaluation 4 Revised example data Updated based on results of Example 4 revised shielding evaluation Steps 5 7
50. to the response Plus as discussed in Appendix 8 of the NU 391 calculation a 5 administrative margin is applied which more than offsets the potential uncertainties in the analysis Summary For Rev 7 Analysis Results The following applies for the revised shielding analysis results presented in Rev 7 of the NU 391 calculation a copy of which is included in this RAI response ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information e All dose rate results have relative error levels under 0 1 e All dose rate results that govern any of the final payload source limit results presented in Table 6 1 1 of the calculation have relative error levels under 0 05 e Only four of the tally surfaces that govern any of the final payload source limit results presented in Table 6 1 1 of the calculation miss only one of the 10 the statistical checks performed by MCNP Any potential uncertainties in those four results are judged to be very small as discussed above e All non governing results from tallies that do not pass all 10 statistical checks would have to increase substantially by over seven times the MCNP output relative error level before they would affect any of the payload source limit results Summary of SAR changes e Text is added to the uncertainties and conservatisms section of Section 5 4 1 which briefly discusses results with relative error levels between 0 05 and 0 1 and tall
51. to the vent port socket head cap screw threads Seal the primary lid with security seals Ensure that all dirt clay debris is removed from the cask lids prior to installation of the cask impact limiter Page 38 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 5 5 4 Replace secondary lid thermal shield and upper impact limiter Warning Ensure inner surfaces of impact limiter are below external package limits as specified in Reference 3 2 and or site release limits Also this should include any enclosed surfaces of external cask body 5 5 5 5 5 6 5 5 7 5 5 4 1 5 5 4 2 5 5 4 3 5 5 4 4 5 5 4 5 Note 5 5 4 6 Note 5 5 4 7 5 5 4 8 Using suitable lifting equipment lift inspect for damage and install the secondary lid thermal shield Contact EnergySolutions CMF if damage is present Install the three secondary lid thermal shield retaining pins into the secondary lid lift lugs and insert the ball lock pins into the retaining pins Attach the crane hook to the lifting lugs on the impact limiter lift it and inspect for damage Position the impact limiter on cask using alignment marks on the cask body and impact limiter and detach the crane hook Replace the top bolts in the ratchet binders Insert holding pins Visually inspect ratchet binder bolts for any signs of cracking or other visual defects Replace any defective bolts or pins Tighten
52. used for preparation of empty packages Section 7 0 was revised to reference Section 8 3 2 1 for the leak test requirements for powdered solid shipments The leak test requirement for leaktight status included in Section 4 9 of the application has been also included in Chapter 8 of the application In order to remove Condition No 7 of the previous CoC the following changes were made i the last paragraph in Section 7 0 now specifies that shipments of powdered solids do not require a leaktight package just that the periodic leak test is performed to leaktight standards This paragraph also refers to Section 8 3 2 1 of the application rather than Section 4 9 ii a new step 7 1 21 6 was added for the shipper to confirm that the package was tested leaktight and iii Section 8 3 2 1 of the application was revised to incorporate the requirements from Section 4 9 for leaktight testing 9 The applicant included a new step step 7 1 10 in the operating procedures to require two independent physical verifications of the secondary s container closure system for contents such as activated metals or radioactive sources for which hot particle migration may occur The basis for the double verification is to ensure that small high specific activity particles do not have the potential to migrate up into the annular gap between the primary lid and the package bolting flange The double physical verification requirement is waived only for uniformly dis
53. whereas four of the cases missed 2 of the 10 checks The other 36 cases missed only one check ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information Furthermore only six of the tallies contained a tally segment result that governed any of the payload source limits presented in Table 6 1 1 of the NU 391 calculation For all other cases the peak tally segment dose rate result would have had to increase by more than 20 times the relative error level before it would govern any of the payload source limit results It was concluded that the non governing tallies were acceptable as it was not deemed credible that the MCNP output confidence intervals were a factor of 20 or more too low because 1 3 of the 10 statistical checks were missed Evaluation of Rev 7 Results As discussed in the response to RAI 5 6 all the NCT cases were rerun with adjusted impact limiter dimensions Also as discussed above in this response some of the HAC cases were rerun with longer computer run times The new analysis results are presented in the NU 391 Rev 7 calculation package These new results were also examined to check for passage of the 10 statistical checks Examination of the Rev 7 shielding analysis results showed that 47 of the 500 tallies did not pass all 10 checks Two tallies missed three checks 6 tallies missed two checks and the remaining 39 tallies only missed one check All non governing tallies woul
54. with Section 8 2 2 5 8 3 1 STRUCTURAL AND PRESSURE TESTS No routine or periodic structural or pressure testing will be performed on the 8 120B packaging 8 3 2 LEAKAGE TESTS 8 3 2 1 Periodic and Maintenance Leak Test The 8 120B packaging shall have been leak tested as described below within the preceding 12 month period before actual use for shipment and after maintenance repair such as weld repair or replacement of components of the containment system Shipments of powdered radioactive materials shall be performed only when the most recent periodic leak test meets the requirements for leaktight status The 8 120B packaging seals shall have been replaced within the 12 month period before actual use for shipment General requirements e Testing method Per ANSI N 14 5 in accordance with ASTM E 427 if using a halogen leak detector or ASTM E 499 if using a helium leak detector e Test Sensitivity the test method must be capable of meeting the appropriate sensitivity requirements specified in Figures 4 4 or 4 7 or 5 0 x 10 atm cm sec for leaktight status Calibration of the leak detector shall be performed using a leak rate standard traceable to NIST e The leak standard s setting shall correspond to the approved leak test rate see Section 4 0 A maximum leak rate of 1 0 x 10 atm cm sec of air is required leaktight status 8 6 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 e Any con
55. within its volume mass since the analysis and qualification is based on the highest source strength density material that occurs anywhere within the payload Once the applicable y sec source strength and y sec g source strength density are determined for the payload they are compared to the corresponding limits that are determined as discussed above 7 8 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 For some payloads use of the highest source strength density may be inappropriately conservative e g payloads with a small mass of high source strength density material within a large mass of much lower source strength density material The qualification methodology takes these payloads into consideration and allows the payload to be separated into distinct components or payload items for which the qualification process is performed separately e g one qualification for the high source strength density components materials and another qualification for the low source strength density materials As an example for radiologically non homogenous materials such as contaminated soil with hot chunks the components would be the soil and the hotter particles Crud contamination or any similar finely distributed powder or granular sources must be treated separately if there is a potential for redistribution i e if the source is not chemically or physically bound to its substrate or bulk material In such cases the
56. 013 Page 2 of 2 Enclosures 1 Safety Analysis Report for the Model 8 120B Type B Shipping Packaging Consolidated Revision 7 November 2013 Non Public Version 1 paper copy Security Related Information Withhold Under 10 CFR 2 390 2 Safety Analysis Report for the Model 8 120B Type B Shipping Packaging Consolidated Revision 7 November 2013 Public Version 1 paper copy cc Mr Pierre Saverot Division of Spent Fuel Storage and Transportation Mr Dan Shrum EnergySolutions ES NRC 13 025 November 13 2013 Attachment 1 Page 1 The following is a summary of the changes incorporated in Revision 7 of the 8 120B Consolidated Safety Analysis Report The revisions indicators in the margins of Revisions 4 through 6 of the 8 120B Consolidated Safety Analysis Report have also been included in Revision 7 to indicate the cumulative changes that have been made in association with the request to amend the 8 120B CoC However the summary of the changes incorporated in Revisions 4 through 6 of the 8 120B Consolidated Safety Analysis Report are not repeated below Summary of Changes 8 120B Consolidated SAR Revision 7 Section Page s Change Purpose 1 2 2 3 Correct section cross reference in Editorial correction 1 sentence of 3 paragraph 7 0 7 1 Revised last paragraph of section Leak test requirements for to reference Section 8 3 2 1 for the leaktight s
57. 1 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 e Interior side of the inner o ring for the secondary lid Leak detection shall be in accordance with the specifications of ASTM E 427 Any condition which results in leakage in excess of the applicable values specified in Figures 4 3 and 4 6 in Chapter 4 shall be corrected 8 1 4 COMPONENT TESTS Gaskets and seals will be procured and examined in accordance with the EnergySolutions Quality Assurance Program 8 1 5 TEST FOR SHIELDING INTEGRITY Shielding integrity of the package will be verified by gamma scan or gamma probe methods to assure the package is free of significant voids in the poured lead shield annulus All gamma scanning will be performed on a 4 inch square or less grid system The acceptance criteria will be that voids resulting in shield loss in excess of 10 of the normal lead thickness in the direction measured shall not be acceptable Remedy for an unacceptable gamma scan include actions such as controlled re heating of the cask body to melt the lead to remove any voids or streaming paths This process may be used as long as average metal temperatures are kept below 800 F If the remedy could affect more than just the unacceptable area e g re heating of the cask body all affected portions will be re scanned 8 1 6 THERMAL ACCEPTANCE TESTS No thermal acceptance testing will be performed on the 8 120B package Refer to the Thermal Evaluation Cha
58. 20852 Subject Consolidated Summary of Changes for the EnergySolutions 8 120B Type B Shipping Package SAR References 1 Letter from EnergySolutions S Sisley to NRC Subject Amendment Request for Certificate of Compliance No 9168 for the EnergySolutions 8 120B Type B Shipping Package Letterbook No ES NRC 13 010 May 23 2013 2 Letter from EnergySolutions S Sisley to NRC Subject Inadvertent Omissions from Amendment Request for Certificate of Compliance No 9168 for the EnergySolutions 8 120B Type B Shipping Package Letterbook No ES NRC 13 013 July 3 2013 3 Letter from EnergySolutions S Sisley to NRC Subject Response to Request for Additional Information for the Model No 8 120B Package Docket No 71 9168 Letterbook No ES NRC 13 017 August 9 2013 4 Letter from EnergySolutions S Sisley to NRC Subject Response to Request for Additional Information for the Model No 8 120B Package Docket No 71 9168 Letterbook No ES NRC 13 019 September 20 2013 5 Letter from EnergySolutions S Sisley to NRC Subject Additional Information for Amendment Request for Certificate of Compliance No 9168 for the EnergySolutions 8 120B Type B Shipping Package Docket No 71 9168 Letterbook No ES NRC 13 025 November 13 2013 Dear Mr Saverot In support of the most recent request to amend the 8 120B Certificate of Compliance CoC EnergySolutions submitted multiple revisions of the Safety Analysis Report in R
59. 20B C of C Number 9168 Revision 25 Warning Treat all debris removed from the bottom surface of the 3 2 12 3 5 2 12 4 Caution 3 2 12 5 Note 5 2 12 6 5 2 12 7 Note Caution 5 2 12 8 lid as potentially radiologically contaminated Clean the bottom surface of the lid and inspect lid bolt holes for damage and accumulation of debris Remove debris if required Visually inspect and clean O Ring seating surfaces for any damage or material that will prevent O Rings from forming a seal If inspection is satisfactory apply a very thin coat of vacuum grease or petroleum jelly Contact Energy Solutions CMF if any damage nicks gauges or anything that might interfere with the o rings sealing properly Care should be taken during handling operations to prevent damage to cask sealing surfaces Visually inspect the cask lid bolts for defects and obtain replacement for any bolts that show cracking or other visual defects Lubricate bolt threads if required and Visually inspect lid bolt holes for damage defects and accumulation of debris Remove debris if required Contact Energy Solutions CMF for any bolt holes that show signs of cracking or visual signs of distress To more easily seat primary lid after positioning lid within guide pins approximately 1 inch above cask body start threading each of the 20 bolts by hand Once all bolts have been started clear the area and slowly place the lid onto the cask body
60. 60 pounds and the gross weight of the packaging and cask payload must not exceed 74 000 pounds Rigging used to lift cask components must be designed to the larger of the weights above or the as built weight indicated on the weight nameplate Page 3 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 30 REFERENCES 3 1 CFR Title 49 Part 172 3 2 CFR Title 49 Parts 173 401 173 478 3 3 Procedure TR TP 002 Air Pressure Drop Test for Model 8 120B Cask 3 4 Procedure CMF RS PR 6003 Cask Maintenance Facility CMF Quality Assurance Records 3 5 Code of Federal Regulations CFR Title 10 Part 20 and Part 71 3 6 Procedure TR MN 005 Gasket Seal O Ring Replacement Repair Procedure for EnergySolutions Cask Fleet 3 7 Transport Cask Model 8 120B Certificate of Compliance 9168 3 8 Drawing C 110 E 0007 8 120B Shipping Cask 3 9 Procedure ES AD PR 008 Condition Reports 4 0 REQUIREMENTS 4 Tools Materials Equipment At Loading Site 4 EnergySolutions Furnished Items 4 1 1 4 1 1 2 4 1 1 3 4 1 1 4 4 1 1 5 8 120B cask impact limiters tiedowns and trailer 8 120B cask license and documentation 8 120B cask lid O Rings O Ring Seals 8 120B cask disposable liner shoring or drum pallets if required by the shipper Test manifolds for performing air leak test 4 1 2 Shipper Furnished Items 4 1 2 1 4 1 2 2 Crane compatible with filled liner loaded drum pallet c
61. 73 24b Additional general requirements for bulk packagings This section contains specifications that must be met by the shipper 173 25 Authorized packages and overpacks Us Not applicable this section addresses specifications for overpacks and the package is not classified as an overpack 173 26 Quantity limitations When quantity limitations do not appear in the packaging requirements of this subchap ter the permitted gross weight or capacity authorized for a packaging is as shown in the packaging specification or standard in part 178 or 179 as applicable of this subchapter The permitted capacity and gross weight is given in Chapter 1 of the SAR and marked on the package nameplate 173 27 General requirements for transportation by aircraft Not applicable the CNS 8 120B is not designed to be transported by aircraft 173 28 Reuse reconditioning and remanufacture of packagings a General Packagings and receptacles used more than once must be in such condition including closure devices and cushioning materials that they conform in all respects to the prescribed requirements of this subchapter Before reuse each packaging must be inspected and may not be reused unless free from incompatible residue rupture or other damage which reduces its structural integrity The package is inspected as specified in Chapter 7 of the SAR before each reuse b Reuse of non bulk packaging A non bulk packaging used more than once
62. 8 Caution 5 2 2 9 Perform an external examination of the unopened package Record any significant observations Remove the impact limiter security seals Properly dispose of removed seals Remove impact limiter lifting lug covers Loosen ratchet binders securing impact limiter Remove holding pin and bolt from upper end of ratchet binder Retain bolts and holding pins for reinstallation Do not lose the ratchet binder holding pins Attach crane to lifting lugs on upper impact limiter using appropriate lifting gear Ensure alignment marks are on impact limiter and cask body Lift off impact limiter To prevent damage to the impact limiter place impact limiter carefully in set down area Remove the ball lock pins from each of the three retaining pins and remove the retaining pins from the secondary lid lift lugs Page 25 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 3 2 3 3 2 2 T0 Using suitable lifting equipment inspect for damage and remove the secondary lid thermal shield Contact EnergySolutions CMF if damage is present Care should be taken to prevent damage to the thermal shield during handling and storage Remove primary cask lid Warning 5 2 3 1 Caution 5 2 3 2 Note 5 2 3 3 Note Caution 3 2 3 4 Treat the underside of the lids the inside surfaces of the cask and any bolts or seals removed as potentially radiol
63. 803 758 1824 CNS IN 99 01 7 7 99 Page 2 of 2 Section 1 Certificate of Compliance 2 3 a 4 5 a Min aa 618 U S NUCLEAR REGULATORY COMMISSION 10 CER 71 1 a CERTIFICATE NUMBER 9168 CERTIFICATE OF COMPLIANCE FOR RADIOACTIVE MATERIAL PACKAGES b REVISION NUMBER c DOCKET NUMBER d PACKAGE IDENTIFICATION NUMBER PAGE PAGE 20 71 9168 USA 9168 B U 96 1 OF 4 a This certificate is issued to certify that the package packaging and contents described in Item 5 below meets the applicable safety standards set forth in Title 10 Code of Federal Regulations Part 71 Packaging and Transportation of Radioactive Mater al PREAMBLE b 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 THIS CERTIFICATE IS ISSUED ON THE BASIS OF A SAFETY ANALYSIS REPORT OF THE PACKAGE DESIGN OR APPLICATION ISSUED TO Name and Address b TITLE AND IDENTIFICATION OF REPORT OR APPLICATION EnergySolutions EnergySolutions application Revision No 7 dated Suite 100 Center Point II November 13 2013 100 Center Point Circle Columbia SC 29210 CONDITIONS This certificate is conditional upon fulfilling the requirements of 10 CFR Part 71 as applicable and the condition
64. 90 the test gas check Helium 4 4 a vacuum for the leak for gas leakage from N A ght test then the cask Lid inner O pressurize to 1 psig ring using the cask Lid test port After pressurizing the volume above After pressurizing the Vent Port Cap Evacuate cask cavity the cask cavity with Screw and Seal with R 134a Fig Fig to 20 Hg then the test gas check the test gas check 4 3 4 4 pressurize to 25 for gas leakage from for gas leakage from psig the Vent Port and the vent penetration Vent Seal on the inner side of Port the lid using a detector probe After pressurizin Evacuate cask cavity the one k cavity x Fig Fig Ru E the test gas check Helium vacuum for the leak N A 4 6 47 for gas leakage from tient xS men the Vent Port Cap pressurize to 1 psig Sume and sen Notes a leak test meets the requirements of Section 8 3 2 1 for leaktight status 8 8 Shipments of powdered radioactive materials shall be performed only when the most recent periodic 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 8 3 2 2 Pre Shipment Leak Test a This test 1s required before every 8 120B cask shipment to verify that the containment system has been assembled properly b The test will be performed by pressurizing the annulus between the O ring seals of each lid or inlet to the vent port with dry air or nitrogen to 18 psig Note The pre shipment leak test is typically performed
65. Calibration of the leak detector shall be performed using a leak rate standard traceable to NIST e The leak standard s setting shall correspond to the approved leak test rate see Section 4 0 e Any condition which results in leakage in excess of the maximum allowable leak rate specified in Figures 4 3 or 4 6 depending on the test gas used shall be corrected and re tested 8 2 44 Testing of the entire containment boundary will be performed prior to lead pour to allow access to all containment welds The containment boundary includes the inner shell the cask bottom base plate BOM 54A the bolting ring the lids the O ring seal plates of both lids the inner O ring of both lids and the vent port cap screw and its seal e Optional Insert the sealed metal cavity filler canister into the cask cavity Verify the canister does not obstruct the vent penetration The metal must be chemically compatible with the cask liner and the test gas e Assemble the cask lids per Section 7 1 e Evacuate the cask cavity to 20 Hg vacuum minimum sealed metal cavity filler canister may be used within the cask cavity e Pressurize the cask cavity to a minimum pressure of 1 25 psig with pure 1 1 1 2 tetrafluoroethane R 134a Or 2 lpsig with pure helium e Check for leakage of the inner shell and base plate components e Measure the leakage of the inner containment O ring via the test port in each lid e Check for leakage at the v
66. CoC for the Model No 8 120B Shipping Package are provided herein The NRC RAI questions which are shown in italics are followed by the ES response and a summary of the resulting changes to the 8 120B Safety Analysis Report CHAPTER 5 SHIELDING EVALUATION 5 1 Provide additional information on the radial thermal barrier Page 5 1 of the application states The impact limiters and radial thermal barrier provide a small amount of additional shielding From Drawing C 11 0 E 0007 Rev 19 sheet 4 it does not appear that the radial thermal barrier goes around the entire circumference of the package Clarify this drawing and state what is present if anything where there is no thermal barrier Regulations limiting dose rates apply to all points on the package Justify that the shielding model is bounding for places where there is no thermal barrier This information is required by the staff to determine compliance with 10 CFR 71 47 and 10 CFR 71 51 a 2 Response to 5 1 The radial thermal barrier is a 3 16 thick steel sheet that is supported above the cask outer shell by a spiral of 5 32 diameter wire wrapped around the outer shell body The thermal barrier does encircle the whole cask body There are notches around the four lift lug pads items 11 and four tie down lugs items 10 Our criteria for determining when to model discontinuities in shielding are whether a standard 3 ion chamber survey instrument would detect a signif
67. Derivation for 0 7 MeV or lower photons Transport Condition Source Case 55 gal Centered Pt Corner Pt Side Point NCT 070 55gal2 Full Cavity Full Cavity Corner Pt NCT 070 fullcav 2 5 ft NCT 070 25ft3s MCNP Case ctr tcor side Location Relative Error for Max Response RE 2 0 1 8 1 9 A N A N A 1 7 1 7 0 6 N A N A N A N A Side Side I L Side body Top 0 3 Surface 2 1 Surface Surface 0 7 0 9 0 5 0 5 N A N A teeta Pete va NA WA N A Bottom Side 1m Bottom Surface 6 296 1 1 1 0 2 8 2 4 2 8 0 6 0 4 3 3 0 9 0 5 0 5 1 5 1 2 va N A 15 ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information Allowable Source Derivation for 0 5 MeV or lower photons Transport Condition NCT HAC Source Case Full Cavity 2 5 ft 55 gal Centered Pt Corner Pt Side Point Full Cavity Corner Pt MCNP Case NCT 050 NCT 050 NCT 050 NCT 050 pt4 NCT 050 pt4 NCT 050 pt4 HAC 050 HAC 050 pt fullcav 25ft3s 55gal2 ctr tcor side fullcav tcor Location Relative Error for Max Response E Side 2 6 2 1 2 4 1 5 2 1 Surface Side I L 1 9 1 5 1 6 1 0 0 8 Surface Bottom 5 0 4 0 4 0 2 N A N A Side N A E 8 396 3 196 Es e f wa foe N A Became e ona epum ges 5s ON Surface Side M 2 8 2 2 2 4 1 0 2 4 2 6 Surface 0 5 0 3 0 4 0 2 1 3
68. Determine the shipping time to reach a hydrogen concentration of 596 in the package see NUREG CR 6673 Section 4 2 2 1 and Appendix F Example 4 If the time to reach 596 concentration is more than double the expected shipping time the shipment meets the hydrogen concentration requirement Authorize the shipment B L Anderson et al Hydrogen Generation in TRU Waste Transportation Packages NUREG CR 6673 Lawrence Livermore National Laboratory Livermore CA February 2000 7 25 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 This page intentionally blank 7 26 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 8 0 Acceptance Tests and Maintenance Program Acceptance tests for Configurations 1 and 2 have different weld examination and leak tests than Configuration 3 Maintenance is the same for all configurations Any reference to drawings either in general or by specific number means the drawings listed in the CoC 81 ACCEPTANCE TESTS CONFIGURATIONS 1 AND 2 CASKS FABRICATED BEFORE APRIL 1 1999 Prior to the first use of the 8 120B package fabricated to Configuration 1 or 2 the following tests and evaluations will be performed 8 1 1 VISUAL EXAMINATION The package will be examined visually for any adverse conditions in materials or fabrication Welds shall be examined for compliance to the drawings Weld integrity shall be verified by visual examination and magnetic particl
69. FR173 Subpart A General Subpart A does not include any prescriptive specifications for the package Part 173 Subpart B Preparation of Hazardous Materials for Transportation 173 21 Forbidden materials and packages This section contains specifications that are either not applicable to the 8 120B or that must be met by the shipper relative to contents of a shipment 173 22 Shipper s responsibility This section contains specifications that must be met by the shipper 173 22a Use of packagings authorized under exemptions This section is not applicable to the CNS 8 120B 173 23 Previously authorized packaging This section is not applicable to the CNS 8 120B ER 01 002 Rev d Page 4 of 15 173 24 General requirements for packagings and packages a Applicability Except as otherwise provided in this subchapter the provisions of this section apply to 1 Bulk and non bulk packagings 2 New packagings and packagings which are reused and 3 Specification and non specification packagings The CNS 8 120B is classified as a bulk packaging Therefore this section is applicable b Each package used for the shipment of hazardous materials under this subchapter shall be designed constructed maintained filled its contents so limited and closed so that under conditions normally incident to transportation 1 Except as otherwise provided in this subchapter there will be no identifiable without the use of instruments relea
70. H PHYSICS TECH HP 17 Cask payload including shoring Max 13 360 lbs 18 Decay heat if applicable Max 200 W 19 Gamma at 2 meters from trailer HP 20 Gamma at cask surface HP 22 Smearable beta gamma d m 100 cm HP 23 Smearable alpha d m 100 cm HP Thereby certify that the above statements are correct and the cask has been loaded and tested in accordance with approved procedures Operators Health Physics Tech s Supervisors Shipper s Page 41 of 41 T M NN Air Pressure Drop Test For Model 8 120B Cask Certificate of Compliance 9168 Revision 20 V7 SLibut 12 16 2013 Christopher S Libert Cask Operations Engineer Date Authored By Digitally signed by Steven Sisley Reviewed By Date 2013 12 16 11 02 35 08 00 Steven Sisley Cask Licensing Manager Date Approved By XY E Phillip H Th m as Director Cask Logistics Non Proprietary m New Proprietary T Title Change Restricted Information Revision Safeguards Information Rewrite El Sensitive Security Information Cancellation Effective Date January 1 2014 Electronic documents once printed are uncontrolled Refer to the Intraweb or the Document Control authority for the correct revision Air Pressure Drop T est for 8 120B Cask TR TP 002 Certificate of Conformance USA 9168 B U Revision 20 Table of Contents Section Page 1 SCOPE A I 9 3 1 1 A o P 3 A A PH RP 3
71. ND SHIPPED BACK TO CMF EMPTY IF PRIMARY LID SECONDAY LID OR VENT PORT O RINGS NEED REPLACED 4 3 2 DO NOT EXCEED A PRESSURE OF 20PSIG 4 3 3 DO NOT over tighten the manifold when connecting it to the test port If it is over tightened the o ring or adapter may be damaged Apply pressure very slowly to prevent damage to o ring 44 Acceptance Criteria The test pressure of 18 psig 1 0 must be held for fifteen 15 minutes 5 0 for the primary and secondary lids and the vent port A drop in pressure greater than the minimum detectable amount i e one half of the maximum graduation of the pressure gauge or 0 05 psig shall be cause for test failure Note EnergySolutionsrequires leak testing of the cask lids and vent port prior to every 8 120B cask shipment even if the lid bolts or vent port socket head cap screw have not been loosened during loading operations This requirement is necessary to assure that the 8 120B cask containment system is properly assembled prior to every shipment since it should not be assumed that the containment system is properly assembled prior to loading operations Note The primary lid secondary lid and vent port seal may be performed in non sequential order 4 5 Responsibilities 4 5 1 A person familiar with the requirements of this procedure shall perform the pressure drop test 4 5 2 A person familiar with the requirements of this procedure shall witness the pressure drop test to verify t
72. November 2013 Assemble packaging in accordance with loading procedure 7 1 10 through 7 1 19 PREPARATION OF EMPTY PACKAGING FOR TRANSPORT 7 3 1 1 3 2 1353 7 3 4 7 3 5 7 3 6 7 3 1 7 3 8 7 3 9 7 3 10 7 3 11 7 3 12 7 3 13 7 3 14 Confirm the cavity is empty of contents are far as practicable Survey the interior decontaminate the interior if the limits of 49 CFR 173 428 d are exceeded Install the lid Install the lid closure bolts Torque using a star pattern the twenty 20 primary lid bolts lubricated to 250 ft lbs 25 ft lbs Re Torque using a star pattern the twenty 20 primary lid bolts lubricated to 500 ft lbs 50 ft lbs Re install the vent port cap screw with the seal Torque the vent port cap screw to 2022 ft lbs Decontaminate the exterior surfaces of the package as necessary Inspect the exterior and confirm it is unimpaired Using suitable lifting equipment lift inspect for damage and install the secondary lid thermal shield Install the three secondary lid thermal shield retaining pins into the secondary lid lift lugs and insert the ball lock pins into the retaining pins Using suitable lifting equipment lift inspect for damage and install upper impact limiter on cask in the same orientation as removed Attach the tamper indicating seals Confirm the requirements of 49 CFR 173 428 are met 7 7 8 120B Safety Analysis Report Consolidated Revision 7 No
73. P 035 Revision 25 should include any enclosed surfaces of external cask body 5 1 2 7 1 5 1 2 7 2 5 1 2 7 3 5 1 2 7 4 3 1 2 1 5 Note 5 1 2 7 6 SJ 3 1 2 1 8 Using suitable lifting equipment lift inspect for damage and install the secondary lid thermal shield Contact EnergySolutions CMF if any damage is present Install the three secondary lid thermal shield retaining pins into the secondary lid lift lugs and insert the ball lock pins into the retaining pins Attach the crane hook to the lifting lugs on the impact limiter and lift it inspect for damage Position the impact limiter on cask using alignment marks on the cask body and impact limiter Replace the bolts in the ratchet binders Visually inspect ratchet binder bolts for signs of cracking or other visual defects Replace any defective materials Contact EnergySolutions CMF prior to replacing any defective materials Insert holding pins Tighten the ratchet binders hand tight and return the ratchet handles to their storage position leaving the flip block in the on tighten position Place security seals on the impact limiter or ratchet handles Install impact limiter lifting lug covers Procedure for Loading Liner into Cask If the liner is pre filled confirm that it has been capped using standard capping devices If the cask contains an empty unused liner the liner may be filled by removing only the secondary lid Refer to Sec
74. PTANCE TESTS AND MAINTENANCE PROGRAM Staff reviewed the licensing basis for the containment seals The applicant is qualifying a compound by performing extensive testing then by doing additional physical acceptance testing on each delivered O ring as a confirmatory measure The O rings are bought from a QL1 supplier whose quality system is audited to assure that when a compound is bought O rings to be procured in the future will have the same compound material on which extensive qualification testing was already done for this compound Section 8 3 2 1 was revised to include leak testing requirements for powdered solid shipments Regarding the maximum specified graduation on the pressure gauge the 0 1 psig graduation is no longer included as a requirement in Section 8 3 2 2 It is understood that the pressure gauge must be capable of measuring the pressure drop to the accuracy required to confirm that the acceptance criteria is satisfied CONDITIONS The conditions specified in the Certificate of Compliance have been revised to incorporate several changes as indicated below Item No 3 a has been revised to identify the new mailing address of Energy Solutions Products and Technology Group Item No 3 b has been revised to identify Energy Solutions consolidated application dated November 2013 10 Condition No 5 a 2 has been revised to add the description of the new Y inch thick steel plate covering the central hollow region of the
75. Page 4 of 20 3 Specification and non specification packagings The CNS 8 120B is classified as a bulk packaging therefore this section is applicable b Each package used for the shipment of hazardous materials under this subchapter shall be designed constructed maintained filled its contents so limited and closed so that under conditions normally incident to transportation 1 Except as otherwise provided in this subchapter there will be no identifiable without the use of instruments release of hazardous materials to the environ ment 2 The effectiveness of the package will not be substantially reduced for example impact resistance strength packaging compatibility etc must be maintained for the minimum and maximum temperatures encountered during transportation 3 There will be no mixture of gases or vapors in the package which could through any credible spontaneous increase of heat or pressure significantly reduce the effectiveness of the packaging This specification is demonstrated to be met in Section 2 6 10 in the CNS 8 120B SAR c Authorized packagings A packaging is authorized for a hazardous material only if 1 The packaging is prescribed or permitted for the hazardous material in a packag ing section specified for that material in Column 8 of the 172 101 Table and conforms to applicable requirements in the special provisions of Column 7 of the 172 101 Table and for specification packagings but not
76. QUE WRENCH CALIBRATION DUE DATE PRESSURE GAUGE TORQUE WRENCH PRIMARY LID Initial Pressure Psig Test Start Time Final Pressure Psig Test End Time Pressure Drop Psig Elapsed Time 15 5 0 minutes Pressure Drop lt Min Detectable Amount Section 4 4 Circle One Passed Failed SECONDARY LID Initial Pressure Psig Test Start Time Final Pressure Psig Test End Time Pressure Drop Psig Elapsed Time 15 5 0 minutes Pressure Drop lt Min Detectable Amount Section 4 4 Circle One Passed Failed VENT PORT Initial Pressure Psig Test Start Time Final Pressure Psig Test End Time Pressure Drop Psig Elapsed Time 15 5 0 minutes Pressure Drop lt Min Detectable Amount Section 4 4 Circle One Passed Failed Note If leakageis noted indicate actions taken in remarks section Retest is required upon test failure REMARKS TEST CONDUCTED BY TEST WITNESSED BY Page 13 of 15 Air Pressure Drop Test for 8 120B Cask TR TP 002 Certificate of C onformance USA 9168 B U Revision 20 APPENDIX B PAGE 1 TROUBLESHOOTING GUIDE FOR LEAK TESTING THE 8 120B CASK Listed below are some suggestions for performing an air leak test on the 8 120B cask Following these suggestions should help achieve a successful air leak test 1 10 11 12 Use extreme care when removing and or replacing the cask lids primary or secondary to prevent damage t
77. R d PACKAGE IDENTIFICATION NUMBER 9168 20 71 9168 USA 9168 B U 96 5 a 2 Packaging Description Continued The centered secondary lid is attached to the primary lid with twelve equally spaced 2 inch diameter bolts A thermal shield consisting of two polished stainless steel plates separated by a thin air gap is attached to the secondary lid lifting lugs with hitch pins A 72 inch thick steel plate covers the central hollow region of the lower impact limiter A 12 gauge stainless steel liner is welded to the cavity of the package and the lid surface to protect all accessible areas from contamination The containment boundary consists of the inner shell the upper baseplate the bolting ring the inner O rings of the lids and the lids Test ports for leak testing of the package are located between the twin O ring seals for both the primary and secondary lids There are three configurations of the packaging Configuration 1 includes a drain port sealed with the insertion and welding of a rod in the drain port Configuration 2 does not have a drain port Configuration 3 does not have a drain port and the packaging s base plate is fabricated differently than for Configurations 1 and 2 Fabrication of Configurations 1 and 2 is not authorized 3 Drawings The packaging is constructed and assembled in accordance with EnergySolutions Drawing Nos C 110 E 0007 sheets 1 6 Revision No 19 The secondary lid thermal shield is constru
78. Revision 7 November 2013 SAM Initial Conditions cuclillas adidas 3 7 34 2 Etre best Conditions uos tede e etd ee bilo o oet th re ties doo dates 3 7 3 4 Maximum Temperatures and Pressure essen nennen 3 8 3 4 4 Maximum Thermal Stresses stood mede RE ee RR ELI YOU QUO Rota vei aie 3 9 3 4 5 Accident Conditions for Fissile Packages for Air Transport 3 9 E HE E 3 9 mod histor Relerences ed eee a dee ee e eet 3 9 O 3 11 4 0 CONTAINMENT cortan Rocas Roel 4 1 4 1 Description of Containment yt 4 1 ZI Containment Vessels iae aa a a e a AE 4 1 4 1 2 Contamment PenetTallOn esent ro Ere Me udi ide M o au era deus 4 1 4 1 3 E A AN 4 1 do COIOSUIE ieu E EE e e AM 4 1 4 2 Containment Under Normal Conditions of Transport 4 2 4 2 1 Maximum Permitted Leak Rate ose dies acdeiessoeaat anteannSepedteesdnlenadenndosacraeaks 4 2 4 2 2 Containment Under Normal Conditions of Transport Powdered Solids 4 3 4 20 3 Containment Under Normal Conditions of Transport Irradiated Hardware 4 6 4 3 Containment Under Hypothetical Accident Conditions Type B Packages 4 7 4 3 1 Containment Under Hypothetical Accident Conditions Powdered Solids 4 8 4 3 2 Containment Under Hypothetical Accident Conditions Irradiated Hardware 4 9 44 Reference Air ee aka ge Ral ik 4 11 4 5 Determination of Equivalent Reference Leakage Rate for R 134a Gas
79. _ 0 1 39E 11 1 18E 07 1 59E 01 6 90E 02 Remaining metal General 0511 2 21E 11 8 12E 04 0 7 0 2 13E 12 0 1 89E 08 4 30E 04 Remainingmetal General 0 8108 7 36E 11 270E 05 0 9 8 63E 11 5 54E 07 8 52E 01 4 88E 03 4 88E 03 Remaining metal General 0 8348 7 40E 11 2 72E 05 09 0 8 63E 11 0 5 54E 07 8 57E 01 4 91E 03 4 91E 03 Remaining metal General 0 8639 5 45E 09 2 00E 03 0 9 0 3 63E 11 8 5 54E 07 6 31E 03 3 61E 05 3 61E 05 Remainingmeta General 1 6747 3 97E 09 1 46E 03 1 83 0 3 04E 10 e 2 06E 06 1 31E 01 7 08E 04 7 08E 04 Ce 60 0 1 18E 07 1 131E 05 1 11E 05 2 56E 08 3 83E 07 3 83E 07 Sum 4 23E 01 1 55E 06 Co 60_ 0 1 39E 11 Cs 137 9 88E 05 Cs 137 2 58E 12 Since the sum is less than 0 95 the container is an acceptable payload if the container and 100 g item are shored such that the 100g item is located at the centroid of the cask cavity 7 21 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Example 5 Contaminated Soil Problem Determine the acceptability of a 100 ft steel secondary container containing a contaminated soil mixture The activity is not uniformly distributed The measured weight of the filled container is 10 100 Ibs the weight of the empty container is 1 100 Ibs 596 of the payload mass is made up of small bits of grout used to immobilize c
80. a source s determined in Step 3 Equivalent gamma energies must be rounded up to the next higher energy level listed in Table 7 1 For each gamma energy of each payload item ignoring gamma energies below 0 3 MeV calculate the total y sec for the payload item and the y sec g for the hottest highest source strength density portion of the item Co and Cs may be treated like single energies since they have their own limits in Table 7 1 Gamma energies must be rounded up to the next higher energy level listed in Table 7 1 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 If any gammas have energies above 3 5 MeV the material is unacceptable for transport in the package For payloads with a large number of gammas the gammas may be grouped into the energy groups in Table 7 land the total gamma sources can be determined for each group The energies listed in Table 7 lare the maximum energies for the groups Calculations of y sec g should not include the mass of liners or other secondary containers 4 For each payload item select the two appropriate limit columns O through 9 in Table 7 1 one each for y sec and y sec g Base the y sec on the total y sec for the item and the y sec g on the highest source strength density hottest portions of the item Confirm that the density of each payload item is less than 9 0 g cm Items with higher densities can only be qualified using the y sec limits becaus
81. ach for selecting the smallest source strength or source strength density which results in dose rates that equal a regulatory limit was acceptable since it has not changed since the last revision of the CoC For the current application the staff compared the results of the new calculations crediting the extra shielding with those of the calculations used to support CoC Rev 19 to ensure that the change in values was reasonable The staff expected in every case that the dose rate response would decrease due to the additional shielding However in a few cases including Cs 137 and calculations for lower energy gammas below 1 0 MeV there were some dose rate responses that increased The staff requested additional information from the applicant to explain this increase The applicant stated that the reason for this increase was due to the changes in the modeling of the shielding components As discussed in Section 5 1 1 and 5 3 1 of this SER by crediting the 8 inner steel liner the applicant then reduced the shielding of the other steel components to account for fabrication tolerances which were previously accounted for with the liner which was not credited However the bolt ring and seal wear plate were modeled at maximum thickness because it raises the lid relative to the top of the lead and creates a larger streaming path and is therefore a more conservative model For Cs 137 and some lower gamma energies this increased the dose rate respo
82. aged within multiple nested confinement layers The inputs to these equations include the bounding effective G H2 value for the contents the G H2 values for the packaging material s the void volume in the containment vessel and in the confinement layers when applicable the temperature when the package was sealed the temperature of the package during transport and the contents decay heat For any package delivered to a carrier for transport the secondary container must be prepared for shipment in the same manner in which the determination for gas generation is made Shipment period begins when the package is prepared sealed and must be completed within twice the expected shipping time For any package containing materials with radioactivity concentration not exceeding that for LSA and shipped within 10 days of preparation or within 10 days of venting the secondary container the gas generation determination above need not be made and the shipping time restriction does not apply 1 2 3 SPECIAL REQUIREMENTS FOR PLUTONIUM Any contents that contain more than 0 74 TBq 20 Ci of plutonium must be in solid form 1 2 4 OPERATIONAL FEATURES Refer to the General Arrangement Drawing of the package in Appendix 1 3 There are no complex operational requirements associated with the package 1 6 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 13 APPENDIX 8 120B Shipping Cask Drawings e C 110 E 0007 8 120B Shipping Ca
83. ain bolts and holding pins for reinstallation Do not lose the ratchet binder holding pins Attach crane to lifting lugs on upper impact limiter using appropriate lifting gear Ensure alignment marks are on impact limiter and cask body To prevent damage to the impact limiter place impact limiter carefully in set down area Lift off impact limiter 5 1 2 2 Remove Secondary Lid Thermal Shield 5 1 2 2 1 Remove the ball lock pins from each of the three retaining pins and remove the retaining pins from the secondary lid lift lugs 5 1 2 2 2 Using suitable lifting equipment remove the secondary lid thermal shield Care should be taken to prevent damage to the thermal shield during handling and storage 5 1 2 3 Remove primary cask lid 3 1 2 3 1 Note Prior to removing the cask primary lid the inspection tag attached to the primary or secondary lid shall be reviewed to verify none of the maintenance inspection or testing activities has passed the due dates recorded on the tag If no tag is present or if any dates have expired or will expire prior to the cask reaching the destination where it will be unloaded EnergySolutions CMF shall be contacted prior to proceeding Contact EnergySolutions CMF for further directions if no inspection tag is present or if any of the due dates on the inspection tag have expired or will expire prior to unloading the cask Page 11 of 41 Handling Procedure for Transport Cask Mode
84. alized tearing and will not impair the ability of the package to meet other requirements of this subpart i When evaluated against the performance requirements of this section and the tests specified in 173 465 or using any of the methods authorized by 173 461 a the packaging will prevent ER 01 004 Rev 1 Page 14 of 20 1 Loss or dispersal of the radioactive contents and 2 A significant increase in the radiation levels recorded or calculated at the external surfaces for the condition before the test The tests specified in 173 465 are evaluated in Chapters 2 3 4 and 5 of the SAR where it is shown that the cask can successfully pass these tests without loss or dispersal of the radioactive contents and without a significant increase in the radiation levels recorded or calculated at the external surfaces for the condition before the test This is demonstrated by analysis for the conditions specified as allowed by 8173 461 a k Each packaging designed for liquids will 1 Be designed to provide for ullage to accommodate variations in temperature of the contents dynamic effects and filling dynamics 2 Meet the conditions prescribed in paragraph j of this section when subjected to the tests specified in 173 466 or evaluated against these tests by any of the methods authorized by 173 461 a and 3 Either i Have sufficient suitable absorbent material to absorb twice the volume of the liquid contents The absorbent
85. aluation ete ee ee iii 5 7 KOMMEN ule E 5 7 E Input and Oufput Doa 5 9 5 4 3 Bluxsto Dose Rate Conversion ii id 5 10 5 4 4 External Radiation Levels and Source Strength LiMitS oooocccnnncccnnoncinocccinnnnnnn 5 10 3 9 Payload Qualification ciii dot cono pecu oO 5 16 5 607 Grid ito Rec 5 18 3 4 Referentes oso Ru paa pU Rande ie iedaalee 5 18 6 0 CRITICALITY EVALUATION store riada 6 1 7 0 OPERATING PROCEDURE i etorecstes totes thee t eub de basso e d vh oec eei eec Pos epe ede ne AIRE SiS 7 1 Jl Loading the Packaging O nS RUM d Ue Ios aei exea E 7 1 7 2 Unloading the Packard dela denia i 7 5 7 3 Preparation of Empty Packaging for Transport seen 7 7 8 0 ACCEPTANCE TESTS AND MAINTENANCE PROGRAM eee eere eene 8 1 8 1 Acceptance Tests Configurations 1 and 2 casks fabricated before April 1 1999 8 1 Bolo Vista LEX amination caa O id 8 1 pl SOMO A E cease E EN PE e E 8 1 SI E O 8 1 SLA Component Leti raras still 8 2 Sales TESPLOE Shielding Ente SEIL A AAA 8 2 5 1 6 Thermal Acceptance TS ie qose asse Hera diee ue PE NS UG SOR niger eun 8 2 8 2 Acceptance Tests Configuration 3 casks fabricated after April 1 1999 8 2 8 2 1 Visual Inspections and Measurements essen eene enne 8 2 S252 o sees a SIE RU a oS os QUSE sessed AY RE SEO dn a EE Ed Te PERS U 8 3 9 23 Structural and Pressure Tests taa 8 3 vi 8 120B Safety Analysis Report C
86. any enclosed surfaces of external cask body 5 4 4 1 Wipe clean the inside surface of the bottom impact limiter 5 4 4 2 Verify the interior of the bottom impact limiter is free of debris and has no obvious damage e g rust holes gouges cracks etc Notify EnergySolutions CMF if damage is observed 5 4 4 3 Lift the cask 5 4 4 4 Inspect and clean the bottom surface of the cask 5 4 4 5 Verify exterior cask bottom and lower impact limiter surfaces has no obvious damage e g rust holes gouges cracks etc Notify EnergySolutions CMF if damage is Observed 5 4 5 Position and slowly lower the cask inside the bottom impact limiter using the alignment mark that was noticed when the cask was removed from the bottom impact limiter Caution Lower cask into bottom impact limiter very slowly to prevent any damage 5 4 6 Install security seal between lower impact limiter and cask body Page 35 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 5 5 Note 5 4 7 5 4 8 5 4 9 5 4 10 Unbolt and remove cask lifting lugs from the cask and mount the cask lifting lugs on the storage rack on the trailer Install and securely tighten the bolts Replace the cask tie down cables and tighten Replace the secondary lid thermal shield and upper impact limiter Follow Steps 5 1 2 7 through 5 1 2 7 8 Return to proper point in handling procedure and proceed with prep
87. ap screw and a thin layer of anti seize should be applied to the vent port socket head cap screw threads Seal the primary lid with security seals Ensure that all dirt clay debris is removed from the cask lids prior to installation of the cask impact limiter 5 2 13 Replace secondary lid thermal shield and upper impact limiter Warning Ensure inner surfaces of impact limiter are below external package limits as specified in Reference 3 2 and or site release limits Also this should include any enclosed surfaces of external cask body 5 2 13 1 5 2 13 2 5 2 13 3 5 2 13 4 Using suitable lifting equipment lift inspect for damage and install the secondary lid thermal shield Contact EnergySolutions CMF if damage is present Install the three secondary lid thermal shield retaining pins into the secondary lid lift lugs and insert the ball lock pins into the retaining pins Attach the crane hook to the lifting lugs on the impact limiter lift it and inspect for damage Position the impact limiter on cask using alignment marks on the cask body and impact limiter and detach the crane hook Page 31 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 5 2 14 5 2 15 5 2 16 Note 5 2 13 5 Note 5 2 13 6 5 2 13 7 5 2 13 8 Visually inspect ratchet binder bolts for any signs of cracking or other visual defects Replace any defective bolts or pins R
88. apter 7 has been revised the note regarding exemption from pre shipment leak testing for LSA and SCO shipments has been deleted and all shipments made with the package require pre shipment leak testing as part of Chapter 7 Operating Procedures Condition No 12 of the previous revision of the certificate was deleted This condition is no longer applicable because the seals authorized in CoC Revision 17 are no longer permitted for use As a result of the deletion of Condition Nos 7 11 and 12 Conditions Nos 8 through 14 of the previous certificate were renumbered A new Condition No 10 was added to authorize the use of the previous revision of the certificate for approximately one more year The expiration date of the certificate was not changed The references section was updated to include the consolidated application dated November 13 2013 CONCLUSION Based on the statements and representations in the application as supplemented and the conditions listed above the staff concludes that the Model No 8 120B package design has been adequately described and evaluated and that these changes do not affect the ability of the package to meet the requirements of 10 CFR Part 71 Issued with Certificate of Compliance No 9168 Revision No 20 on November 22 2013 Section 2 Procedures REM ENERGYSOLUTIONS TR OP 035 Handling Procedure for Transport Cask Model 8 120B Certificate of Compliance Number 9168 Revision 25 Chui
89. aring the cask for transport Preparation of Empty Packaging for Transportation The procedural steps for preparing empty packaging for transportation at the unloading facility are included in Section 5 2 The procedure described in this section is intended to be used when an empty package is prepared for transportation at a location other than an unloading facility Note After completing step 5 5 7 verify that nothing is obstructing the viewing of cask information Tape magnets or any other objects may NOT be placed over the cask CoC number Model Serial number name plate information Type B tri foil etc Note If shipping the cask radioactive empty UN2908 air drop testing is not required 5 5 1 5 5 2 5 5 3 Note Confirm that the cask cavity is empty of radioactive waste contents to the extent practicable For foreign material exclusion concerns cask internals must also be verified clean and clear of all non radioactive debris Survey the cask interior to confirm that the removable contamination does not exceed the limits of 49 CFR 173 428 d Decontaminate the cask interior as necessary to satisfy the removable contamination does not exceed the limits of 49 CFR 173 428 d Replace primary lid If the secondary lid is not sealed with a proper EnergySolutions security seal the secondary lid shall be removed for inspection of O Rings and seating surfaces prior to reinstalling the primary lid on the cask body or ma
90. ase of hazard ous materials from the receptacle and 4 For shipments in bulk packagings venting is authorized for the specific hazard ous material by a special provision in the 172 101 Table or by the applicable bulk packaging specification in part 178 of this subchapter Not applicable h Outage and filling limits 1 General When filling packagings and receptacles for liquids sufficient ullage outage must be left to ensure that neither leakage nor permanent distortion of the packaging or receptacle will occur as a result of an expansion of the liquid caused by temperatures likely to be encountered during transportation Re quirements for outage and filling limits for non bulk and bulk packagings are specified in 173 24a d and 173 24b a respectively 2 Compressed gases and cryogenic liquids Filling limits for compressed gases and cryogenic liquids are specified in 8173 301 through 173 306 for cylinders and 173 314 through 173 319 for bulk packagings ER 01 004 Rev 1 Page 7 of 20 i Air transportation Packages offered or intended for transportation by aircraft must conform to the general requirements for transportation by aircraft in 173 27 except as provided in 171 11 of this subchapter This section contains specifications that must be met by the shipper 173 24a Additional general requirements for non bulk packagings and packages Not applicable the CNS 8 120B is classified as a bulk packaging 1
91. ask lids and impact limiter Lifting hardware Page 4 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 4 2 4 1 2 3 4 1 2 4 4 1 2 5 4 1 2 6 4 1 2 7 4 1 2 8 Tools 4 1 2 3 1 Calibrated torque wrenches various sizes that are capable of achieving the following torque values 12 20 200 250 and 500 ft Ibs 4 1 2 3 2 Proper size sockets with ratchets a 3 8 inch socket set b 3 1 8 inch socket 3 inch socket and ratchet handle c Adapters for torque wrenches 4 1 2 3 3 Small medium adjustable wrench and open end wrench set Lifting slings compatible with impact limiter and cask lids Acceptable bolt lubricant Moly Z Neolube or Anti Seize Health Physics HP instrumentation and support materials Filling equipment for disposal liners Vacuum grease for example Parker Super O Lube or petroleum jelly Tools Materials Equipment At Unloading Site 4 2 1 Crane compatible with filled liner loaded drum pallet impact limiter and cask lids 4 2 2 Lifting and unloading hardware 4 2 3 Tools 4 2 3 1 4 2 32 4 2 3 3 Calibrated torque wrenches various sizes that are capable of achieving the following torque values 12 20 200 250 and 500 ft Ibs Proper size sockets with ratchet a 3 8 inch socket set b 3 1 8 inch socket 3 inch socket and ratchet handle c Adapter for torque wrenches Small medium adjustable
92. ask or shielding provided by the cask Also inspect for loose materials or moisture Report any noted damage or defects to EnergySolutions CMF for resolution before proceeding with cask loading Remove any liquids or foreign materials from the cask cavity Load the pallet into the cask Caution Do not place the drums on the pallet lifting sling Page 13 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 Caution Confirm that the safety hook if installed on the pallet sling remains attached to the lifting ring Caution Care should be taken during handling operations to prevent damage to cask sealing surfaces Warning Treat all debris removed from the pallet as potentially radiologically contaminated 5 1 2 5 1 Clean each pallet before loading it Load each pallet with a maximum of four 55 gallon drums or equivalent 5 1 2 5 2 Perform two independent physical verifications of each secondary container s closure system to ensure that it is properly closed and secured Record the compliance of this step in attachment 7 1 step 1 Note This requirement is waived for uniformly distributed resins filters and for solidified wastes with no dimension less than 1 cm 5 1 2 5 3 Attach the crane hook to the pallet lifting ring 5 1 2 5 4 Carefully lift the pallet and place into the cask Detach the crane hook and place pallet lifting ring on top of drums DO NOT damage the inside
93. at Pre shipment leak test required the pre shipment leak test of the for all Type B shipments vent port is not a condition of except for LSA material and whether the vent port plug has or SCO material that is exempt has not been removed under 10 CFR 71 14 b 3 1 2105 South Bascom Ave Suite 230 Campbell California 95008 408 558 3500 Fax 408 558 3518 www energysolutions com ES NRC 13 017 August 9 2013 Attachment 1 Page 2 Summary of Changes 8 120B Consolidated SAR Revision 5 Section Page s Change Purpose 4 7 1 4 20 Corrected units for parameter L Editorial correction printing 5 1 1 5 1 Revised 1 paragraph to discuss Revised in response to RAI 5 2 presence of cask cavity cladding Deleted last sentence of paragraph Table 5 1 5 2 Dose rates updated based on Revised in response to RAI 5 6 revised shielding analysis 5 1 2 3 5 3 Corrected Table 5 1 cross Editorial correction reference in last sentence of 1 paragraph 5 3 1 1 5 4 Revised to discuss application of Revised in response to RAI 5 2 tolerances modeling of the cask and 5 6 cavity liner cladding and radial thermal barrier and adjustments to impact limiter model to account for effects of NCT drop tests 5 4 1 5 8 Added text to Analysis Method Revised in response to RAI 5 7 Uncertainties and Conservatisms section to discuss results with relative error levels between 0 05 and 0 1 and tallies
94. ation levels conform to requirements as established in Site radiation and contamination release procedures 49 Page 32 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 5 3 Note 5 2 16 6 5 2 16 7 CFR 173 441 and and 10 CFR 71 47 as applicable see References 3 2 and 3 5 That the cask lids and impact limiters are sealed with security seals That all lifting lugs are removed or properly covered for transport Removing the Cask from the Trailer Removal of cask from trailer is usually not necessary Authorization to remove cask from trailer must be granted on a case by case basis If removal is necessary authorization may be obtained from EnergySolutions CMF 5 3 1 Locate the trailer 5 3 1 1 5 3 1 2 Position the trailer and cask within reach and safe load limit of the crane Be sure the trailer is level visual determination 5 3 2 Loosen and remove the cask tie down cables 5 3 3 Prepare the cask for removal from the trailer 5 3 3 1 5 3 3 2 5 3 3 3 5 3 3 4 5 3 3 5 5 3 3 6 Be aware that the cask must be set back into place using the alignment marks on the bottom impact limiter and cask body Remove upper impact limiter and secondary lid thermal shield Follow Steps 5 1 2 1 through 5 1 2 2 2 Check torque on primary and secondary lid bolts and ensure all bolts are torqued to 500 x 50 ft Ibs using a star pattern Bolt torque does
95. be performed on each plastic pack aging or receptacle used for Packing Group materials The maximum rate of permeation of hazardous lading through or into the plastic packaging or re ceptacles may not exceed 0 5 percent for materials meeting the definition of a Division 6 1 material according to 173 132 and 2 0 percent for other hazard ous materials when subjected to a temperature no lower than A 18 C 64 F for 180 days in accordance with Test Method 1 in appendix B of this part B 50 C 122 F for 28 days in accordance wey Test Method 2 in appendix B of this part or C 60 C 140 F for 14 days in accordance with Test Method 3 in appendix B of this part iii Alternative procedures or rates of permeation are permitted if they yield a level of safety equivalent to or greater than that provided by paragraph e 3 ii of this section and are specifically approved by the Associate Ad ministrator for Hazardous Materials Safety 4 Mixed contents Hazardous materials may not be packed or mixed together in the same outer packaging with other hazardous or nonhazardous materials if such materials are capable of reacting dangerously with each other and causing i Combustion or dangerous evolution of heat ii Evolution of flammable poisonous or asphyxiant gases or iii Formation of unstable or corrosive materials ER 01 004 Rev 1 Page 6 of 20 S Packagings used for solids which may become liquid at temperatures li
96. be verified by gamma scan to assure the package lead layer meets or exceeds the minimum thickness specified on the cask drawing All gamma scanning will be performed on a 4 inch square or less grid system The acceptance criteria maximum dose rate value will be determined by Option 1 measurement of the maximum dose rate value using a test block which has shield layers that replicate the cask geometry per the drawing using the gamma scan source and reproducing the source shield detector geometry that will be used during the scan of the cask or Option 2 calculation of the maximum dose rate value using detailed modeling software MCNP or equivalent incorporating the specific cask dimensions from the drawing and the source shield detector geometry applicable to the gamma scan Any location on the cask which shows a gamma scan dose rate value greater than the maximum dose rate value will be identified as unacceptable All unacceptable areas will be remedied and re scanned Remedy for an unacceptable gamma scan include actions such as controlled re heating of the cask body to melt the lead to remove any voids or streaming paths This process may be used as long as average metal temperatures are kept below 800 F If the remedy could affect more than just the unacceptable area e g re heating of the cask body all affected portions will be re scanned 8 2 7 THERMAL TESTS No thermal acceptance testing will be performed on the 8 120B packaging Refer t
97. ben de idas 2 94 Figure 2 11 Cask Tie Down AMiiininialiai ia as 2 95 Figure 2 12 Tie Down Arm Geometria teta sditeets 2 96 Figure 2 13 Tie Down Free Body Diagram edente Ba eee edge eds 2 97 Figure 2 14 Tie Down Arm Dels ds 2 08 Figure 2 15 FEM of 8 120B Cask Outer Shell amp Tie Down Arm eee 2 90 Figure 2 16 8 120B Cask Outer Shell Maximum Principal Stress esses 2 100 Figure 2 17 8 120B Cask Tie Down Arm Maximum Stress Intensity sess 2 101 Figure 2 18 The finite element model used in the analyses esses 2 102 Figure 2 19 Temperature Distribution Hot Environment Loading sss 2 103 Figure 2 20 Stress Intensity Contour Plot Hot Environment Loading 2 104 Figure 2 21 Temperature Distribution Cold Environment Loading 2 105 Figure 2 22 Stress Intensity Contour Plot Cold Environment Loading 2 106 Figure 2 23 Fracture Critical Cask Components teu peso o tiae dde 2 107 Figure 2 24 Design Chart for Category II Fracture Critical Components 2 108 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Figure 2 25 Stress Intensity Contour Plot Reduced External Pressure Loading 2 109 Figure 2 26 Stress Intensity Contour Plot Increased Exter
98. by finding the maximum allowed gamma source that meets regulatory limits at the various package surfaces The applicant uses MCNP to calculate a dose rate response at the prescribed locations on a per source particle basis The staff reviewed and approved the methods used in this application in the last revision of the CoC and no changes within the current application give the staff cause to believe that they are obsolete or invalid for any reason Therefore staff s conclusion that they are acceptable remains valid 5 4 2 Input and Output Data The applicant provided input files for the MCNP calculations used to determine the maximum radioactivity of the contents Staff reviewed sample input files and found that the information regarding material properties and dimensions used in the calculations is consistent with descriptions of the calculations given in the application The staff compared the calculation results in the calculation file NU 391 from the current application to Revision 5 used with CoC Revision 19 and noticed that there were some dose rate responses that increased despite the additional shielding The staff would expect in every case that these would decrease This observation led the staff to speculate that there could either be large uncertainties associated with these calculations or that there could be problems with the calculations convergence and the staff requested information from the applicant that they explain how the MCNP unce
99. ccur as a result of an expansion of the liquid caused by temperatures likely fo be encountered during transportation Re quirements for outage and filling limits for non bulk and bulk packagings are specified in 8173 24a d and 173 24b a respectively ER 01 002 Rev 1 Page 7 of 15 2 Compressed gases and cryogenic liquids Filling limits for compressed gases and cryogenic liquids are specified in 173 301 through 173 306 for cylinders and 173 314 through 173 319 for bulk packagings i Air transportation Packages offered or intended for transportation by aircraft must conform to the general requirements for transportation by aircraft in 173 27 except as provided in 171 11 of this subchapter This section contains specifications that must be met by the shipper 173 24a Additional general requirements for non bulk packagings and packages Not applicable the CNS 8 120B is classified as a bulk packaging 173 24b Additional general requirements for bulk packagings This section contains specifications that must be met by the shipper 173 25 Authorized packages and overpacks Not applicable this section addresses specifications for overpacks and the package is not classified as an overpack 173 26 Quantity limitations When quantity limitations do not appear in the packaging requirements of this subchap ter the permitted gross weight or capacity authorized for a packaging s as shown in the packaging specification or standar
100. ce Kilograms pounds Feet lt Mass 5000 11 000 4 5 000 11 000 Mass to 3 10 000 22 000 10 000 22 000 Mass to 2 15 000 33 000 215 000 33 000 Mass 1 Section 2 6 6 of the SAR examines the package for the one foot free drop side drop and corner drop The analyses show that the package can successfully with stand and maintain package integrity for the specified one foot drop 2 For packages containing fissile material the free drop test specified in paragraph C 1 of this section must be preceded by a free drop from a height of 0 3 meter 1 foot on each comer or in the case of cylindrical packages onto each of the quarters of each rim Not applicable for the CNS 8 120B package 3 For fiberboard or wood rectangular packages with a mass of 50 kilograms 110 pounds or less a separate specimen must be subjected to a free drop onto each corner from a height of 0 3 meter 1 foot Not applicable for the CNS 8 120B package 4 For cylindrical fiberboard packages with a mass of 100 kilograms 220 pounds or less a separate specimen must be subjected to a free drop onto each of the quarters of each rim from a height of 0 3 meter 1 foot Not applicable for the CNS 8 120B package ER 01 002 Rev 1 Page 13 of 15 5 The target for the free drop test must be a flat horizontal surface of such mass and rigidity that any increase in its resistance to displacement or deformation upon impact by the specimen
101. ce Bottom 1 0 0 6 N A NCT NCT 11 N N A A N A N A N A N A ES NRC 13 017 Enclosure 1 Responses to Request for Additional Information Docket No 71 9168 Allowable Source Derivation for 3 5 MeV or lower photons Transport Condition NCT HAC Source Case Full Cavity 2 5 f 55 gal Centered Pt Corner Pt Side Point Full Cavity Corner Pt MCNP Case NCT 350 NCT 350 NCT 350 NCT 350 pt4 NCT 350 pt4 NCT 350 pt4 HAC 350 HAC 350 pt fullcav 25ft3t 55gal ctr tcor side fullcav tcor Relative Error for Max Response E Location Side 0 8 0 6 0 4 0 8 Surface Side I L Surface Side M 1 0 1 1 0 5 0 9 1 0 0 5 0 9 0 2 0 4 8 8 Surface Surface Bottom 2 6 0 4 2 5 2 6 1 3 0 9 0 7 9 2 0 2 6 1 4 N A N A N A E 0 5 0 5 DEEE N A O oe 7 3 7 7531 7 1 1 MENOS Side Allowable Source Derivation for 2 75 MeV or lower photons Transport Condition Source Case Full Cavity 2 5 f 55 gal Centered Pt Corner Pt Side Point Full Cavity Corner Pt MCNP Case Location NCT 275 fullcav NCT 275 25ft3t NCT 275 55gal ctr tcor side Relative Error for Max Response RE Side Surface Side I L 0 6 0 7 0 4 0 6 0 5 0 7 0 3 0 4 0 9 0 4 Surface Side body Surface Top 1 0 1 7 0 3 0 4 1
102. ce program described in Chapter 8 of the application Ts Except for close fitting contents shoring must be placed between the secondary containers or activated components and the package cavity s walls to prevent both radial and axial movements during transport 8 Flammable gas hydrogen concentration is limited to less than 5 in volume Compliance with this concentration limit is determined by the methodology used in NUREG CR 6673 NRC FORM 618 U S NUCLEAR REGULATORY COMMISSION 8 2000 10 CFR 71 CERTIFICATE OF COMPLIANCE FOR RADIOACTIVE MATERIAL PACKAGES d PACKAGE IDENTIFICATION NUMBER PAGE PAGE USA 9168 B U 96 4 OF 4 9 The package authorized by this certificate is hereby approved for use under the general license provisions of 10 CFR 71 17 10 Revision No 19 of this certificate may be used until August 31 2014 11 Expiration date August 31 2017 REFERENCES EnergySolutions application Revision No 7 November 13 2013 FOR THE U S NUCLEAR REGULATORY COMMISSION I LC af Kr Michele M Sampson Chief Licensing Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards Date November 22 2013 SAFETY EVALUATION REPORT Docket No 71 9168 Model No 8 120B Certificate of Compliance No 9168 Revision No 20 SUMMARY By letter dated May 23 2013 Energy Solutions ES submitted an amendment request to the U S Nuclear Regulatory Commission for th
103. cement resulting in a slight permanent egg shape DESCRIPTION OF POTENTIAL SCENARIO To characterize the concern the following scenario is provided which illustrates the potential problem A packaging liner e g a 14 170LPRCT liner which consists of a 14 170 HIC inside of a steel shell with an OD of 74 inches is inserted into a cask which has an out of round insert The typical inch radial clearance would not be achieved The liner could make contact with the shield insert wall without being noticed and due to its weight still slide down sufficiently within the insert and the cask During off load operation friction or binding between the liner wall and the insert wall may be sufficient to cause the shield insert to be withdrawn as the liner is withdrawn THIS CAN POTENTIALLY BE A DANGEROUS SITUATION It may not be quickly recognized that the shield insert is being withdrawn with the liner Under such circumstances withdrawal may continue until the liner and insert are above the cask lid opening with the potential for the insert to spring loose from the liner and fall free As a result severe damage may occur to personnel the cask or associated equipment from the 2 700 pound insert CNS IN 99 01 7 7 99 Page 1 of 2 RECOMMENDED ACTIONS FOR USERS While the example used to demonstrate the concern involves a liner which would be shipped in a 14 195 14 215 or similar cask Chem Nuclear is advising that any shield insert may if not
104. cement from EnergySolutions 5 3 17 Clean the set screw plug of all debris thread tape ect and reinstall in the primary lid Hand tighten until the plug is snug Storage of the M anifold After completion of the leak test s remove the air test manifold and all associated parts treating all parts as potentially contaminated and replace in storage box located on trailer Test gauge must be disconnected from the test manifold and stored back in its protected case within the cask trailer tool box 6 RECORDS 6 1 6 2 Each leak test performed shall be documented on an Air Leak Test Inspection Form see Appendix A or equivalent form If this procedure is performed at a EnergySolutions facility any records including Appendix A generated shall be maintained in accordance with Reference 2 3 When a leak test is performed at a customer s facility a copy of Appendix A or equivalent form shall be maintained by the shipper in accordance with 10CFR71 91 Furthermore a copy of Appendix A or equivalent form should be forwarded to EnergySolutions whereby the form shall be stored in accordance with Reference 2 3 Page 12 of 15 Air Pressure Drop Test for 8 120B Cask TR TP 002 Certificate of C onformance USA 9168 B U Revision 20 APPENDIX A 8 120B AIR LEAK TEST INSPECTION FORM DATE OF TEST CASK SERIAL NUMBER ID NUMBER SERIAL NUMBER PRESSURE GAUGE TORQUE WRENCH CALIBRATION DATE PRESSURE GAUGE TOR
105. cess of Type A quantities specified in 10 CFR 20 1906 a shall be received monitored and handled by the licensee receiving the package in accordance with the requirements of 10 CFR 20 1906 as applicable Before a loaded cask leaves the shipper s facility the following shall be confirmed 4 3 9 1 All lifting lugs are removed or properly covered for transport 4 3 9 2 Trailer placarding and cask labeling and marking meet D O T specifications see References 3 1 and 3 2 as applicable 4 3 0 3 Exterior radiation levels do not exceed 200 millirem per hour 2 mSv h on contact 10 millirem per hour 0 1 mSv h at 2 meters and 2 millirem per hour 0 02 mSv h in tractor cab in accordance with 49 CFR 173 441 and 10 CFR 71 47 see References 3 2 and 3 5 4 3 9 4 Cask external removable contamination does not exceed Site Release Limits 49 CFR 173 443 and 10 CFR 71 87 as applicable see References 3 2 and 3 5 4 3 9 5 Cask lids and vent port have been leak tested in accordance with Reference 3 3 4 3 9 6 Cask lid bolts and vent port socket head cap screw are properly torqued 4 3 0 7 X That the cask lids and impact limiters are sealed with security seals Page 7 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 4 3 9 8 Note That two independent physical verifications of the secondary container s closure system have been performed as part of the package loading o
106. cessary to assure that the 8 120B cask containment system is properly assembled prior to every shipment since it should not be assumed that the containment system is properly assembled prior to loading operations 7 4 8 120B Safety Analysis Report Consolidated Revision 7 7 1 17 7 1 18 7 1 19 7 1 20 7 1 21 November 2013 Attach and hand tighten ratchet binders between upper and lower impact limiter assemblies Cover lift lugs as required Inspect package for proper placards and labeling Complete required shipping documentation Prior to shipment of a loaded package the following shall be confirmed 7 1 21 1 7 1 21 2 7 1 21 3 7 1 21 4 7 1 21 5 7 1 21 6 That the licensee who expects to receive the package containing materials in excess of Type A quantities specified in 10 CFR 20 1906 a meets and follows the requirements of 10 CFR 20 1906 as applicable That trailer placarding and package labeling meet DOT specifications 49 CFR 172 That the provisions of 10 CFR 71 87 are met including that the external radiation dose rates are less than or equal to 200 millirem per hour mrem hr at the surface and less than or equal to 10 mrem hr at 2 meters in accordance with 10 CFR 71 47 by performing radiation surveys These surveys should be sufficient to ensure that a non uniform distribution of radioactivity does not cause the surface or 2m limit to be exceeded The SAR thermal analysis demonstrates t
107. cted in accordance with EnergySolutions Drawing No DWG CSK 12CV01 EG 0001 01 Rev 3 b Contents 1 Type and form of material i Byproduct source or special nuclear material in the form of dewatered resins solids including powdered or dispersible solids or solidified material contained within secondary containers or ii Radioactive material in the form of activated metals or metal oxides in solid form contained within secondary containers 2 Maximum quantity of material per package i Activity not to exceed 3 000 times a Type A quantity along with the following limits 1 The limit determined per the procedure in Attachment 1 to Chapter No 7 of the application for beta and gamma emitting radionuclides rr RM 618 U S NUCLEAR REGULATORY COMMISSION 10 CFR 71 CERTIFICATE OF COMPLIANCE FOR RADIOACTIVE MATERIAL PACKAGES 1 a CERTIFICATE NUMBER b REVISION NUMBER c DOCKET NUMBER d PACKAGE IDENTIFICATION NUMBER PAGE PAGE 9168 20 71 9168 USA 9168 B U 96 3 OF 4 2 The mass limits for fissile materials as prescribed by 10 CFR 71 15 for exempting materials from classification as fissile material 3 A maximum total package neutron source of 1x10 neutrons second for materials that produce neutrons other than fissile materials through any means including spontaneous fission alpha neutron reactions and gamma neutron reactions ii Maximum decay heat 200 Watts iii Maximum weight
108. ctive concentrations not exceeding that for LSA material ensure that the shipment occurs within 10 days of preparation or 10 days of venting the loaded secondary container 4 4 Acceptance Criteria 4 4 1 The package has been prepared for shipment per this handling procedure and the requirements of Reference 3 7 4 42 Air pressure drop leak tests have been satisfactorily performed prior to release of the cask for shipment in accordance with Reference 3 3 Note The presence of a security seal on the lids does not imply that leak testing has been previously performed or is not required EnergySolutions requires leak testing of the cask lids and vent port prior to every shipment Page 9 of 41 Handling Procedure for Transport Cask TR OP 035 Note Note Model 8 120B C of C Number 9168 Revision 25 5 0 DETAILED PROCEDURE Note Prior to loading the cask the payload must be qualified in accordance with the requirements of Reference 3 7 The maximum decay heat of the contents shall not exceed 200 watts The maximum payload weight must not exceed 13 360 pounds nor result in a maximum packaging weight exceeding 74 000 pounds The maximum quantity of material in the contents shall be limited per Reference 3 7 Prior to loosening the impact limiter ratchet binders inspect the exterior of the package for damage e g large dents gouges tears to the impact limiter skin and thermal shield Contact EnergySolutions CMF if damage is pres
109. d Page 10 of 15 Air Pressure Drop Test for 8 120B Cask TR TP 002 Certificate of C onformance USA 9168 B U Revision 20 5 3 10 5 3 11 5 3 12 5 3 13 5 3 14 Note Dueto temperature changes it may be necessary to adjust the pressure back to 18 psig The pressure should not drop when the regulating shut off valve is closed It may take up to 30 minutes for the temperature to equalize Once 18 psig 1 0 psig is obtained on the Test Pressure Gauge close the Leak Test Supply Valve Set the Air Regulator to O psig or OFF and close the Air Regulator Inlet Valve Disconnect the air supply from the manifold Record the time on the Air Leak Test Inspection Form Appendix A After a period of fifteen 15 minutes 45 0 pressurized at 18 psig 1 0 psig and no drop in pressure greater than the minimum detectable amount record time on Appendix A Connect off gas header if required by plant procedure to the control side of the test manifold Slowly open valves on the test manifold and bleed air from cask Note Air bled from cask is potentially contaminated Take appropriate health physics precautions If the air pressure drop test fails perform the following steps and refer to Appendix B for troubleshooting 5 3 14 1 Remove the vent port socket head cap screw using a 3 8 allen wrench 5 3 14 2 Visually inspect the socket head cap screw and seal o ring to ensure that they are in good condition free of
110. d development plans and programs of potential commercial value to EnergySolutions f The information contains patentable ideas for which patent protection may be desirable g The information is third party Proprietary Information The information is being transmitted to the Commission in confidence and under the provisions of 10 CFR Section 2 390 it is to be received in confidence by the Commission The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief The proprietary information sought to be withheld in this submittal is that which is appropriately marked and being transmitted by EnergySolutions to the Document Control Desk The proprietary information has been presented to the Nuclear Regulatory Commission and is being voluntarily provided by EnergySolutions Public disclosure of the information is likely to cause substantial harm to the competitive position of EnergySolutions because a Similar products are manufactured and sold by competitors of EnergySolutions Page 3 of 4 b The development of this information by EnergySolutions is the result of a significant expenditure of staff effort and a considerable sum of money To the best of my knowledge and belief a competitor would have to undergo similar effort and expense in generating e
111. d have to increase by over seven times their relative error level before they would affect any of the payload source limit results Four of the tallies all of which missed only one check were governing tallies that contained tally segment dose rate responses that determined one of the payload source limits Examination of the dose rate response results profiles for those four cases showed that results were all well behaved Also the tally segment results in all four tallies also have very low relative error levels 1 or less Three of those four tallies missed one check because there was a trend in the figure of merit FOM over the last half of the run Examination of the FOM trends showed that the variations in FOM were very small 0 6 to 2 6 The MCNP manual states that small jumps in R VOV and or the FOM as a function of N are not threatening to the quality of the result On this basis 1t is concluded that those three tallies are acceptable The fourth tally missed one check due to trend in the estimated mean over the last half of the run The estimated mean results were examined and they did not show any significant variation or trend On the basis of all the above it was concluded that the four governing tallies that did not pass all 10 statistical checks are acceptable The uncertainty in those dose rate response results due to missed statistical checks is judged to be less than 1 which is offset by adding the relative error
112. d in Attachment 2 of this letter Should you or any member of your staff have questions please contact the undersigned at 408 558 3509 Sincerely Steven E Sisley Cask Licensing Manager EnergySolutions 2105 South Bascom Ave Suite 230 Campbell California 95008 408 558 3500 Fax 408 558 3518 www energysolutions com ES NRC 13 017 August 9 2013 Page 2 of 2 Attachments 1 Summary of Changes 8 120B Consolidated SAR Revision 5 3 pages 2 Affidavit pursuant to 10 CFR 2 390 Enclosures 1 Responses to Request for Additional Information 2 Proprietary Responses to Request for Additional Information 3 Safety Analysis Report for the Model 8 120B Type B Shipping Packaging Consolidated Revision 5 August 2013 Non Public Version 1 paper copy Security Related Information Withhold Under 10 CFR 2 390 4 Safety Analysis Report for the Model 8 120B Type B Shipping Packaging Consolidated Revision 5 August 2013 Public Version 1 paper copy 5 EnergySolutions Calculation Package 8 120B Shielding Response Document No CALC NU 391 Revision 7 1 paper copy Proprietary Withhold Under 10 CFR 2 390 cc Mr Pierre Saverot Division of Spent Fuel Storage and Transportation Mr Dan Shrum EnergySolutions ES NRC 13 017 August 9 2013 Attachment 1 Page 1 The following is a summary of the changes incorporated in Revision 5 of the 8 120B Consolidated Safety Analysis Report The revisions
113. d in part 178 or 179 as applicable of this subchapter The permitted capacity and gross weight is given in Chapter 1 of the SAR and marked on the package nameplate 173 27 General requirements for transportation by aircraft Not applicable the CNS 8 120B is not designed to be transported by aircraft 173 28 Reuse reconditioning and remanufacture of packagings a General Packagings and receptacles used more than once must be in such condition including closure devices and cushioning materials that they conform in all respects to the prescribed requirements of this subchapter Before reuse each packaging must be inspected and may not be reused unless free from incompatible residue rupture or other damage which reduces its structural integrity The package is inspected as specified in Chapter 7 of the SAR before each reuse ER 01 002 Rev 1 Page 8 of 15 b Reuse of non bulk packaging A non bulk packaging used more than once must conform to the following provisions and limitations Not applicable the package is classified as a bulk package 173 29 Empty packagings This section contains specifications that must be met by the shipper 173 30 Loading and unloading of transport vehicles A person who loads or unloads hazardous materials into or from a transport vehicle or vessel shall comply with the applicable loading and unloading requirements of parts 174 175 176 and 177 of this subchapter This section contains s
114. d in the sections above covering 8173 410 As discussed below under 8173 465 c and d the package is evaluated and shown to meet these requirements in the SAR 3 Each IP 3 packaging must meet the requirements for an IP 1 and an IP 2 and must meet the requirements specified in 8173 412 a through 8173 412f j Not Applicable 4 Each specification IM 101 or IM 102 portable tank 88178 270 178 271 7 78 272 of this subchapter that is certified as meeting the requirements for an IP 2 or P 3 must i Satisfy the requirements for IP 2 or IP 3 respectively ii Be capable of withstanding a test pressure of 265 kPa 37 1 pounds per square inch gauge ii Be designed so that any added shielding is capable of withstanding the static and dynamic stresses resulting from normal handling and normal conditions of transport and l l a of iv Be designed so that loss of shielding will not result in a significant increase in the radiation levels recorded at the external surfaces Not Applicable 5 Each freight container that is certified as meeting the requirements of IP 2 or IP 3 must i Satisfy the requirements for IP 2 or IP 3 respectively ii Be designed to conform to the requirements of ISO 1496 3 1995 E Se ries 1 Freight Containers Specifications and Testing Part 3 Tank Containers for Lig uids Gases and Pressurized Dry Bulk ii Be designed so that loss of shielding will not result in a significant
115. d the function of reviewing the information described in paragraph 2 which is sought to be withheld and have been duly authorized to apply for its withholding 2 The information sought to be withheld is contained in the document listed in Table 1 This document has been appropriately designated as proprietary TABLE 1 Document No Document Title Rev Date CALC NU 391 8 120B Shielding Response 6 3 I have personal knowledge of the criteria and procedures used by EnergySolutions in designating information as trade secret privileged or as confidential commercial or financial information 4 Pursuant to the provisions of paragraph b 4 of 10 CFR 2 390 the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure including the information as designated in paragraph 2 above should be withheld Page 1 of 4 i i The information sought to be withheld from public disclosure is included in the report documenting information which is owned and has been held in confidence by EnergySolutions The information is of a type customarily held in confidence by EnergySolutions and not customarily disclosed to the public EnergySolutions has a rational basis for determining the types of information customarily held in confidence by it and in that connection utilizes a system to determine when and whether to hold certain typ
116. dated Revision 7 November 2013 This page intentionally blank Section 5 Drawings Drawings withheld as security related sensitive information Section 6 References pm ENERGYSOLUTIONS Letterbook No ES NRC 13 010 Docket No 71 9168 May 23 2013 ATTN Document Control Desk Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U S Nuclear Regulatory Commission Washington DC 20555 0001 Subject Amendment Request for Certificate of Compliance No 9168 for the EnergySolutions 8 120B Type B Shipping Package References 1 Certificate of Compliance No 9168 Revision 19 Docket No 71 9168 Package Identification No USA 9168 B U 96 Dated August 23 2012 2 Safety Analysis Report for the Model 8 120B Shipping Packaging Consolidated Revision 3 July 2012 Dear Sir or Madam EnergySolutions hereby submits an application to amend Certificate of Compliance CoC for the Model 8 120B Shipping Package Reference 1 The application requests the addition of a steel plate that covers the central hollow region of the lower impact limiter and is credited for radiation shielding under NCT The application provides a revised shielding evaluation which includes the effects of the added plate along with some other existing components of the packaging that were conservatively ignored in the previous shielding evaluation In addition the application includes editorial cor
117. decontaminated d The outer layer of packaging will avoid as far as practicable pockets or crevices where water might collect There are no pockets or crevices on the outer layer of the packaging where water might collect e Each feature that is added to the package will not reduce the safety of the package Features of the package are evaluated in the SAR and it was determined that there are none that reduce its safety f The package will be capable of withstanding the effects of any acceleration vibration or vibration resonance that may arise under normal conditions of transport without any deterioration in the effectiveness of the closing devices on the various recepta cles or in the integrity of fhe package as a whole and without loosening or uninten tionally releasing the nuts bolts or other securing devices even after repeated use see 173 24 173 24a and 173 24b The package is similar to many other proven casks with many years of operational use in a transport environment This experience demonstrates that vibrations normally incident to transport will have no effect upon the package ER 01 004 Rev 1 Page 10 of 20 g The materials of construction of the packaging and any components or structure will be physically and chemically compatible with each other and with the package con tents The behavior of the packaging and the package contents under irradiation will be taken into account i The package is cons
118. der Certificate of Compliance USA 9168 B The CNS 8 120B was certified as a Type B package by demonstrating compliance with NRC Type B requirements specified in 10CFR Part 71 Therefore the CNS 8 120B should readily meet the requirements for an IP 2 package Nevertheless this report examines each regulatory requirement individually to assess the package s conformance to IP 2 specifications However where appropriate references are made to the Safety Analysis Report for the CNS 8 120B Reference 5 2 that was prepared to support certification by the NRC Since the requirements for an IP 2 packaging are more stringent than for an IP 1 this report will serve as a basis for use of the cask as an IP 1 packaging as well This Engineering Report evaluates the shipment of solid or liquid radioactive material in this cask when used as an IP 2 or an IP 1 packaging While the SAR does not specify liquid form as a permitted content this omission only applies when using the cask as a Type B packaging The analysis that follows considers the contents to be in liquid or solid state The shipper is also responsible for ensuring that the contents do not exceed any of the limits placed on the contents by the analyses in this report The applicable requirements for IP 2 packagings is given in 49CFR173 41 1 b 2 which is as follows Each IP 2 must meet the general design requirements prescribed in 8173 410 and when subjected to the tests specified in 8173 465
119. dic Mus e ees 2 6 2 3 Fabrication irn li 2 6 2 352 O side conta d stes Od A outage 2 6 2 4 General Requirements for All Packages esee enne 2 7 XA a A cane een fur d be fend IONS a eee 2 7 242 Tamper Indicating Porte da 2 7 24 3 Positive CIOSUEeSa quo easi A A A a De td Ree 2 7 2 5 Lifting and Tie Down Standards for All Packages eene 2 7 Zol Litine Device uni ni radiata 2 8 2 A E A o A NOEL EO ddr Al ose 2 17 2 6 Normal Conditions of Transport sissies A ases 2 22 pH MEN mre P LEE 2 23 2 26 27 CCOlU S Lr E Sd ts E 2 24 26 5 Reduced External Pressute sooo test tad Ea 2 25 20 4 Increased External Pressure ascii tia bea opto Gaiden 2 26 iii 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 20 3 VIDEAUOI 5 iiri baie e Hie Up Bude a doit dada 2 26 2 0 0 Water Spray o rotas 2 26 20 E esai 2 26 20 07 Corer O 2 28 2 06 9 CompressiOn iioi aun te EUR E R E E A VE didas 2 28 ZOO POCO le S De eade 2 28 2 7 Hypothetical Accident Conditions iiie egeo cet e deett ds 2 29 ZU MPSS RO is op ace stot sd oth none tate eeiam dto daten qo oa M an E cd Re 2 29 2 62 A dose uates t e te CI es toad Sor ta f 2 49 Lada PUNTO i id ii A A s 2 49 DI A A o e e nd 2 55 240 Immersion TPissile matenal A tee oi Eaa 2 56 2 7 6 Immersion All packages icon eene etenim tte 2 56 Zoid Deep Walter Immersion TT ER 2 56 2 5 ummaeryobDamdge donee i een e eat A S a a aa
120. dition which results in leakage in excess of the appropriate maximum allowable leak rate specified in Figures 4 3 4 6 or 1 0 x 10 atm cm sec for leaktight status shall be corrected and re tested Testing of the Lids and Vent e Optional Insert the sealed metal cavity filler canister into the cask cavity Verify the canister does not obstruct the vent penetration The metal must be chemically compatible with the cask liner and the test gas e Assemble the cask lids per Section 7 1 e Evacuate the cask cavity to 20 Hg vacuum minimum or 90 vacuum for the leak tight test e Pressurize the cask cavity to the following pressure 1 25 psig minimum with pure 1 1 1 2 tetrafluoroethane R 134a Or 2 1 psig minimum with pure helium or 0 to 1 psig with pure helium for leaktight status e Measure the leakage of the inner containment O ring via the test port in each lid e Measure the leakage of the vent port Testing of the Lids Optional Method e Assemble the cask lids per Section 7 1 e Connect to the O ring test port on the lid and evacuate the annulus between the cask lid O rings to 20 Hg vacuum minimum e Pressurize the O ring annulus to a minimum pressure of 25 psig with pure 1 1 1 2 tetrafluoroethane R 134a e Check for leakage of the inner containment O ring by moving a detector probe along the interior surface of the inner seal according to the specifications of ASTM E 427 Testing of th
121. drawing changes 1 Added Y inch thick plate are as follows Item 56 to cover central 1 Plate added for shielding region of the Lower Impact 2 Editorial correction for Limiter consistency with safety 2 Revised thickness of impact analyses and limiter skin and 3 Removed dimensions not 3 Removed non critical used in Safety Analyses dimensions on the impact limiter lift lug Items 45A and 46 Revised Impact Limiter section to discuss plates covering the central regions of the upper and lower impact limiters Revised for clarity ES NRC 13 010 May 23 2013 Page 2 of 4 Summary of Changes 8 120B Consolidated SAR Revision 4 Change Purpose Section Page s 2 1 3 2 4 Changed section for the following 1 Changed the word conservative to nominal in first sentence 2 Reduced Payload weight to offset additional weight of plate added to lower impact limiter 3 Deleted separate line for Thermal Shield weight and combined weight of the thermal shield and plate added to lower impact limiter in Misc line and 4 Added discussion of possible shift in package center of gravity due to eccentric payload configurations Purposes of revisions to section are as follows 1 Weights are based on nominal dimensions 2 Maintain overall package weight within limit 3 Simplify weight summary 4 Added to clarify that the effect of payl
122. e 3 4 Temperature Distribution Hot Environment esee 3 20 Figure 3 5 Temperature Distribution Cold Environment eere 3 21 Figure 3 6 Temperature Distribution Normal Hot ooocccnoccninccnonononcnonnnonnncnnnononcnnnncnnn ccoo nono 3 22 Figure 3 7 Temperature Distribution Normal Cold eee 3 23 Figure 3 8 Temperature Distribution in the Cask Cavity Hot Environment 3 24 Figure 3 9 HAC Fire Analysis Load Steps and Boundary Conditions 3 25 Figure 3 10 Identification of the Nodes where Time History is Monitored 3 26 Figure 3 11 Temperature Time History Plot in Various Components of the Cask 3 27 Figure 3 12 Temperature Time History Plot in Various Components of the Cask 3 28 Figure 3 13 Temperature Distribution 7 500 Sec After the Start of the Fire 3 29 Figure 3 14 Temperature Distribution in the Cask Cavity 40 289 Sec After the Start of the lcm EN 3 30 Figure 3 15 Temperature Distribution in the Cask with Puncture Drop Damage 7 500 Sec After the Start of the Plata ia suse inan das 3 31 Figure 3 16 8 120B Cask Secondary Lid with Thermal Shield Complete FEM 3 32 Figure 3 17 8 120B Cask Secondary Lid Seal Temperature Time History Plot With Thermal A A teras dfi pet e
123. e Model No 8 120B package ES requested the addition of a steel plate that covers the central hollow region of the lower impact limiter to improve the shielding effectiveness of the package On July 3 2013 ES provided inadvertent omissions to its application and on August 9 2013 ES provided responses to the request for additional information RAI dated July 15 2013 On September 20 and November 13 2013 ES provided responses to an RAI letter dated September 16 2013 NRC staff reviewed the applicant s responses and found that the package meets the requirements of 10 CFR Part 71 1 0 GENERAL INFORMATION A 12 thick steel plate has been added to the design of the package to cover the central hollow region of the lower impact limiter This new plate is credited for radiation shielding under normal conditions of transport NCT as explained and justified in Chapter 5 of the application The maximum gross weight of the package stays the same at 74 000 lbs but the maximum payload weight has been reduced to 14 150 lbs to account for the weight of this added steel plate Except for those modifications the design of the package as well as the authorized contents remains unchanged The staff reviewed Revision 19 of Energy Solutions Drawing No C 110 E 0007 sheets 1 6 and Revision 3 of EnergySolutions Drawing No DWG CSK 12CV01 EG 0001 0 The staff concludes that the information presented in this section of the application provides an adequat
124. e Vent Optional Method e Assemble the cask Vent Port Cap Screw and Seal per Section 7 1 e With the vent port cover Item 30 removed connect to and evacuate the volume above lid exterior the Vent Port Cap Screw and Seal Items 26 and 27 to 20 Hg vacuum minimum e Pressurize the volume to a minimum pressure of 25 psig with pure 1 1 1 2 tetrafluoroethane R 134a e Check for leakage of the Vent Port Cap Screw and Seal by moving a detector probe along the interior surface of the Primary Lid in the area of the vent port according to the specifications of ASTM E 427 The requirements for Periodic and Maintenance Leak Testing of the 8 120B are summarized in Table 8 1 8 7 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Table 8 1 Periodic and Maintenance Leak Test of 8 120B 5 LD a EB 5 S oc 2 2 S O SEE gt m Test Pressure Procedure Alternate Procedure 8 amp asi O 2 A After pressurizing Aterp a between the lid O the cask cavity with Evacuate cask cavity Meter check ring annulus with the Fig Fig to 20 Hg then aa test gas check for R 134a for gas leakage from 4 3 4 4 pressurize to 25 thecask Lid imer Os 25 leakage from the psig cask Lid inner O ring using the cask i Lidtest pori ring using a detector Lid i probe After pressurizing Evacuate cask cavity the cask cavity with Fi Fi to 20 Hg or
125. e basis for the evaluation of the Model No 8 120B package against 10 CFR Part 71 requirements for each technical discipline 2 0 STRUCTURAL EVALUATION The new cover plate that covers the central hollow region of the lower impact limiter is designed to remain intact and attached to the impact limiter during NCT However this cover plate has no significant effect on the energy absorption characteristics of the impact limiter during the NCT and hypothetical accident conditions HAC free drop tests and therefore is not considered in the NCT and HAC free drop analyses 2 The structural evaluation of the package remains unchanged 3 0 THERMAL EVALUATION The impact limiters are not explicitly included in the thermal finite element model For NCT the impact limiters are conservatively represented by fully isolated boundary conditions and only the exposed portions of the fire shield and package body are used for heat rejection to the ambient The addition of the new cover plate does not change the thermal evaluation of the package or its results 4 0 CONTAINMENT EVALUATION The containment evaluation remains unchanged The applicant noted an inconsistency between the reference leakage rate La of 2 2x10 cm sec stated in the previous revision of the application based on irradiated hardware and the reference leakage rate Lg for the package of 1 54x10 ref cm sec as mentioned in the corresponding safety evaluation report This
126. e derived from the ANSI ANS 6 1 1 1977 standard The applicant calculated the factors from the polynomial fit for gamma radiation given in that standard As this is the standard that staff finds acceptable for calculation of dose rates the staff found the applicant s conversion factors to be acceptable The conversion factors used in the input files are consistent with those described in the application 5 4 4 External Radiation Levels The applicant used the regulatory limits to calculate the maximum quantities of the package contents The applicant derived a set of limits for various contents configurations and set restrictions on how the user applies those limits to ensure that the regulatory dose rate limits are not exceeded The package is designed to transport radioactive materials by exclusive use shipment Thus the applicant used the 10 CFR 71 47 dose rate limits for exclusive use shipments There is no enclosure included with the package design and there are no conditions regarding the vehicle other than a width of 8 feet So the dose rate limits for transport in an open or flat bed vehicle are used in the shielding method The applicant determined the source strengths point sources and source strength densities distributed sources that would meet each NCT and HAC limit for the axial top axial bottom and radial side of the package Since the package is always transported in a vertical position i e the package axis is vertical
127. e following marain of safety 2 17x10 in D d a il o M S 32 000 735 1242 7 This calculation is conservative since the structural support of the lead and inner shell are not considered The same compressive load acting vertically on the lid is also considered do ipia oM 3 AO a AA 1096psi which yields the A 0 7854 3 14x36 6 in 3 14x35 12 in following margin of safety M S E 12282 4 0 Conclusions and Recommendations The conclusion of this report is that the CNS 8 120B meets the requirements for an IP 1 and IP 2 package 5 0 References 5 1 Code of Federal Regulations Title 49 Parts 100 through 185 October 1 2000 5 2 Safety Analysis Report for Chem Nuclear Systems Model No CNS 8 120B Rev 4 August 2000 ER 01 002 Rev 1 Page 15 of 15 DURATEK ENGINEERING REPORT ER 01 004 Revision 1 RR ean ES TN REPT SC TIT CPA RADICA SON Approvals Page Conformance of CNS 8 120B Cask with Specifications for DOT 7A Type A Packagings Prepared by Signature on File 10 8 02 Shayne Merritt Project Engineer Date Independent Reviewer Signature on File 10 8 02 Patrick L Paquin General Manager Date 1 0 2 0 3 0 4 0 5 0 TABLE OF CONTENTS INTRODUCTION cc citum peres tos de E EVO vai ere dri ti reget ee ce nl eei 3 DISCUSSION a ceri abet EU a 3 RESUL p m P 4 CONCLUSIONS AND RECOMMENDATIONS ocoococcccoccononorannconanonnacinnococccnnranos 20 REFERENCE Noa 20
128. e marked on the outside USA DOT 7A Type A and Radioactive Material The conclusion of this report is that the CNS 8 120B meets the specification requirements for a DOT 7A package and can be marked as required by 8178 350 b 5 0 References 5 1 Code of Federal Regulations Title 49 Parts 100 through 185 October 1 2000 5 2 Safety Analysis Report for Chem Nuclear Systems Model No CNS 8 120B Rev 4 August 2000 ER 01 004 Rev 1 Page 20 of 20 Section 3 Typical User Registration Letter Sample User Registration Letter Date U S Nuclear Regulatory Commission Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Washington DC 20555 Gentlemen Pursuant to the requirements of 10 CFR 71 17 organization s name as holder of License No wishes to register as a user of the 8 120B radioactive materials shipping cask Package identification number for this cask is USA 9168 B U 96 NRC Docket No 71 9168 It is requested that future information for this package be forwarded to the following individual Name Title Organization Organization s Address Sincerely Name Title ec EnergySolutions Document Control Suite 100 Center Point II 100 Center Point Circle Columbia SC 29210 Section 4 Safety Analysis Report Sections 1 7 and 8 SAFETY ANALYSIS REPORT For MODEL 8 120B TYPE B SHIPPING PACKAGING CONSOLIDATED REVISION 7 November 2013 S
129. e not evaluated since it contains only definitions rather than specifications The methods for demonstrating compliance with the test requirements of 173 465 are given in 8173 461 These are 1 performance of tests 2 reference to a previous satisfactory demonstration of compliance 3 performance of tests with models or 4 calculations or reasoned evaluation The primary method used in this report is method number 4 or reference to the cask SAR which also primarily uses method 4 3 0 Results 49CFR173 Subpart A General Subpart A does not include any prescriptive specifications for the package Part 173 Subpart B Preparation of Hazardous Materials for Transportation 173 21 Forbidden materials and packages This section contains specifications that are either not applicable to the 8 120B or that must be met by the shipper relative to contents of a shipment 173 22 Shipper s responsibility This section contains specifications that must be met by the shipper 173 22a Use of packagings authorized under exemptions This section is not applicable to the CNS 8 120B 173 23 Previously authorized packaging This section is not applicable to the CNS 8 120B 173 24 General requirements for packagings and packages a Applicability Except as otherwise provided in this subchapter the provisions of this section apply to 1 Bulk and non bulk packagings 2 New packagings and packagings which are reused and ER 01 004 Rev 1
130. e or dye penetrant NDE examinations shall be performed by an ASME Certified inspector Acceptance criteria for NDE shall be according to ASME Code Section III Div 1 Section NB5342 or NB5352 as applicable 8 1 2 STRUCTURAL TESTS No structural testing is required 8 1 3 LEAK TESTS This test shall be performed prior to acceptance and operation of a newly fabricated package in accordance with ASTM E 427 using a leak detector capable of detecting the applicable leak rates specified in Figures 4 4 and 4 7 in Chapter 4 Calibration of the leak detector shall be performed using a leak rate standard traceable to NIST The standard s setting shall correspond to the approved leak rates specified in Figures 4 4 and 4 7 in Chapter 4 All four containment boundary penetrations must be tested e The volume above the vent port Stat O Seal e The volume between the drain line plug and interior of the cask e The annulus between the o ring seals of the primary lid e Theannulus between the o ring seals of the secondary lid All four of these volumes must be evacuated to a minimum vacuum of 20 Hg and then be pressurized to a minimum pressure of 25 psig with pure dichlorodifluoromethane R 12 or 1 1 1 2 tetrafluoroethane R 134a Use the detector probe to sniff the following areas e The vent port penetration on the underside of the primary lid e Around the outer plug of the drain line e Interior side of the inner o ring for the primary lid 8
131. e package which could have hydrogen greater than 5 For any package delivered to a carrier for transport the secondary container must be prepared for shipment in the same manner in which determination for gas generation is made Shipment period begins when the package is prepared sealed and must be completed within twice the expected shipment time ER 01 004 l Rev 1 Page 12 of 20 f The containment system will retain its radioactive contents under the reduction of ambient pressure to 25 kPa 3 6 pounds per square inch The following evaluation is performed to show that the cask can safely withstand a reduced external pressure to 3 6 absolute A reduction in external pressure to 3 67 absolute assuming a maximum internal pressure normal conditions of Ibs ae transport of 8 953 gauge is equivalent to a net internal pressure of 20 187 Ata net internal pressure of 20 0 the loads on the primary and secondary lid bolts and cask wall will be as follows For the primary lid Dp P where A area of primary lid N number of bolts 20 The load on each of the primary lid bolts will be p 57328 20 15 4940 lbs 74 20 According to ASTM specification A 354 the tensile strength for the 2 8UN primary lid bolts is 415 446 Ibs The margin of safety is 415 446 4240 1 96 For the secondary lid Ap P where A area of primary lid N number of bolts 12 The load on each of
132. e properly converged This procedure should include a discussion on how the figure of merit FOM and 10 statistical checks were used to ensure the quality of the precision of the calculation and the steps taken when any checks have failed Provide the relative error R value for all calculations presented in Tables 9 3 1 through 9 3 11 in CALC NU 391 Rev 6 The MCNP manual states that R values greater than 0 1 are not reliable Justify the calculations for any R value greater than 0 1 This information is required by the staff to determine compliance with 10 CFR 71 47 and 10 CFR 71 51 a 2 Response to 5 7 We run lower gamma energy cases longer in order to improve statistics The non azimuthally symmetric cases 1 e top corner source cases also require more run time since the dose rates are tallied over narrow axial strips which lie at the azimuth of the source point whereas the azimuthally symmetric cases can employ larger tally areas that extend over the entire 360 degree azimuthal span of the cask exterior surfaces In order to ensure that MCNP calculations have properly converged the following steps are taken e MCNP responses are examined to see if they behave predictably without unexpected sudden changes or large variations e The code output is examined to ensure that important features such as streaming paths or shielding discontinuities are adequately sampled e When tallies have relative error levels over 0 10 or
133. e shipment leak test of LSA material and SCO objects in the CoC amendment ES proposes the Condition be worded as follows Prior to each shipment the package must be leak tested in accordance with Section 8 3 2 2 of the application For contents that meet the 10 CFR 71 4 definitions of Low Specific Activity LSA or Surface Contaminated Object SCO and also meet the exemption standard for LSA material and SCO objects in 10 CFR 71 14 b 3 1 the pre shipment leak test is not required Basis The Condition 8 exemption for the pre shipment leak test of LSA material and SCO objects that was included in Revision 18 appears to have been inadvertently omitted in CoC Revision 19 Requested Change 4 Delete Condition 12 of Revision 19 of the CoC Basis If the ongoing CoC amendment is approved and effective by August 31 2013 this condition will no longer applicable because the seals authorized in CoC Revision 17 will no longer be permitted for use Requested Change 5 Add a Condition allow a 90 day transition period for the addition of the steel plate to the lower impact limiter ES proposes the Condition be worded as follows The package may be used until insert date 90 days after the effective date on the amended CoC with the package design authorized in Revision 19 of the CoC 1 e Dwg Nos C 110 E 0007 Revision 18 and DWG CSK 12CV01 EG 0001 01 Revision 3 ES NRC 13 013 July 3 2013 Attachment Pg 2 of2 provided that sou
134. e the y sec g limits are not valid for p gt 9 0 g cm For discrete sources confirm that the sources meet the shoring requirement and the volume and the physical dimension specifications listed in the beginning of this Attachment Crud contamination or powder payload items can only be qualified using the y sec limits Table 7 1 column O or 9 5 For each energy calculate the y sec and y sec g fractions 1 e payload item source limit fraction Select the smallest of each pair of fractions at each energy and add the resulting fraction to the running sum of fractions 6 Repeat Steps 4 5 for each payload item adding the fractions to the running sum 7 Ifthe sum of fractions is less than 0 95 the payload s radiological source is acceptable 7 12 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Determine payload types and gather data Ci mass volume etc for each item General Sources most conservative Use Limits in Columns 056 Select a Payload Item Payload Qualification Type Use Limits in Columns Discrete Sources 803000 shored at centroid No more items No more energies Select an Energy or Nuclide Running Sum gt 0 95 Yes Calculate fractions for Add the smaller of the No y sec and two fractions to the STOP y sec g limits running sum Figure 7 1 Payload Qualification Flow Cha
135. e to meet other requirements of this subpart Any other structural part of the package which could be used to lift the package must be capable of being rendered inoperable for lifting the package during transport or must be designed with strength equivalent to that required for lifting attachments Section 2 4 3 of the SAR demonstrates that the structural requirements of the lifting attachments are met Failure of the lifting attachment will not impair the ability of the package to meet other requirements of this subpart There are no other structural parts of the package that could be used to lift it c The external surface as far as practicable will be free from protruding features and will be easily decontaminated The external surfaces of the package are free of protruding features except those necessary for the package to perform its function The external surfaces are hard and smooth and therefore easily decontaminated d The outer layer of packaging will avoid as far as EUREN pockets or crevices where water might collect There are no pockets or crevices on the outer layer of the packaging where water might collect e Each feature that is added to the package will not reduce the safety of the package Features of the package are evaluated in the SAR and it was determined that there are none that reduce its safety f The package will be capable of withstanding the effects of any acceleration vibration or vibration reso
136. e water has soaked in to the maximum extent without apprecia ble drying of the exterior of the specimen In the absence of evidence to the con trary this interval may be assumed to be two hours if the water spray is applied from four different directions simultaneously However no time interval may elapse if the water spray is applied from each of the four directions consecutively As discussed in Section 2 1 1 1 of the SAR the exterior of the package is fabricated from carbon steel The closure lids are bolted closed and sealed with gaskets Hence a water spray will have negligible effects on the package c Free drop test The specimen must drop onto the target so as to suffer maximum damage to the safety features being tested and 1 The height of the drop measured from the lowest point of the specimen to the upper surface of the target may not be less than the distance specified in Table 12 for the applicable package mass The target must be as specified in 173 465 c 5 Table 12 is as follows Table 12 Free Drop Distance for Testing Packages to Normal Conditions of Transport Packaging mass u Free drop distance Kilograms pounds Meters Feet Mass 5000 11 000 1 2 4 E 5 000 11 000 Mass to 0 9 3 10 000 22 000 10 000 22 000 Mass to 0 6 2 15 000 33 000 a gt 15 000 33 000 Mass 0 3 i 1 Section 2 6 6 of the SAR examines the package for the one foot free drop and c
137. ear Regulatory Commission Washington DC 20555 0001 Subject Response to Request for Additional Information for the Model No 8 120B Package Docket No 71 9168 Reference Letter from P Saverot NRC to S Sisley EnergySolutions Request for Additional Information for the Model No 8 120B Package Docket No 71 9168 July 15 2013 ADAMS Accession Number ML13197A036 Dear Sir or Madam By the referenced letter dated July 15 2013 NRC requested that EnergySolutions ES provide additional information needed for NRC staff to complete their review of the application to amend Certificate of Compliance CoC No 9168 for the 8 120B Shipping Package ES hereby provides the additional information requested by NRC in the referenced letter as described in Enclosures 1 and 2 Enclosure 3 contains one 1 paper copy of the non public version of the revised 8 120B SAR that contains security related sensitive information that should be withheld under 10 CFR 2 390 Enclosure 4 contains one 1 paper copy of the public version of the revised 8 120B SAR in which all proprietary information and security related sensitive information is redacted Enclosure 5 contains one 1 paper copy of the revised shielding analysis for the 8 120B cask which contains proprietary information An affidavit containing a full statement of the reasons that the proprietary information should be withheld from the public pursuant to the requirements of 10 CFR 2 390 is include
138. ed as follows e Use the 2 5 f limits 6 0 when the payload item has a volume of 2 5 ft 70 792 cm or less a height of 28 inches 71 16 cm or less and a diameter of 17 65 inches 44 84 cm or less and is shored at the centroid of the cavity e Use the 55 gallon limits 6 9 when the payload item has a volume of 7 7 fe 218 868 cm or less a height of 33 5 inches 85 1 cm or less and a diameter of 25 7 inches 65 3 cm or less and is shored at the centroid of the cavity e Ifthe payload item does not meet the requirements of either the 2 5 ft or 55 gallon definitions regardless of shoring then use the y sec limit for general sources O and the general y sec g limit 6 Source limits from Table 7 1 may not be interpolated in energy The proper procedure for gammas and for equivalent bremsstrahlung gammas is to round source energies up to the next higher energy level in Table 7 1 For the purpose of qualification the total y sec source strength for the entire payload is determined for each gamma energy group Then for each gamma energy group the y sec g source strength density is conservatively determined based on the highest source strength hottest portion of the payload Averaging of the source strength density is not allowed either between payload items or within payload items This conservative approach ensures that package dose rate limits will be met even for payloads for which the source strength density is not uniform
139. eferences 1 through 5 Attached to each of the referenced letters is a Summary of Changes specific to the revision of the SAR submitted with the letter For completeness and to summarize all SAR changes made in support of the subject CoC amendment request a Consolidated Summary of Changes to the 8 120B SAR has been prepared and is included in Attachment 1 This is provided only for your convenience since the same information was provided to NRC piecemeal in the referenced letters 2105 South Bascom Ave Suite 230 Campbell California 95008 408 558 3500 Fax 408 558 3518 www energysolutions com ES NRC 13 026 November 13 2013 Page 2 of 2 Should you or your staff have questions please contact the undersigned Sincerely Steven E Sisley Licensing Manager EnergySolutions Products and Technology Group 408 558 3509 E Mail ssisley energysolutions com Attachments 1 Consolidated Summary of Changes 8 120B Consolidated SAR Revisions 4 through 7 9 pages ES NRC 13 026 Attachment I November 13 2013 Page of 4 Consolidated Summary of Changes 8 120B Consolidated SAR Revisions 4 through 7 Consolidated Revision 4 Changes Reference 1 Front Matter x Added blank page Editorial formatting for two sided printing 123 1 Expanded description of impact Revised for clarity limiter skin and cover plates impact limiter in order to maintain maximum package 13 Added list of drawi
140. elding analysis 5 3 Corrected Table 5 1 cross Editorial correction reference in last sentence of 1 paragraph Table 5 1 3 1 2 3 Revised to discuss application of tolerances modeling of the cask cavity liner cladding and radial thermal barrier and adjustments to impact limiter model to account for effects of NCT drop tests Added text to Analysis Method Revised in response to RAI 5 7 Uncertainties and Conservatisms section to discuss results with relative error levels between 0 05 and 0 1 and tallies that do not pass all 10 statistical checks performed by MCNP Updated to reflect results of revised shielding analysis Revised in response to RAI 5 2 and 5 6 Table 5 5 Figure 5 3 Figure 5 4 Revised in response to RAI 5 6 and 5 7 Revised step and added footnote to clarify when the requirement is waived Revised in response to RAI 7 1 Table 7 1 and Updated to reflect results of Revised in response to RAI 5 6 examples in revised shielding analysis and 5 7 Attachment 1 of Chapter 7 ES NRC 13 026 November 13 2013 Page 7 of 9 Consolidated Summary of Changes 8 120B Consolidated SAR Revisions 4 through 7 Revised to clarify required testing Revised to address issue for containment seals 2 bullet identified during inspection of and replaced reference to fabrication activities and specification 3 bullet editorial chan
141. ements for Fracture Critical Components of the Bel DOB aS em ML EC 2 66 Table 2 8 Stress Intensities in 8 120B Cask under Reduced External Pressure 2 67 Table 2 9 Stress Intensities in 8 120B Cask under Increased External Pressure and Immersion Nsa 2 68 Table 2 10 Normal Condition Drop Test Summary eene 2 60 Table 2 11 Stress Intensities in 8 120B Cask under 1 ft End Drop Hot Condition 2 70 Table 2 12 Stress Intensities in 8 120B Cask under 1 ft End Drop Cold Condition 2 71 Table 2 13 Stress Intensities in 8 120B Cask under 1 ft Side Drop Hot Condition 2 72 Table 2 14 Stress Intensities in 8 120B Cask under 1 ft Side Drop Cold Condition 2 73 Table 2 15 Stress Intensities in 8 120B Cask under 1 ft Corner Drop Hot Condition 2 74 Table 2 16 Stress Intensities in 8 120B Cask under 1 ft Corner Drop Cold Condition 2 15 Table 2 17 Hypothetical Accident Condition Drop Test Summary sss 2 76 Table 2 18 Stress Intensities in 8 120B Cask under 30 ft End Drop Hot Condition 2 77 Table 2 19 Stress Intensities in 8 120B Cask under 30 ft End Drop Cold Condition 2 78 Table 2 20 Stress Intensities in 8 120B Cask under 30 ft Side Drop Hot Condition 2 79 Table 2 21 Stress I
142. emove the air test manifold and all associated parts treating all parts as potentially contaminated and inspect the set screw plug to ensure that there are no defects 1 e cracks deformed or stripped threads etc If the set screw plug is defective obtain a replacement from EnergySolutions Clean the test port set screw plug of all debris thread tape ect and reinstall in the primary lid Hand tighten until the set screw plug is snug Page 7 of 15 Air Pressure Drop Test for 8 120B Cask Certificate of C onformance USA 9168 B U TR TP 002 Revision 20 5 2 Pressure Drop Test For Primary Lid O Ring Seal Note 5 2 1 5 2 2 5 2 3 5 2 4 5 2 5 5 2 6 5 21 Review the troubleshooting guide listed in A ppendix B prior to performing the air pressure drop leak test Following the instructions in Appendix B should help obtain a successful air leak test of the cask Ensure cask is assembled in accordance with Reference 2 1 and applicable drawings listed in Reference 2 2 Verify cask lid bolts and vent port socket head cap screw are properly torqued to values listed in the cask handling procedure Using a 3 4 inch allen wrench remove the set screw plug from the primary lid test port Retain for reinstallation Remove any debris foreign materials from the air test port Ensure that the o ring gasket on the adapter test manifold is in good condition and lubricated Replace if necessary Attach manifold to
143. ent The cask may not be used as a Type B package until the damage is assessed by EnergySolutions CMF and repairs if required are made to achieve conformance with Reference 3 7 Steps of this procedure in Section 5 0 may be performed in non sequential order 5 1 Loading Procedure Note If it is necessary to remove the cask from the trailer refer to Section 5 3 5 1 1 Prepare to Load the Cask Warning Treat the underside of the lids the inside surfaces of the cask and any bolts or seals removed as potentially radiologically contaminated Note The cask may be loaded using either pallets or a liner processed through either the primary or secondary lid Follow Step 5 1 2 for loading pallets Follow Step 5 1 3 for loading a liner through the primary lid Follow Step 5 1 4 for processing liner through secondary lid 5 1 2 Procedure for Loading Pallets 5 1 2 1 Remove upper impact limiter Note Position cask and trailer on a level surface visual determination to facilitate impact limiter and lid removal 5 1 2 1 1 Remove the security seal Properly dispose of removed seal 5 1 2 1 2 Remove impact limiter lifting lug covers 5 1 2 1 3 Loosen ratchet binders securing impact limiter Page 10 of 41 Handling Procedure for Transport Cask Model 8 120B C of C Number 9168 5 1 2 1 4 Note 5 1 2 1 5 5 1 2 1 6 Caution 5 1 2 1 7 TR OP 035 Revision 25 Remove holding pin and bolt from upper end of ratchet binder Ret
144. ent leak testing requirement for LSA material and SCO shipments 8 120B package now require pre shipment leak testing ES NRC 13 019 September 20 2013 Attachment 1 Page 2 Summary of Changes 8 120B Consolidated SAR Revision 6 Section Change Purpose 8 3 2 2 a All shipments made in the 8 120B package now require pre shipment leak testing Deleted note regarding exemption from pre shipment leak testing requirement for LSA material and SCO shipments Added the required pre shipment Editorial clarification leak test pressure Revised to clarify that the Editorial correction allowable pressure drop is 0 1 psig and that the maximum graduation not sensitivity of the pressure guage shall be 0 1 psig Enclosure 1 Responses to Request for Additional Information 2 pages total ES NRC 13 019 September 20 2013 ES NRC 13 019 Enclosure 1 Docket No 71 9168 Response to Request for Additional Information The response to the NRC Request for Additional Information RAT associated with the EnergySolutions request to amend the Certificate of Compliance CoC for the Model No 8 120B Shipping Package is provided herein The NRC RAI question which is shown in italics is followed by the ES response and a summary of the resulting changes to the 8 120B Safety Analysis Report QUESTION During the review of your application for rev
145. ent port 8 2 5 COMPONENT AND MATERIAL TESTS EnergySolutions will apply its USNRC approved 10CFR71 Appendix B Quality Assurance Program which implements a graded approach to quality based on a component s or material s importance to safety to assure all materials used to fabricate and maintain the 8 120B are 8 4 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 procured with appropriate documentation which meet the appropriate tests and acceptance criteria for packaging materials This includes as example e ASTM steel material used for shells lids bolts etc will comply with and meet ASTM manufacturing requirements e Containment seals will be made from elastomeric compounds that have been qualified using ES C 038 Reference 8 4 2 which includes requirements for hardness low temperature compatibility permeability and temperature pressure testing Fabricated seals are suitable for use if the delivered seals are traceable to a batch of material manufactured under the same process as and having the same chemical composition as a qualified compound Acceptance testing for containment seals will include hardness and low temperature compatibility testing on each batch of elastomer plus dimensional inspections on each seal all per the acceptance criteria in ES C 038 e The impact limiter foam will meet the requirements of ES M 175 Reference 8 4 1 8 2 6 SHIELDING TESTS Shielding integrity of the package will
146. ent that any normal condition regulatory dose rate limits would be exceeded The allowable contents are so broad that the applicant chooses generic geometries for the contents to bound all the possible contents These source geometries remain unchanged from the last CoC revision and therefore remain acceptable by the staff 5 3 2 Material Properties Materials used in the shielding evaluation are presented in Table 5 3 The applicant did not change any of the material properties in this application from the last revision of the CoC Therefore the staff s conclusion that they are acceptable remains valid 5 4 Shielding Evaluation 5 4 1 Methods The applicant performed shielding calculations with MCNP5 Rev 1 51 MCNP is a three dimensional Monte Carlo transport code developed and maintained by Los Alamos National Laboratory The code s capabilities include modeling of and determining dose rates from package design features where radiation streaming may be a concern This code is used 26 extensively for shielding calculations by industry Given the code s capabilities and its extensive application in industry ensuring the code is well vetted the staff found the code acceptable for use in the present application Maximum quantities of radioactive material are based on the maximum gamma energy of the content as limited by the emission rate in Table 5 5 over the range of 0 5 MeV to 3 5 MeV The applicant calculates the values in Table 5 5
147. entered secondary lid is sealed with a double o rings and twelve equally spaced 2 inch diameter bolts The lid sealing surfaces are stainless steel and the space between the double o ring seals is provided with a test port for leak testing The top and bottom of the cask is provided with steel encased rigid polyurethane foam impact limiters The impact limiters are secured to each other about the cask with eight inch diameter ratchet binders The impact limiters are 102 inches in diameter and the overall height of the package with the impact limiters attached is 132 inches The package is provided with four tie down and two removable lifting devices Each lid is provided with three lifting lugs The maximum gross weight of the packaging and contents is limited to 74 000 pounds The approximate as built weights of the packaging components per Reference 3 7 are as follows Cask Weight Empty Including Lids and Thermal Shield 49 640 pounds er during 5 200 pounds Cask Secondary DA asset ceciderunt Cea up tenia as 1 975 pounds Secondary Lid Thermal Shield et idas 250 pounds Maximum Cask Payload Including Shoring sess 13 360 pounds impact Limiters eath M M 5 500 pounds Individual component as built weights may exceed the design weights in Reference 3 7 due to fabrication tolerances However the maximum weight of the payload must not exceed 13 3
148. epartment after the contents have been removed Remove any liquid or foreign materials from the cask cavity Treat this liquid or material as potentially radiologically contaminated Visually inspect the cask for damage to the lid impact limiter O Rings seals O Rings seal seating surfaces ratchet binders lifting lugs lifting slings and tie downs When lowering a liner or pallet into cask be alert to the possibility of airborne radiological contamination escaping the cask Visually inspect all bolts 1 e primary and secondary lid bolts lifting lug bolts etc vent port socket head cap screw if removed and test port set screws for defects prior to each shipment and obtain replacements from EnergySolutions CMF for any parts that show cracking or other visual defects Caution Only remove the cask lid vent port socket head cap screw if needing to relieve internal pressure so that the primary lid can be Page 6 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 Note 4 3 8 4 3 9 removed Use caution not to damage the vent port socket head cap screw or vent port seal For every 8 120B cask shipment whether or not the lid bolts or vent port socket head cap screw have been removed the primary lid secondary lid and vent port seals must be leak tested prior to shipment in accordance with Reference 3 3 A packaging containing quantities of radioactive material in ex
149. eplace the top bolts in the ratchet binders Insert holding pins Tools wrenches pipes ect are not permitted to be used on any cask ratchet binder Using these tools will cause damage to ratchet binders Tighten the ratchet binders hand tight and return ratchet handles to storage position leaving flip block in the lock position Place security seals on the impact limiter Install impact limiter lifting lug covers Inspect the cask tie down cables for tightness Tighten if necessary The Health Physics Technician shall survey all exterior surfaces of the cask for contamination and radiation levels Decontaminate as required to meet the limits set in Site radiation and contamination release procedures and Reference 3 2 Before the empty cask leaves the shipper s facility the following shall be confirmed 5 2 16 1 5 2 16 2 5 2 16 3 5 2 16 4 5 2 16 5 Cask verified to be empty of radioactive waste For foreign material exclusion concerns cask internals must also be verified clean and clear of all non radioactive debris Cask internal and external removable contamination does not exceed Site Release Limits 49 CFR 173 428 49 CFR 173 443 and 10 CFR 71 87 as applicable see References 3 2 and 3 5 The cask lid bolts and vent port socket head cap screw are properly torqued Trailer placarding and cask labeling and marking meet D O T specifications in References 3 1 and 3 2 as applicable That radi
150. equirement is waived for uniformly distributed resins filters and for solidified wastes with no dimension less than 1 cm Replace secondary lid 5 1 4 5 1 Note 3 1 4 5 2 Attach crane and lifting sling to lifting lugs on secondary lid The cables used to lift the secondary lid must have a true angle of not less than 45 with respect to the horizontal The secondary lid O Ring seals shall be visually inspected for serviceability ensuring that they are in the proper position and free of cracks tears cuts or discontinuities which may prevent them from sealing properly The seal seating surface shall be visually inspected to ensure that they are free of damage debris gravel or any foreign matter which might damage the seals or prevent the seals from properly sealing If any defects are detected that may prevent the seals from forming a seal contact EnergySolutions CMF Refer to the provisions of Step 4 4 2 for leak test requirements Page 21 of 41 Handling Procedure for Transport Cask Model 8 120B C of C Number 9168 Warning Caution 5 1 4 5 3 5 1 4 5 4 Caution 5 1 4 5 5 Note 5 1 4 5 6 Note TR OP 035 Revision 25 Inspect and clean the O Ring seating surfaces A very thin coat of vacuum grease or petroleum jelly should be applied to the sealing surface of the O Ring prior to installing and torquing the lid Inspect the air test annulus and leak test port to assure that they are free of f
151. er is 9168 see Reference 2 2 REFERENCES 2 1 TR OP 035 Handling Procedure for Transport Cask CNS 8 120B Certificate of Compliance Number 9168 latest revision required 2 2 Certificate of Compliance Number 9168 Docket Number 71 9168 issued by the Nuclear Regulatory Commission latest revision required 2 3 ES QA PR 005 Records 24 Drawing DWG CSK 12GCL1 ME 001 Air Test Manifold or equivalent system 2 5 ES AD PR 013 Control of Nonconforming Items 2 6 Drawing C 110 E 0007 8 120B Shipping Cask DEFINITIONS 3 1 Set Screw Plug 1 1 2 set screw used to plug all 3 test ports Reference 2 6 Item 34 3 2 Socket Head Cap Screw 1 2 socket head cap screw used to plug vent port Reference 2 6 Item 27 3 3 Lid Bolts 2 hex head bolt used to fasten primary and secondary lids to cask body Reference 2 6 Item 39 34 Vent Port Seal o ring used to seal vent port Reference 2 6 Item 26 35 Lid O Ring Inner and outer o rings used to seal primary and secondary lids Reference 2 6 Items 22 thru 25 Page 3 of 15 Air Pressure Drop Test for 8 120B Cask TR TP 002 Certificate of C onformance USA 9168 B U Revision 20 4 REQUIREMENTS 4 1 4 2 Prerequisites Note Examination of o rings is only necessary if the lid or vent port socket 4 1 1 head cap screw is removed The cask shall be examined visually for integrity condition of o rings and sealing surfaces Cask sealing surfaces must be free o
152. ered Op 5x EUN 5 TE tb 1096psi which yields the A 0785dj 3 14x36 6 in 3 14x35 1 in following margin of safety _ 32 000 1096 M S 1 28 2 e Penetration test For the penetration test the specimen must be placed on a rigid flat horizontal surface that will not move significantly while the test is being per formed 1 A bar of 3 2 centimeters 1 25 inches in diameter with a hemispherical end and a mass of 6 kilograms 13 2 pounds must be dropped and directed to fall with its longitudinal ax s vertical onto the center of the weakest part of the specimen so that if it penetrates far enough it will hit the containment system The bar may not be significantly deformed by the test and 2 The height of the drop of the bar measured from its lower end to the intended point of impact on the upper surface of the specimen must be 1 meter 3 3 feet or greater Impact energies resulting from the penetration test at 1 0 meter will have no significant effect on the packaging The impact limiter fully protects both ends of the cask leaving only the central body exposed The cask body is manufactured from 2 thick steel plate and backed with 1 7 8 of lead The ends are comprised of steel 5 1 thick No valves Valve covers or fragile protrusions exist ER 01 004 Rev 1 Page 19 of 20 4 0 Conclusions and Recommendations The requirements of 178 350 b are that Each Specification 7A packaging must b
153. ergySolutions CMF before proceeding with cask operations Contact Health Physics Department for instructions on removal of any liquids or foreign materials from the cask cavity Caution Care should be taken during liner handling operations to prevent damage to cask sealing surfaces 5 2 11 Place a new liner in the cask if required The liner cables should be taped on the liner to ensure the cables do not interfere with installing the HIC lid Reload the pallets into the cask if required Note Load only one pallet at a time Warning Treat any material removed from the bottom of the liner or pallets as potentially radiologically contaminated Page 28 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 5 2 11 1 Caution 5 2 11 2 5 2 11 3 Attach crane hook to slings on liner the grapple ring on the liner or to the lifting ring on the pallet and slowly lift the liner or pallet Clean the bottom of the liner or pallet before placing it into the cask Do not damage the O Ring seating surfaces the sides of the cask or inner walls Carefully lower the liner or pallet into the cask and detach the crane hook Repeat Steps 5 2 11 and 5 2 11 2 to place other pallet into cask 5 2 12 Replace primary lid Note If the secondary lid is not sealed with a proper EnergySolutions security seal the secondary lid shall be removed for inspection of O Rings and seating su
154. es of information in confidence The application of that system and the substance of that system constitute EnergySolutions policy and provide the rational basis required Under that system information is held in confidence if it falls in one or more of several types the release of which might result in the loss of an existing or potential competitive advantage as follows a The information reveals the distinguishing aspects of a process or component structure tool method etc and the prevention of its use by EnergySolutions competitors without license from EnergySolutions gives EnergySolutions a competitive economic advantage b The information consists of supporting data including test data relative to a process or component structure tool method etc and gives EnergySolutions a competitive economic advantage e g by optimization or improved marketability c The information if used by a competitor would reduce the competitor s expenditure of resources or improve the competitor s advantage in the design manufacture shipment installation assurance of quality or licensing of a similar product Page 2 of 4 iii iv v vi d The information reveals cost or price information production capacities budget levels or commercial strategies of EnergySolutions its customers or suppliers e The information reveals aspects of past present or future EnergySolutions or customer funde
155. etroleum jelly etc Treat all debris removed from the bottom surface of the lid as potentially radiologically contaminated Clean the bottom surface of the lid and inspect lid bolt holes for damage and accumulation of debris Remove debris if required Visually inspect and clean O Ring seating surfaces for any damage or material that will prevent O Rings from forming a seal If inspection is satisfactory apply a very thin coat of vacuum grease or petroleum jelly Contact EnergySolutions CMF if any damage nicks gauges or anything that might interfere with the o rings sealing properly Care should be taken during handling operations to prevent damage to cask sealing surfaces Visually inspect the cask lid bolts for defects and obtain replacement for any bolts that show cracking or other visual defects Lubricate bolt threads if required and Visually inspect lid bolt holes for damage defects and accumulation of debris Remove debris if required Contact EnergySolutions CMF for any bolt holes that show signs of cracking or visual signs of distress Page 37 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 5 5 3 6 Note 5 5 3 7 Note Caution 5 5 3 8 Note 5 5 3 9 5 5 3 10 Note 5 5 3 11 Note 5 5 3 12 5 5 3 13 Lift the primary lid and lower onto the cask and position using alignment marks and alignment pins To more easily seat primary
156. eumatic or hydraulic torque wrenches non impacting may be used to install the bolts Re torque all the bolts to 500 50 ft Ibs lubricated using a star pattern It is recommended that the bolts be torqued a second time to 500 x 50 ft Ibs repeating the star pattern Check torque on all bolts at least once using a circular pattern to 500 50 ft Ibs Start torque at the same start bolt used in Step 5 1 2 6 7 Torque the vent port socket head cap screw to 20 2 ft lbs If the vent port socket head cap screw is removed the O ring Seal shall be inspected and replaced if damaged Prior to installation the O ring Seal shall be installed on the vent port socket head cap screw and a thin layer of anti seize should be applied to the vent port socket head cap screw threads Leak test the cask primary lid secondary lid and vent port per Reference 3 3 After completing the leak tests in accordance with Reference 3 3 ensure all 3 test port set screw plugs are in place Seal the primary lid with security seals Ensure that all dirt clay debris is removed from the cask lids prior to installation of the cask impact limiters Replace secondary lid thermal shield and upper impact limiter Ensure inner surfaces of impact limiter are below external package limits as specific in Reference 3 2 Also this Page 16 of 41 Handling Procedure for Transport Cask Model 8 120B C of C Number 9168 Note Note TR O
157. f any defects that would prevent forming a seal Cask sealing surfaces shall be clean and free of contaminants which could affect the leak test Moisture in the test air may affect the test results Therefore the air should be as dry as possible Note Nitrogen may be used in place of plant air A troubleshooting guide is listed on Appendix B of this procedure Refer to Appendix B prior to assembly of the cask and or prior to performing the air leak test Tools Materials and Equipment 4 2 1 4 2 2 4 2 3 4 2 4 4 2 5 4 2 6 Air Induction Test Manifold see References 2 4 or a similar system Calibrated gauge capable of indicating 30 psig 1 of full scale with a maximum graduation of 0 1 psig The accuracy of the gauge shall be verified at least annually RECORD GAUGE CALIBRATION INFORMATION ON APPENDIX A Sockets and wrenches 4 2 3 1 3 8 allen wrench by 3 8 drive socket 4 2 3 2 3 4 allen wrench Calibrated 0 50 ft Ib torque wrench or equivalent with appropriate adapter to fit socket head cap screw listed in Step 5 3 4 RECORD TORQUE WRENCH CALIBRATION INFORMATION ON APPENDIX A O Ring lubricant vacuum grease or petroleum jelly Acceptable bolt plug lubricant Moly Z Neolube or anti seize Page 4 of 15 Air Pressure Drop Test for 8 120B Cask TR TP 002 Certificate of C onformance USA 9168 B U Revision 20 4 3 Precautions L imits 4 3 1 THE CASK WILL NEED TO BE UNLOADED IF LOADED A
158. fting equipment if required and proceed with cask use 5 4 Reinstalling the Cask on Trailer 5 4 1 5 4 2 Locate the trailer 5 4 1 1 5 4 1 2 Position the trailer within reach and safe load limits of the crane Be sure the trailer is level visual determination Prepare cask for reinstallation on trailer 5 4 2 1 5 4 2 2 Check all lid bolts on the primary and secondary lids torqued to 500 50 ft Ibs using a star pattern Bolt torque does not have to be checked on bolts with security seals Reinstall the two 2 cask lifting lugs per steps 5 3 3 5 through 5 3 3 7 Page 34 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 5 4 3 Connect lifting equipment to the two cask lifting lugs Note The cables used to lift the cask must have a true angle of not less than 60 with respect to the horizontal Caution Do not lift cask by lifting lugs on the primary or secondary lids Caution Be sure the lifting equipment is adequate to lift the cask The empty weight of cask with lids and thermal shield is approximately 49 640 pounds or as stated on nameplate Total gross design weight of loaded cask is approximately 63 000 pounds 5 44 Prepare mounting surfaces on bottom impact limiter and cask Warning Ensure inner surfaces of impact limiter are below external package limits as specified in Reference 3 2 and or site release limits Also this should include
159. gap above the secondary lid The thermal shield assembly is attached to the secondary lid lifting lugs with hitch pins The impact limiters are 102 inches in outside diameter and extend 22 inches beyond each end of the cask There is a 50 0 inch diameter void at each end Each impact limiter has an external shell fabricated from ductile low carbon steel which allows it to withstand large plastic deformations without fracturing The volume inside the shell is filled with a crushable shock and thermal insulating polyurethane foam The polyurethane is sprayed into the shell and allowed to expand until the void is completely filled The foam bonds to the shell which creates a unitized construction for the impact limiters The impact limiters skin is 12 gage steel including the upper impact limiter s weather cover The lower impact limiter has a 2 thick steel cover plate 1 1 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Secondary Lid Thermal Shield not shown for clarity Primary Lid Inner Shell Lead Shielding Tie Down Arm Outer Shell Fire Shield Impact Limiter Foam Figure 1 1 Features of the 8 120B Cask 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 The properties of the foam are further described in Section 2 2 The top and bottom impact limiters are connected together by eight one inch diameter ratchet binders This serves to hold the impact limiters in p
160. ge Changed section from an appendix Specifications which were not to references included in the appendix are references The section has been revised to reflect this Consolidated Revision 6 Changes Reference 4 Table 4 2 Corrected to refer to 8 120B Editorial correction Caption Table 4 2 Deleted note regarding exemption All shipments made in the Footnote from pre shipment leak testing 8 120B package now require requirement for LSA material and pre shipment leak testing SCO shipments Revised referenced procedure step Editorial correction in the last sentence of first paragraph Corrected revision number of Editorial correction Reference 5 7 2 7 3 7 4 Change step number from 7 1 9B Revised to avoid confusion through to 7 1 10 and renumbered all since A steps are associated 71 13 subsequent steps accordingly with loading through the cask secondary lid V1 0 Revised second sentence and Clarify conditions under which associated footnote the requirement is waived and the basis for waiving the requirement 7 1 14 7 4 7 5 Change step number from 7 1 12A Revised to avoid confusion through to 7 1 14 and renumbered all since A steps are associated Pacha subsequent steps accordingly with loading through the cask secondary lid ES NRC 13 026 November 13 2013 Page 8 of 9 Consolidated Summary of Changes 8 120B Consolidated SAR Revisions 4 through 7 Revised step and deleted note
161. hanges 8 120B Consolidated SAR Revisions 4 through 7 Table 8 1 8 8 Added Note 1 Clarify the periodic leak testing requirements for shipments of powdered radioactive materials 8 3 2 2 d 8 9 Deleted last sentence Pressure gauge graduation requirement is not necessary Page 2 29 in SAR Consolidated Revision 7 due to repagination Inadvertently omitted from Summary of Changes in Reference 1 Later revised in SAR Consolidated Revision 5 in response to RAI Step number changed in SAR Consolidated Revision 6 Inadvertently omitted from Summary of Changes in Reference 4
162. hanges to the shielding model are as follows e The new 2 thick carbon steel shield disk is modeled in the hollow end section of the lower impact limiter This disk is only modeled in the NCT analyses e The impact limiter steel casing which is 12 gauge sheet is now modeled in the NCT cases only The dimensions used account for NCT deformations see Response to 5 6 The impact limiter foam is still conservatively neglected e The 12 gauge steel cladding that covers the top bottom and radial surfaces of the cask inner cavity is now modeled in both the NCT and HAC analyses Because we have taken credit for the cladding we have also deducted the maximum tolerances from the sheet and plate discussed further below e The 3 16 thick radial thermal shield which covers the axial section of the cask body that lies between the impact limiters is now modeled in both the NCT and HAC analyses Because we are including steel which has previously been neglected the NCT and HAC models were also revised to account for thickness tolerances in the steel cask components This change resulted in small changes to many of the modeled coordinates In most cases the minimum plate tolerances were modeled The bolt ring drawing item 4 however is conservatively modeled at the maximum thickness tolerance as this raises the lid relative to the top of the lead Similarly the thickness of the seal wear plate drawing item 9 was increased to its maximum thic
163. hat by meeting the 200w decay heat limit the temperature requirement of 10 CFR 71 43 g is met No temperature survey is required That all security seals are properly installed Prior to shipping a loaded package inspect the exterior of the cask for damage e g large dents gouges tears to the impact limiter skin and thermal shield Contact EnergySolutions if damage is present Prior to shipping a loaded package confirm that the periodic leak test described in Section 8 3 2 1 has been performed For shipments of powdered radioactive materials confirm that most recent periodic leak test of the 8 120B demonstrated leaktight status 7 2 UNLOADING THE PACKAGE In addition to the following sequence of events for unloading a package packages containing quantities of radioactive material in excess of Type A quantities specified in 10 CFR 20 1906 a 7 5 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 shall be received monitored and handled by the licensee receiving the package in accordance with the requirements of 10 CFR 20 1906 as applicable Identification of packages containing greater than Type A quantities can be made by review of the shipping papers accompanying the shipment 121 12 2 7 2 3 7 2 4 7 2 5 7 2 6 7 2 1 7 2 8 7 2 9 Move the unopened package to an appropriate level unloading area Perform an external examination of the unopened package Record any significant ob
164. hat the requirements of this procedure are satisfied during testing Note The person witnessing the pressure drop test shall not be the same person performing the test 4 5 3 Operations and or maintenance personnel are responsible for preparing the container for testing and providing support during the pressure drop test Page 5 of 15 Air Pressure Drop Test for 8 120B Cask TR TP 002 Certificate of C onformance USA 9168 B U Revision 20 of DETAILED PROCEDURE Note This procedure must be used with the latest revision of the 8 120B cask 5 1 handling procedure T R O P 035 Pressure Drop Test For Secondary L id O Ring Seal Note Review the troubleshooting guide listed in Appendix B prior to performing the air pressure drop leak test Following the instructions in Appendix B should help obtain a successful air leak test of the cask 5 1 1 Ensure cask is assembled in accordance with Reference 2 1 and applicable drawings listed in Reference 2 2 Verify cask lid bolts and vent port socket head cap screw are properly torqued to values listed in the cask handling procedure 5 1 2 Using a 3 4 inch allen wrench remove set screw plug from the secondary lid test port Retain for reinstallation 5 1 3 Remove any debris foreign materials from the air test port 5 1 4 Ensure that the o ring on the adapter test manifold is in good condition and lubricated Replace if necessary Attach manifold to secondary lid test port by placing
165. have expired or will expire prior to the cask reaching the destination where it will be unloaded EnergySolutions CMF shall be contacted The basis for double verification is to assure that small high specific activity particles do not have the potential to migrate up into the annular gap between the primary lid and the cask bolting flange Payloads containing any form of isotope sources or containing highly activated fines swarf crud or other hot particles less than 1 cm in size are therefore not exempt Page 8 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 4 3 12 Use of impact wrenches to remove cask lid bolts is limited to breaking initial torque on the bolt Once the bolt is free to rotate further removal of bolt with impact wrench shall stop Final removal of lid bolts is to be done by hand Note Pneumatic or hydraulic torque wrenches non impacting may be used to remove the bolts 4 3 13 Impact wrenches should not be used for the installation of the cask lid bolts bolts should be installed and hand tightened then torqued using a star pattern Note Pneumatic or hydraulic torque wrenches non impacting may be used to install the bolts 4 3 14 Flammable gas hydrogen concentration is limited to less than 5 in volume Compliance with this concentration limit is determined by the methodology used in NUREG CR 6673 Note For any package containing materials with radioa
166. i is subjected to the tests prescribed in 173 466 or evaluated against these tests by any of the methods authorized by 173 461 a Not applicable ER 01 004 Rev 1 Page 15 of 20 173 415 Authorized Type A packages The following packages are authorized for shipment if they do not contain quantities exceeding A1 or A2 as appropriate a DOT Specification 7A 178 350 of this subchapter Type A general packaging Each offeror of a Specification 7A package must maintain on file for at least one year after the latest shipment and shall provide to DOT on request complete documentation of tests and an engineering evaluation or comparative data showing that the construction methods packaging design and materials of construction comply with that specification Use of Specification 7A packagings designed in ac cordance with the requirements of 178 350 of this subchapter in effect on June 30 1983 see 49 CFR Part 178 revised as of October 1 1982 is not authorized affer April 1 1997 This report should be retained by the shipper to meet the requirements of this para graph Note also the exception allowed by 173 431 is that a DOT 7A package can exceed A or A quantities in the contents if the contents are LSA or SCO materials b Any other Type A packaging that also meets the applicable standards for fissile materials in 10 CFR Part 71 and is used in accordance with 173 471 Not applicable to the CNS 8 120B package c Any Ty
167. icant increase over the discontinuity whether the discontinuity is in an area of interest 1 e potentially governing and the amount of shielding material missing due to the discontinuity In this case the discontinuities are in an area of interest but the amount of shielding lost in the notches is small and more than compensated by the thick lift lug pads tie down lugs and seal welds The lift lug pads are 2 thick plate and the notch area is significantly filled with weld metal due to the specified 7 cover fillet weld on the lift lug plate and the radial thermal barrier seal weld which must seal the 3 16 plate and the 5 16 standoff A standard survey instrument would read a significant drop over the notch area due to the extra shielding afforded by the plate and weld material Likewise the tiedown lugs would have a lower survey reading over the notch because they are 1 1 2 thick plate and the thermal barrier is also seal welded The notches are therefore not modeled in the shielding analysis ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information 5 2 Summary of SAR changes e Nochanges List all differences between the shielding model for the previous revision of the CoC and the current application for both NCT and hypothetical accident conditions HAC This information is required by the staff to determine compliance with 10 CFR 71 47 and 10 CFR 71 51 a 2 Response to 5 2 The c
168. icate bolt threads if required Visually inspect lid bolt holes for damage defects and accumulation of debris Remove debris if required Contact EnergySolutions CMF for any Page 12 of 41 Handling Procedure for Transport Cask Model 8 120B C of C Number 9168 5 1 2 4 5 1 2 3 8 TR OP 035 Revision 25 bolt holes that show signs of cracking or visual signs of distress Visually inspect and clean the O Ring seating surfaces Remove the contents of the cask Warning Treat the pallets as potentially radiologically contaminated items Caution Care should be taken during handling operations to prevent damage to cask sealing surfaces 5 1 2 5 5 1 2 4 1 5 1 2 4 2 3 1 2 4 5 5 1 2 4 4 Warning 5 1 2 4 5 Attach the crane hook to the pallet lifting ring Lifting the pallet straight up out of the cask and place it on absorbent material or plastic sheeting if required Remove the crane hook Repeat Steps 5 1 2 4 1 through 5 1 2 4 3 as necessary to remove both pallets from the cask Radioactively contaminated liquids may be pumped out or removed by use of an absorbent material Removal of any material from inside the cask shall be performed under the supervision of qualified health physics personnel with the necessary H P monitoring and radiological health safety precautions and safeguards Visually inspect the interior of the cask for any damage or defects that may affect the integrity of the c
169. ie 2 56 2 8 Accident Conditions for Air Transport of Plutonium eene 2 57 2 9 Accident Conditions for Fissile Material Packages for Air Transport 2 57 2 10 Special Por sssini dree nap E aves ins 2 57 2 11 Fuel RODS CE 2 57 2 12 Appendix o sass na ccoes on om decense do 2 58 212 1 lastofBefereuces cc vice uch oit nee ia 2 58 3 0 JXHERMAL EVALUATION iitineete stores ve ener adn dia ido Ri apa eeu eue Pho PN TA RENE RE Sion 3 1 3 1 Description of Thermal design ise dete A Rec ea s Pen eU anaes 3 1 Sill Design Estres tas 3 1 9wW 2 Content s Decay Meat tices ct ects e T et AD UMS 3 1 3 1 3 Summary Tables of Temperatures idad 3 1 3 1 4 Summary Table of Maximum Pressures eese enne 3 2 3 2 Material properties and component specificatiONS oconnoncnonononnconcnnnoncnoncnoncnnnnnnnn ccoo across 3 2 S200 Material Properties a ooo cesa eost tent A datio betae cda tede 3 2 3 22 Gomiponent SpeotieatlODisi Iii 3 2 3 3 Thermal Evaluation for Normal Conditions of Transport eese 3 2 A Cold nets eire qtue iecet dese ter tori pi Dt e ee eundo sendet beet be M hause cure Oto ute 3 3 3 3 2 Maximum Normal Operating Pressure ooooonocccnoncccnoncccnoncccnnnnnnnoncnnnnncnonncconnncnnnnos 3 4 A Ut A sot atm oc ed arti eet icu refi 3 6 3 4 Hypothetical Accident Thermal Evaluation eese enne 3 6 iv 8 120B Safety Analysis Report Consolidated
170. ies are for the basic material and should not include voids Radioactive payload items with densities above 9 0 g cc must be qualified using the y sec limits alone In summary all sources must be accounted for using the sum of fractions method described in the following procedure The only sources which may be considered insignificant and not included in the sum of fractions are e Gammas with energies below 0 3 MeV e All pure beta emitters with peak energies below 0 3 MeV e Pure beta emitters with peak energies above 0 3 MeV when the combined source of all such betas is under 2x10 f sec e Beta emissions from gamma emitting isotopes 7 9 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Table 7 1 Payload Source Streneth and Source Strength Density Limits Discrete Sources shored at centroid Source Density 2281606 3 634606 6 869606 1592607 617367 1919608 070 6 366608 050 4 185609 Co 60 4 074607 6137 353608 For discrete source limits use columns and O when the payload object meets the 2 5 ft size criteria or columns Band O when it meets the 55 gallon size criteria When the size meets neither criteria use columns Gand O 7 10 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Qualification Procedure The Payload Qualification Flowchart Figure 7 1 provides a graphical overview of the qualification process The procedure below provides more detailed ste
171. ies that do not pass all 10 statistical checks performed by MCNP e The payload source limit results presented in Table 5 5 Figures 5 3 and 5 4 and Table 1 of Chapter 7 are updated to reflect the new results for the few cases that were re performed with a longer computer runtime to improve result statistics CHAPTER 7 OPERATING PROCEDURES 7 1 Modify the language in proposed revision to Operating Procedure 7 1 9B regarding the closure of the secondary system By letter dated July 3 2013 ADAMS Accession No ML 13189A107 ES proposed a revision to Condition 7 of Rev 19 of the CoC by deleting this condition and adding step 7 1 9B to the Operating Procedures The staff finds in principle that adding this step to the operating procedures as opposed to being a CoC condition is acceptable however the staff finds that the proposed language is ambiguous Specifically For shipments of payloads that have a potential for hot particle migration e g activated metals or radioactive sources could have multiple interpretations Clarify this language and modify it to remove any ambiguity This information is required by the staff to determine compliance with 10 CFR 71 47 and 10 CFR 71 51 a 2 ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information Response to 7 1 We propose the change Step 7 1 9B to say Perform two independent physical verifications of the secondary container s closure
172. if required by the radiological qualification procedure of Attachment 1 7 1 10 Perform two independent physical verifications of the secondary container s closure system to ensure that it is properly closed and secured This requirement is waived for uniformly distributed resins filters and for solidified wastes with no dimension less than 1 cm 7 1 11 Clean and inspect lid seal surfaces 7 1 12 Replace the primary lid on the cask body Secure the lid by hand tightening the twenty 20 primary lid bolts 7 1 12 1 Torque using a star pattern the twenty 20 primary lid bolts lubricated to 250 ft lbs 25 ft lbs The basis for double verification is to assure that small high specific activity particles do not have the potential to migrate up into the annular gap between the primary lid and the cask bolting flange Payloads containing any form of isotope sources or containing highly activated fines swarf crud or other hot particles less than 1 cm in size are therefore not exempt 7 3 8 120B Safety Analysis Report Consolidated Revision 7 7 1 12A 7 1 13 7 1 14 7 1 15 7 1 16 November 2013 7 1 12 2 Re Torque using a star pattern the twenty 20 primary lid bolts lubricated to 500 ft lbs 50 ft lbs Replace the secondary lid on the primary lid Secure the lid by hand tightening the twelve 12 secondary lid bolts 7 1 12 1A Torque using a star pattern the twelve 12 secondary lid bolts lubricated
173. ight summary 4 Added to clarify that the effect of payload configuration on the package center of gravity is not significant and does not require separate evaluations of payload configurations limiter 3 Deleted separate line for Thermal Shield weight and combined weight of the thermal shield and plate added to lower impact limiter in Misc line and 4 Added discussion of possible shift in package center of gravity due to eccentric payload configurations Address impact of penetration test on impact limiter cover plates Changed to include thicknesses of the weather cover on the impact limiter and the plate added to the lower impact limiter Added for completeness and consistency with existing safety analyses More accurately depict design configuration Editorial figure caption missing in previous SAR revision Add discussion of damage to impact limiter covers resulting from HAC puncture test Changed graphic to show cover plate on lower impact limiter Added figure caption 2 Reduced Payload weight to 2 Maintain overall package offset additional weight of weight within limit Figure 2 5 Added for completeness and consistency with existing safety analyses Changed discussion to include the plate added to the lower impact limiter Revised 2 paragraph to discuss Editorial clarification treatment of impact li
174. ile the package is disassembled or empty between loading operations The previous opening of the containment boundary vent port on a prior LSA SCO shipment is not known during the loading of Type B contents Consequently Type B contents could be transported without performing a pre shipment leakage rate test on a vent port that was opened during a prior loading or between loading operations Therefore to prevent this from occurring the applicant has deleted the note regarding the exemption from pre shipment leak testing for LSA and SCO shipments All shipments made with the package require pre shipment leakage rate testing as indicated in Chapter 7 Operating Procedures Based on the review of the statements and representations in the application the staff concluded that the containment design of the Model No 8 120B package has been adequately described and evaluated per the change of contents and the package design meets the containment requirements of 10 CFR Part 71 5 0 SHIELDING EVALUATION The purpose of the shielding review is to verify that the package design meets the external radiation requirements of 10 CFR Part 71 for NCT and HAC The applicant requested an increase in radioactivity levels of about 30 for all contents The applicant performed a new shielding analysis to support the increase in contents by adding a steel plate to the bottom impact limiter and crediting the additional steel already present in the package The shielding
175. in Attachment 1 of this letter Should you or any member of your staff have questions please contact the undersigned at 408 558 3509 Sincerely Steven E Sisley Cask Licensing Manager EnergySolutions Attachments 1 Summary of Changes 8 120B Consolidated SAR Revision 6 2 pages 2105 South Bascom Ave Suite 230 Campbell California 95008 408 558 3500 Fax 408 558 3518 www energysolutions com ES NRC 13 019 September 20 2013 Page 2 of 2 Enclosures 1 Response to Request for Additional Information 2 Safety Analysis Report for the Model 8 120B Type B Shipping Packaging Consolidated Revision 6 September 2013 Non Public Version 1 paper copy Security Related Information Withhold Under 10 CFR 2 390 3 Safety Analysis Report for the Model 8 120B Type B Shipping Packaging Consolidated Revision 6 September 2013 Public Version 1 paper copy cc Mr Pierre Saverot Division of Spent Fuel Storage and Transportation Mr Dan Shrum EnergySolutions ES NRC 13 019 September 20 2013 Attachment 1 Page 1 The following is a summary of the changes incorporated in Revision 6 of the 8 120B Consolidated Safety Analysis Report The revisions indicators in the margins of Revisions 4 and 5 of the 8 120B Consolidated Safety Analysis Report have also been included in Revision 6 to indicate the cumulative changes that have been made in association with the request to amend the 8 120B CoC However the summary of the cha
176. in References 3 1 and 3 2 as applicable Page 23 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 5 1 6 2 5 1 6 3 5 1 6 4 5 1 6 5 5 1 6 6 5 1 6 7 5 1 6 8 5 1 6 9 Note 5 1 6 10 That exterior radiation levels do not exceed 200 millirem per hour 2 mSv h on contact 10 millirem per hour 0 1 mSv h at 2 meters and 2 millirem per hour 0 02 mSv h in the tractor cab in accordance with 49 CFR 173 441 and 10 CFR 71 47 see References 3 2 and 3 5 That cask external removable contamination does not exceed Site Release Limits 49 CFR 173 443 and 10 CFR 71 87 as applicable see Reference 3 2 and 3 5 Cask primary lid secondary lid and vent port o ring seals have been air pressure drop leak tested in accordance with Reference 3 3 Cask lid bolts and vent port socket head cap screw are properly torqued That the cask lids and impact limiters are sealed with security seals That all lifting lugs are removed or properly covered for transport Inspect the accessible exterior surfaces of the package for damage e g large dents gouges and or tears in the impact limiter skin or thermal shielding Contact EnergySolutions CMF if damage is identified Two independent physical verifications of the secondary container s closure system have been performed as part of the package loading operations to ensure that it is properly closed and secured Record the co
177. including UN standard packagings manufactured outside the United States the specification require ments in parts 178 and 179 of this subchapter or 2 The packaging is permitted under and conforms to provisions contained in 171 11 171 12 171 12a 173 3 173 4 173 5 173 7 173 27 or 176 11 of this subchapter Column 8 of the 172 101 Table specifies the applicable packaging specifications and exceptions for a hazardous materials being addressed for example Radioactive Material LSA n o s d Specification packagings and UN standard packagings manufactured outside the U S 1 Specification packagings A specification packaging including a UN standard packaging manufactured in the United States must conform in all details to the applicable specification or standard in part 178 or part 179 of this subchapter 2 UN standard packagings manufactured outside the United States A UN stan dard packaging manufactured outside the United States in accordance with na tional or international regulations based on the UN Recommendations on the Transport of Dangerous Goods may be imported and used and is considered to be an authorized packaging under the provisions of paragraph c 1 of this sec tion subject to the following conditions and limitations i The packaging fully conforms to applicable provisions in the UN Recommen dations on the Transport of Dangerous Goods and the requirements of this subpart including reuse prov
178. inconsistency did not affect any of the conditions of the certificate During the review of this amendment request ES submitted a notification dated August 14 2013 regarding the failure to observe CoC conditions for the package vent port leak test hold time ADAMS Accession Number ML 132474179 The pre shipment leakage rate test had been performed using a pressure drop test on the primary lid secondary lid and vent port seals To determine the required hold time for the pressure drop test a maximum test volume was calculated and for the lid seal the maximum hold time was determined to be 60 minutes and was conservatively used for the smaller pressure drop test volumes of the secondary lid and vent port pre shipment leakage rate tests The 60 minute hold time was described in Chapter 7 of the application However ES air pressure drop test procedure TR TP 002 specified a 20 minute hold time for the vent port pre shipment leakage rate test Based on equation B 14 in ANSI N14 5 American National Standard For Radioactive Materials Leakage Tests on Packages for Shipment the pressure drop test hold time is proportional to the pressure drop test total volume In its response to staff s RAI the applicant showed that the pressure drop test total of the test vent port volume and the test manifold volume was less than one third 20 minutes 60 minutes of the pressure drop test total of the primary containment seal test chamber volume and the tes
179. indicators in the margins of Revision 4 of the 8 120B Consolidated Safety Analysis Report have also been included in Revision 5 to indicate the cumulative changes that have been made in association with the request to amend the 8 120B CoC However the summary of the changes incorporated in Revision 4 of the 8 120B Consolidated Safety Analysis Report is not repeated below Summary of Changes 8 120B Consolidated SAR Revision 5 Section Page s Change Purpose Front matter xiv Added revision control sheet Editorial change 2 2 1 2 5 Replaced reference to Editorial change Appendix 1 specification Section 8 changed to References 3 2 2 3 2 Corrected O ring durometer Editorial correction for specification 1 bullet and consistency with drawing and replaced references to Section 8 references specifications 1 and 3 bullets Chapter 4 All Chapter 4 has been re typeset in Editorial change its entirety Formatting changes are not marked as revisions All other changes are described below 4 0 4 1 Deleted CNS from the model Editorial change designation 4 2 2 4 5 Corrected referenced equation Editorial correction numbers for Finn Dmax and Fen Dimax 4 2 3 4 6 Clarified basis for assumed weight Editorial correction used in containment calculation Revised heading text Editorial change 4 19 Corrected ME to divide Editorial correction 4 7 4 19 Revised 2 sentence to clarify th
180. ing 5 1 1 5 1 Changed to discuss shielding Components are credited for design features of the radial shielding in the revised thermal barrier impact limiter shielding evaluation skins and plate added to lower impact limiter Table 5 1 5 2 Changed package dose rate Updated based on results of results revised shielding evaluation 5 1 2 2 5 2 Expanded parenthetical discussion Clarify reason for point source of point source modeling location 5 1 2 3 5 3 Changed allowable source Updated based on results of strengths revised shielding evaluation 5 3 1 1 5 4 Revised 2 sentence to discuss Added for completeness and treatment of plate tolerances in consistency with revised safety shielding model analyses 5 4 1 5 8 Revised the discussion of Added for completeness and conservatism in the shielding consistency with revised safety model to include modeling analyses minimum steel plate thicknesses Table 5 5 5 11 Changed table to report results of Updated based on results of revised shielding evaluation revised shielding evaluation Figure 5 3 5 12 Changed figure to report results of Updated based on results of revised shielding evaluation revised shielding evaluation Figure 5 4 5 13 Changed figure to report results of Updated based on results of revised shielding evaluation revised shielding evaluation 6 2 Added blank page Editorial formatting for two sided printing ES NRC 13 010 May 23 2013 Page 4 of4 Su
181. ing the information described in paragraph 2 which is sought to be withheld and have been duly authorized to apply for its withholding 2 The information sought to be withheld is contained in the document listed in Table 1 This document has been appropriately designated as proprietary TABLE 1 Document No Document Title Rev Date CALC NU 391 8 120B Shielding Response 7 ES NRC 13 017 Proprietary Responses to Request for Additional August 9 Enclosure 2 Information 2013 3 I have personal knowledge of the criteria and procedures used by EnergySolutions in designating information as trade secret privileged or as confidential commercial or financial information 4 Pursuant to the provisions of paragraph b 4 of 10 CFR 2 390 the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure including the information as designated in paragraph 2 above should be withheld Page 1 of 4 ii The information sought to be withheld from public disclosure is included in the report documenting information which is owned and has been held in confidence by EnergySolutions The information is of a type customarily held in confidence by EnergySolutions and not customarily disclosed to the public EnergySolutions has a rational basis for determining the types of information customarily held in confidence by it and in that connection utilizes a system
182. ing the small activated item Note that it is not acceptable to average the activated metal together with the small 100 g item Shape Energy Payload Source Term Tias Fractions F Payload Item Type Discrete MeV or Finin Only Nuclide y sec y sec g Energy y sec y sectg y sec y secig 100g activated item 55 gal 4 44E 11 4 44E 09 Co 60 2 22E 12 8 16E 05 Co 60 0 2 Remaining metal 0511 2 21E 11 8 12E 04 0 8108 7 36E 11 2 70E 05 ini po 39E 1 ini 07 ini 09 Remaining metal General 0 8348 7 40E 11 2 72E 05 0 9 ini a 99 ini 183 a is 1 2 13E 1 8 63E 1 1 18E 07 6 90E 02 1 89E 08 4 30E 04 4 88E 03 4 91E 03 1 18E 07 3 19E 00 3 76E 02 3 19E 00 1 1 j 5 54E 07 6 31E 03 3 61E 05 3 61E 05 7 Remaining metal 0 8639 5 45E 09 2 00E 03 1 6747 3 97E 09 146E 03 1 83 2 06E 06 1 31E 01 7 08E 04 7 08E 04 155E 06 ____ Co 60 1 18E 07 1118 05 1 11E 05 Cs 137 9 88E 05 2 56E 08 3 83E 07 3 83E 07 Sum 3 27E 00 e e e e e e e e Cs 137 e This approach does not pass Since the discrete shored payload items have higher limits we can try to see if shoring the 100g item will pass Shape Energy Payload Source Term Limits Fractions F Payload Item Type Discrete MeV or Fmin 3 43E 01 3 43E 01 Remaining metal Genera Co 60 2 22E 12 8 16E 05 Co 60
183. iphar SLibert 12 16 2013 Authored By Christopher Libert Cask Operations Engineer Date Digitally signed by Steven Sisley Date 2013 12 16 11 01 16 08 00 Reviewed By Steven Sisley Cask Licensing Manager Date 12 2 Date Approved By Phillip H Thomas Director Cask Logistics Non Proprietary New 4 Proprietary a Title Change Ls Restricted Information Revision b Safeguards Information Rewrite Sensitivite Security Information gi Cancellation Effective Date January 1 2014 Electronic documents once printed are uncontrolled Refer to the Intraweb or the Document Control authority for the correct revision Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 Table of Contents Section Page I CPE vacuna TENUIS 3 1 1 A PP RERUM II E NT adu M M ena ese MEE 3 LD PRL ANT o ia 3 20 CASK DESCRIPTION cuca A id 3 JU REFERENCES soii olas quia aid 4 Z0 REQUIREMENTS sca cps cease 4 4 1 Tools Materials Equipment At Loading Site eese 4 4 2 Tools Materials Equipment At Unloading Site ees 5 4A Acceptance CA 9 30 DETAILED PROCEDURE cuida 10 5 1 Ladino Prop ue pai a bt NE EE E O beau dE 10 5 2 Unl ading Proced Te seniorers E au E R a 25 5 3 Removing the Cask from the Tra 33 5 4 Reinstalling the Cask on Trailer tn 34 5 5 Preparation of Empty Packaging for Transportation ococoncnnnnnnnonnnonnnnnnncnnncnoncn
184. ision to Certificate of Compliance CoC No 9168 for the Model No 8 120B package EnergySolutions submitted a notification dated August 14 2013 regarding the failure to observe CoC Conditions for the package vent port leak test hold time ADAMS Accession Number ML13247A179 In connection with this notification we need you to i provide complete calculations for the test vent port volume used in the pressure drop test ii clarify the volume combined test manifold and small residual volume inside the vent port or small residual volume inside the vent port that is less than 34 4 cm and iii also clarify if the value of 34 4 cm is correct Your notification states the following The vent port test volume the staff interprets this to be the total of the test vent port volume and test manifold volume is equal to the combined volume of the test manifold 10 cm plus a very small residual volume inside the vent port the staff interprets this to be the test vent port volume which is less than 34 4 cm However you do not specifically state the value of the small residual volume inside the vent port or show how it was calculated The calculation of the test vent port volume used in the pressure drop test is necessary to show that the test vent port volume in addition to the maximum test manifold volume 10 cm is less than one third of the total of the primary containment seal test chamber volume and the maximum test manifold volu
185. isions ER 01 004 Rev 1 Page 5 of 20 ii The packaging is capable of passing the prescribed tests in part 178 of this subchapter applicable to that standard and iii The competent authority of the country of manufacture provides reciprocal treatment for UN standard packagings manufactured in the U S Not applicable e Compatibility 1 Even though certain packagings are specified in this part it is nevertheless the responsibility of the person offering a hazardous material for transportation to ensure that such packagings are compatible with their lading This particularly applies to corrosivity permeability softening premature aging and embrittle ment 2 Packaging materials and contents must be such that there will be no significant chemical or galvanic reaction between the materials and contents of the pack age 3 Plastic packagings and receptacles i Plastic used in packagings and receptacles must be of a type compatible with the lading and may not be permeable to an extent that a hazardous condition is likely to occur during transportation handling or refilling ii Each plastic packaging or receptacle which is used for liquid hazardous mate rials must be capable of withstanding without failure the procedure specified in appendix B of this part Procedure for Testing Chemical Compatibility and Rate of Permeation in Plastic Packagings and Receptacles The procedure specified in appendix B of this part must
186. ity the very local additional crush that may occur in the impact limiter corners is not modeled because that location has relatively low dose rates that are always non controlling by a wide margin The revised shielding analysis is presented in Rev 7 of the NU 391 calculation package which is provided as part of this RAI response package The structural analyses do not show that there are any permanent impacts or deformations of the thermal barrier Thus the shielding analyses model the un deformed configuration of the thermal barrier as described in the SAR drawings Summary of SAR changes e Text is added to Section 5 3 1 1 which discusses the adjustments to the impact limiter dimensions to account for the effects of the NCT drop tests ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information e The dose rates presented in Table 5 1 are updated to reflect the revised shielding analysis e The payload source limit results presented in Table 5 5 and in Figures 5 3 and 5 4 are updated to reflect the revised shielding analysis e Table 1 and the examples in Chapter 7 are updated to reflect the revised shielding analysis 5 7 Provide additional information justifying that the MCNP calculations have converged properly The staff found from the MCNP input files that various computing time cut off ctme values were specified Describe the procedure used to ensure that the MCNP calculations hav
187. ive e Columbia South Carolina 29210 e 803 256 0450 March 29 2000 Dear Customer In May of 1999 Chem Nuclear Systems CNS asked the NRC for clarification to the condition in the CNS 8 120B Certificate of Compliance 9168 Revision 8 dealing with pre shipment leak tests We asked the NRC to clarify the LSA requirements referenced in Condition 8 The NRC gave a verbal interpretation stating that the LSA requirements were the specific activity limits listed in 10 CFR 71 4 LSA material definition Chem Nuclear Systems requested a Certificate of Compliance amendment to reflect this interpretation The NRC recently amended the Certificate of Compliance to clarify the condition and has also issued a Safety Evaluation Report to explain the changes Please be advised that the recent Certificate of Compliance amendment does not reflect the NRC s verbal interpretation from May of 1999 Condition 8 of the CNS 8 120B Certificate of Compliance Revision 9 now states Prior to each shipment the package must be leak tested in accordance with Section 8 2 2 2 of the application For contents that meet the definition of low specific activity material or surface contaminated objects in 10 CFR 71 4 and also meet the exemption standard for low specific activity and surface contaminated objects in 10 CFR 71 10 b 2 the pre shipment leak test is not required Therefore a pre shipment leak test shall be performed on the 8 120 Type B cask unless its contents
188. ividual tally segment results are less likely to be correct In other words the degree of precision in the dose rate results may be somewhat less than that suggested by the code output relative error levels The manual states that some things which result in a missed check such as small changes in FOM do not necessarily indicate an inaccurate result The manual does not give any specific quantitative criteria for addressing results that do not pass all 10 checks Our practice is that tallies that do not pass all 10 statistical checks performed by MCNP are examined to determine if they contain tally segment results peak dose rates that have any potential to affect the conclusions of the analysis Also the dose rate profiles on such surfaces are examined to see if they exhibit any unpredictable or unexpected behavior Results that do not pass all 10 checks are accepted if the dose rate profiles are predictably behaved and if the dose rate response would have to increase substantially 1 e by an amount much larger than the size of the confidence interval output by MCNP before they would govern any of the payload source limit results Evaluation of Rev 6 Results Examination of the NU 391 Rev 6 shielding analysis results submitted to NRC with the initial license amendment application shows that 43 of the over 500 tallies did not pass 1 3 of the 10 statistical checks performed by MCNP Only three of the cases missed 3 of the 10 checks
189. kely to be encountered during transportation must be capable of containing the hazard ous material in the liquid state This section contains specifications that must be met by the shipper D Closures 1 Closures on packagings shall be so designed and closed that under conditions including the effects of temperature and vibration normally incident to transpor tation 1 Except as provided in paragraph g of this section there is no identifiable re lease of hazardous materials to the environment from the opening to which the closure is applied and 11 The closure is secure and leakproof 2 Except as otherwise provided in this subchapter a closure including gaskets or other closure components if any used on a specification packaging must con form to all applicable requirements of the specification As discussed in the Chapter 4 of the SAR under the requirements of 10CFR 71 871 43 and 71 51 the package meets the requirements of this section g Venting Venting of packagings to reduce internal pressure which may develop by the evolution of gas from the contents is permitted only when 1 Transportation by aircraft is not involved 2 Except as otherwise provided in this subchapter the evolved gases are not poisonous likely to create a flammable mixture with air or be an asphyxiant un der normal conditions of transportation 2E 3 The packaging is designed so as to preclude an unintentional rele
190. kness which conservatively raises the lid and more importantly the point sources relative to the top of the lead The effects of the changes on the dose rate response are discussed in the response to 5 5 Summary of SAR changes e Text is added to Section 5 1 1 which discusses the presence of the cask cavity liner ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information e Text is added to Section 5 3 1 1 which discusses the application of tolerances as well as the modeling of the cask cavity liner and radial thermal barrier 5 3 Refer to proprietary enclosure Response to 5 3 Refer to proprietary Enclosure 2 5 4 Refer to proprietary enclosure Response to 5 4 Refer to proprietary Enclosure 2 5 5 Explain why the dose rate response i e mrem hr per photon s calculated by MCNP increases for some configurations Given the increase in shielding modeled all around the package for the calculations presented in the application the staff expects in every calculation that the peak dose rate response i e mrem hr per photon s calculated by MCNP would decrease from previous levels associated with Rev 19 of the CoC However the review of Tables 9 3 1 through 9 3 11 in CALC NU 391 Rev 6 and their comparison to the same tables in Rev 5 of the same document shows that in some cases this value increases for the lower energy gammas and 137CS Discuss why this happens If this is
191. l 8 120B C of C Number 9168 5 1232 Caution 5 1 2 3 3 Note 5 1 2 3 4 Note Caution 5 1 2 3 5 Warning 5 1 2 3 6 5 1 2 3 7 TR OP 035 Revision 25 Remove the security seals Properly dispose of removed seals Use of impact wrenches to remove cask lid bolts is limited to breaking initial torque on the bolt Once the bolt is free to rotate stop using impact wrench Final removal of lid bolts is to be done by hand Loosen and remove the twenty 20 2 inch hex head bolts from the primary cask lid using a star pattern Do not leave bolts in lid during removal Retain them for reinstallation Pneumatic or hydraulic torque wrenches non impacting may be used to install and remove the bolts Attach crane hook to primary lid lifting lugs using appropriate lifting hardware The cables used to lift the primary lid must have a true angle of not less than 45 with respect to the horizontal Care should be taken during handling operations to prevent damage to cask sealing surfaces Slowly raise the cask lid to clear cask and set the lid down on absorbent material or plastic sheeting if required Treat the underside of the lid the inside surfaces of cask and any bolts or seals removed as potentially radiologically contaminated Visually inspect the cask lid bolts for defects and obtain replacement bolts from EnergySolutions CMF for any lid bolts that show cracking or other visual defects Lubr
192. l surfaces of the liner before placing it in the cask Warning Treat all debris removed from the liner as potentially radiologically contaminated Page 18 of 41 Handling Procedure for Transport Cask Model 8 120B C of C Number 9168 5 1 3 3 3 Note 5 1 3 3 4 Caution 5 1 3 3 5 5 1 3 3 6 5 1 3 3 7 Note TR OP 035 Revision 25 Perform two independent physical verifications of the liner s closure system to ensure that it is properly closed and secured Record the compliance of this step in attachment 7 1 step 1 This requirement is waived for uniformly distributed resins filters and for solidified wastes with no dimension less than 1 cm Attach the crane hook to the cables or grapple ring on the liner and lift the liner Care should be taken during liner handling operations to prevent damage to cask or lid seal surfaces Lower the liner straight into cask Detach crane hook from the cables or grapple ring on the liner Ensure that liner lifting cables lay flat to allow proper installation of the cask lid Shore the liner if necessary to prevent movement during normal transport conditions 5 1 3 4 Replace primary cask lid Follow Steps 5 1 2 6 through 5 1 2 6 13 5 1 3 5 Replace secondary lid thermal shield and upper impact limiter Follow Steps 5 1 2 7 through 5 1 2 7 8 Procedure for Processing Liner through Secondary Lid 5 1 4 1 Remove upper impact limiter and secondary lid thermal
193. lace on the cask during shipment while allowing easy removal of the impact limiters for loading and unloading operations A general arrangement drawing of the package is included in Appendix 1 3 It shows the package dimensions as well as all materials of construction 1 2 1 1 Containment Vessel The containment vessel is defined as the inner steel shell of the cask body together with closure features comprised of the lower surface of the cask primary lid and 20 equally spaced 2 8 UN closure bolts and the lower surfaces of the cask secondary lid and the 12 equally spaced 2 8 UN closure bolts 1 2 1 2 Neutron Absorbers There are no materials used as neutron absorbers or moderators in the package 1 2 1 3 Package Weight Maximum gross weight for the package is 74 000 Ibs including a maximum payload weight of 14 150 lbs 1 2 1 4 Receptacles There are no receptacles on this package 1 2 1 5 Vent and Test Ports Pressure test ports with manual venting features exist between the twin o ring seals for both the primary and secondary lids This facilitates leak testing the package in accordance with ANSI N14 5 The vent port is provided with the same venting features for venting pressures within the containment cavity which may be generated during transport prior to lid removal Each port is sealed with an elastomer gasket Specification information for all seals and gaskets is contained in Chapter 4 1 2 1 6 Lifting Devices Lifting device
194. ld Contact EnergySolutions if damage is present The cask may not be used as a Type B package until the damage is assessed by EnergySolutions and repairs if required are made to achieve conformance with the drawings listed in the CoC 7 1 1 Impact Limiter Removal 7 1 1 1 Loosen and disconnect ratchet binders from upper impact limiter 7 1 1 2 Using suitable lifting equipment remove upper impact limiter assembly Care should be exercised to prevent damage to impact limiter during handling and storage 7 1 2 Secondary Lid Thermal Shield Removal 7 1 2 1 Remove the ball lock pins from each of the three retaining pins and remove the retaining pins from secondary lid lift lugs 7 1 2 2 Using suitable lifting equipment remove the secondary lid thermal shield Care should be taken to prevent damage to thermal shield during handling and storage 7 1 3 Determine if cask must be removed from trailer for loading purposes To remove cask from trailer 7 1 3 1 Disconnect cask to trailer tie down equipment 7 1 3 1 1 Inspect cask lifting ear bolts for defects Obtain replacement bolts as specified on the drawing listed in 5 a 3 of the CoC 7 1 8 120B Safety Analysis Report Consolidated Revision 7 7 1 6A November 2013 for any bolts that show cracking or other visual signs of distress 7 1 3 1 2 Inspect cask lifting ear threaded holes for defects Contact EnergySolutions if any bolt holes show signs of cracking or visual signs of dis
195. lectronic file containing change pages 7 3 through 7 7 for Consolidated Revision 4 of the 8 120B Type B Shipping Packaging SAR Filename 8 120B ConRev4 inadvertent omissions pdf dated 7 3 2013 2105 South Bascom Ave Suite 230 Campbell California 95008 408 558 3500 Fax 408 558 3518 www energysolutions com ES NRC 13 013 July 3 2013 Attachment Pg 1 of2 Requested Changes to CoC Amendment EnergySolutions requests the following changes to CoC No 9168 in association with the amendment request Reference 1 and provides the following bases for the requested changes Requested Change 1 Editorial Revise 5 b 1 ii to read as follows Radioactive material in the form of activated metals or metal oxides in solid form contained within secondary containers Basis The addition of the commas is requested for clarity Requested Change 2 Remove Condition 7 of CoC Revision 19 which requires two independent physical verifications of the secondary container s closure system Basis Step 7 1 9B requiring two independent physical verifications of the secondary container s closure system for payloads that have a potential for hot particle migration e g activated metals or radioactive sources has been added to Section 7 1 of Consolidated Revision 4 Therefore Condition 7 of CoC No 9168 Revision 19 is no longer required Requested Change 3 Include an exemption equivalent to Condition 8 of CoC Revision 18 for the pr
196. ll the air test port adapter test manifold into the lid air test port and tighten snuggly Do not over tighten If the adapter test manifold is tightened too much the o ring will be damaged and not properly sealed Ensure the valves on the test manifold are closed and the air regulator is set on zero prior to connecting the air hose to the manifold This is to ensure the pressure gauge is not over pressurized Ensure that the quick disconnects are properly connected The air used for the test should be dry and free of moisture Page 14 of 15 Air Pressure Drop Test for 8 120B Cask TR TP 002 Certificate of C onformance USA 9168 B U Revision 20 APPENDIX B PAGE 2 TROUBLESHOOTING GUIDE FOR LEAK TESTING THE 8 120B CASK 13 Allow pressure to equalize by applying the pressure for 20 to 30 minutes i e this soak time allows the temperature and pressure to equalize The manifold isolation valve should remain closed during the soak period After the soak time adjust the pressure to 18 1 0 psig Lightly tap the gauge face after the required test pressure has been obtained to alleviate any hysteresis effects on the gauge reading Start the leak test period of 15 minutes 14 If pressure dropped more than 0 1 psig after the leak test time period has started check the following a Soap bubble test the connection between the air test port adapter manifold and the cask lid b Soap bubble test all the connections on the air isolation par
197. ll the bolts to 500 50 ft Ibs lubricated using a star pattern It is recommended that the bolts be torqued a second time to 500 x 50 ft Ibs repeating the star pattern Check torque on all bolts at least once using a circular pattern to 500 50 ft Ibs Do not leave bolts in lid during removal Start torque at the same start bolt used in Step 5 1 4 4 7 Torque the vent port socket head cap screw to 20 2 ft lbs If the vent port socket head cap screw is removed the vent port seal shall be inspected if damaged contact EnergySolutions CMF Prior to installation the vent port seal shall be installed on the vent port socket head cap screw and a thin layer of anti seize should be applied to the vent port socket head cap screw threads Leak test the cask primary lid secondary lid and vent port o ring seals per Reference 3 3 After completing reference 3 3 ensure all 3 test port set screw plugs are in place Place security seals on secondary lid Ensure that all dirt clay debris is removed from the cask lids prior to installation of the cask impact limiters 5 1 4 5 Replace secondary lid thermal shield and upper impact limiter Follow Steps 5 1 2 7 through 5 1 2 7 8 Inspect the cask tie down cables for tightness Tighten if necessary Before the loaded cask leaves the shipper s facility the following shall be confirmed 5 1 6 1 Trailer placarding and cask labeling and marking meet D O T specifications
198. load items The limits in columns O and apply for y sec and y sec g respectively Sum the Fractions As a first try we attempt to qualify the payload as being two components the grout and soil Shape Enemy Payload Source Tem Umis Fractions E Type Discrete MeV or Fri General Cs 137 4 95E 13 2 43E 08 Cs 137 0 2 58E 12 2 56E 08 9 50E 01 9 50E 01 E 1 3 6 0 Cs 137 2 69E 13 6 93E 06 Cs 137 2 58E 12 2 56E 08 2 71E 02 2 71E 02 Sum 9 77E 01 Since the sum is greater than 0 95 the container is not an acceptable payload It is acceptable however to treat the payload as a single combined item with a y sec equal to the sum of the component grout and soil y sec values and a y sec g equal to that of the hottest component 1 e the grout 7 23 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Shape Energy Payload Item Discrete Only MeV or Nuclide Cs 137 y sectg y sectg y sectg 7 64E 13 2 43E 08 Cs 137 o 2 58E 12 el 2 56E 08 2 96E 01 9 50E 01 9 50E 01 Sum 9 50E 01 Energy 1 All grout Since the sum is less than 0 95 the container is an acceptable payload This example illustrates that there is no benefit from dividing a payload into multiple payload items if all of the items qualify under the y sec g limit If the payload is divided one of the y sec g fractions will be
199. lower impact limiter and change the maximum payload weight from 14 430 lbs to 14 150 Ibs to offset the additional weight of the plate and maintain at the same time the maximum package weight as in previous revisions of the CoC Condition No 5 a 3 has been revised to include new revisions for Energy Solutions Drawing Nos C 110 E 0007 sheets 1 6 and DWG CSK 12CV01 EG 0001 Condition No 5 b 1 ii has been edited to add commas for clarity purposes Condition No 5 b 2 iii has been revised to show a maximum payload weight of 14 430 lbs when including shoring and secondary containers Condition No 7 of the previous revision of the certificate which required two independent physical verifications of the secondary container s closure system has been deleted The requirements of Condition No 7 have now been added to Chapter 7 of the application as part of step 7 1 10 of the loading operating procedure Since Condition No 6 requires compliance with Chapter 7 of the application Condition No 7 is no longer necessary in the CoC Condition No 11 of the previous revision of the certificate has been deleted Condition No 11 stated that a pre shipment leak test was required before each shipment of Type B quantities Such a wording could lead to a false interpretation of regulations for contents such as Low Specific Activity LSA or Surface Contaminated Object SCO materials as being exempted from a pre shipment leak test Section 7 1 14 of Ch
200. lusions of the analysis Based on the above table from the MCNP User s Manual results with relative error levels between 0 1 and 0 2 may be acceptable if they would have to increase by a factor of two or more before they would affect any payload source limit results Results with relative error levels between 0 2 and 0 5 may be acceptable if they would have to increase by several orders of magnitude before they would affect any payload source limit results Examination of the NU 391 Rev 6 shielding analysis results submitted to NRC with the initial license amendment application shows that 17 individual tally segment results out of a total of over 10 000 had relative error levels over 0 1 These results occurred over eight tally surfaces with three of the eight surfaces having four tally segments with relative error levels over 0 1 All but one of these 17 individual tally segment results had relative error levels between 0 10 and 0 14 All of those 16 results would have to increase by a factor of 2 or more before they would affect any of the payload source limit results The one remaining result had a relative error level of almost 0 24 but it would have to increase by a factor of over 1000 before it would affect any of the payload source limit results ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information Based on the above it was concluded that the small number of results with relative error levels
201. material must be compatible with the package contents and suitably positioned to contact the liquid in the event of leakage Or i Have a containment system composed of primary inner and secondary outer containment components designed to assure retention of the liquid contents within the secondary outer componentin the event that the primary inner component leaks 1 The liner may be partially filled to accommodate this requirement However this is the responsibility of the shipper 2 Section 2 7 1 of the SAR evaluates the performance of the packaging when it is subjected to the free drop test Impact energies resulting from the penetration test at 1 7 meters will have no significant effect on the packaging The impact limiter fully protects both ends of the cask leaving only the central body exposed The cask body is manufactured from 2 thick steel plate and backed with 1 7 8 of lead The ends are comprised of steel 5 thick No valves valve covers or fragile protrusions exist 3 The cask will serve as the secondary outer containment while a liner will serve as the primary inner containment The cask is designed to assure retention of the liquid contents within the cask in the event that the liner leaks 1 Each package designed for gases other than tritium not exceeding 40 TBq 1000Ci or noble gases not exceeding the A2 value appropriate for the noble gas will be able to prevent loss or dispersal of contents when the package
202. me 20 min 60 min 103 2 cm 10 cm 37 3 cm for the 20 minute hold time to be adequate The staff calculated that the test vent port volume must be less than 37 3 cm 10 cm 27 3 cm for the 20 minute hold time to be adequate We need this information to determine compliance with 10 CFR 71 51 a 1 and 2 and request that you provide this information by September 30 2013 We do recognize that this calculation applies to the old lids not to the new lids that will be used for all future shipments but it is our intent to explain staff s position on leak testing in the Safety Evaluation Report pertaining to the amendment request currently under review RESPONSE Figure 1 shows the test manifold configuration used for the assembly verification leak test of the 8 120B vent port evaluated in Section 4 4 of the July 2012 SAR Addendum The vent port test flange is affixed to the lid and the test manifold partially shown in Figure 1 is screwed into the test flange The volume of the test manifold Vm is required to be less than 10 cm The total vent port test volume equals Vy V V2 V3 where V is the small volume inside the 23 8 threaded hole of the test port flange between the bottom end of the test manifold and the top plane of the lid V2 is the volume of the 21 25 x 3 8 deep countersunk hole in the lid ES NRC 13 019 Enclosure 1 Docket No 71 9168 Response to Request for Additional Information
203. method was reviewed in detail when the staff issued Revision 19 of the CoC ADAMS Accession No ML12236A198 The staff s review focused on the changes to the application and used the guidance in Section 5 of NUREG 1609 Standard Review Plan for Transportation Packages for Radioactive Material 5 1 Description of Shielding Design 5 1 1 Design Features The shielding design features a packaging body with a steel base steel primary and secondary lids and a steel lead steel wall with dimensions specified in Drawing No C 110 E 0007 Revision 19 In the shielding analysis that supported Revision 19 of the CoC the applicant relied on the lead thickness and the steel components of the packaging i e the radial shells base plates and lids In this amendment request the applicant also credits the 12 gauge steel liner inside the cavity the 12 gauge impact limiter steel casing the 3 16 thick radial thermal barrier and has included a 1 2 steel base plate in the hole of the bottom impact limiter This base plate is a new component The applicant had also previously modeled nominal dimensions for the steel cask components The staff found this acceptable in Revision 19 of the CoC because the applicant had not modeled the 12 gauge steel liner inside the cavity Since the applicant is now crediting this component the shielding model was changed to account for these design tolerances by reducing the component thicknesses by the tolerance a
204. min Remove the threaded cap covering the vent port Connect test manifold to the vent port Pressurize the seal and head of the vent Vent Port 15 min port cap screw for the minimum hold time A drop in pressure of greater than the minimum detectable amount shall be cause for test failure 8 3 3 COMPONENT AND MATERIAL TESTS Cask seals O rings are inspected each time the cask lids or vent port cap screw are removed Inspection and replacement of the seal is discussed in Section 8 3 8 0 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 New seals are lightly coated with a lightweight lubricant such as Parker Super O Lube or equivalent prior to installation The lubricant will minimize deterioration or cracking of the elastomer during usage and tearing if removal from the dovetail groove is necessary for inspection Coating the exposed surfaces of installed lid seals with the lightweight lubricant immediately prior to closing the lid can help to minimize deterioration or cracking of the seal during use Excess lubricant should be wiped off before closing the lid Painted surfaces identification markings and match marks used for closure orientation shall be visually inspected to ensure that painted surfaces are in good condition identification markings are legible and that match marks used for closure orientation remain legible and are easy to identify Visible cask external and cavity welds shall be
205. miters in thermal analysis ES NRC 13 026 November 13 2013 Page 3 of 9 Consolidated Summary of Changes 8 120B Consolidated SAR Revisions 4 through 7 Added discussion of potential Added for completeness and damage to impact limiter cover consistency with existing safety plates resulting from the HAC analyses puncture test and the damaged configuration considered in the HAC fire evaluation 3 38 Added blank page WwW nN Editorial formatting for two sided printing Components are credited for shielding in the revised shielding evaluation Y a E Added for completeness and consistency with revised safety analyses 1 oc 3 4 Salad 5 Changed to discuss shielding design features of the radial thermal barrier impact limiter skins and plate added to lower impact limiter Table 5 1 5 Changed package dose rate Updated based on results of results revised shielding evaluation 322 5 Expanded parenthetical discussion Clarify reason for point source of point source modeling location 912 3 Changed allowable source Updated based on results of strengths revised shielding evaluation AC Led 5 4 Revised 2 sentence to discuss Added for completeness and treatment of plate tolerances in consistency with revised safety shielding model analyses 5 4 1 Revised the discussion of conservatism in the shielding model
206. mmary of Changes 8 120B Consolidated SAR Revision 4 Section Change Purpose Table 7 1 Updated based on results of revised shielding evaluation Changed table to report results of revised shielding evaluation Attachment 1 Revised example data Updated based on results of Example 1 revised shielding evaluation Steps 5 7 Attachment 1 Revised example data Updated based on results of Example 2 revised shielding evaluation Steps 5 7 Attachment 1 Revised example data Updated based on results of Example 3 revised shielding evaluation Steps 5 7 Attachment 1 7 21 Revised example data Updated based on results of Example 4 revised shielding evaluation Steps 5 7 Attachment 1 7 22 and Example 5 7 23 Step 3 Attachment 1 7 23 and Example 5 7 24 Steps 5 7 Revised selected example More pertinent example chosen parameters based on revised shielding analysis results Revised example data Updated based on results of revised shielding evaluation Added blank page Editorial formatting for two sided printing July 2012 All Deleted No longer applicable SAR Addendum AFFIDAVIT PURSUANT TO 10 CFR 2 390 State of California SS County of Santa Clara I Steven E Sisley depose and say as follows 1 I am Licensing Manager of EnergySolutions Products and Technology Group and have been delegate
207. mount specified in the cask drawings The staff found crediting the inner liner acceptable because the applicant accounted for all fabrication tolerances within their model The staff requested information clarifying the drawing with respect to the radial thermal barrier From Drawing No C 110 E 0007 the barrier appeared to be discontinuous and no 4 discontinuities were accounted for in the shielding model In response to staff inquiries the applicant explained that there are discontinuities where there are the lift lug pads and the tie down pads Based on these other features providing at least an equivalent amount of shielding as the thermal barrier the staff found the shielding model acceptable The staff reviewed the package Drawing No C 110 E 0007 and verified that the newly credited features were included The staff found that the figures certificate drawing and discussion describing the shielding features are sufficiently detailed to support an in depth technical evaluation 5 1 2 Summary Table of Maximum Radiation Levels The package transports a wide variety of contents and therefore determining the maximum dose rate of all possible contents is not practical The applicant has instead back calculated from the allowable dose rate limit the amount of radioactive contents that could be shipped The summary table of maximum radiation levels includes sample calculations for a Cobalt 60 Co 60 point source and a Cesium 137 Cs 137
208. mpliance of this step in attachment 7 1 step 1 This requirement is waived for uniformly distributed resins filters and for solidified wastes with no dimension less than 1 cm The periodic leak test of the primary lid secondary lid and vent port plug o ring seals has been performed in the prior 12 month period For a shipment of powdered radioactive materials 1 e powdered solids confirm that the most recent periodic leak test demonstrated leaktight status Complete the USER CHECK OFF SHEET Attachment 7 1 or equivalent sheet and send a copy with the shipment Page 24 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 5 2 Unloading Procedure Note Verify compliance to Step 4 3 8 Note If it is necessary to remove the cask from the trailer refer to Section 5 3 of this procedure Warning All personnel handling a filled liner or filled drums shall observe established site radiation protection procedures 5 2 1 Move the unopened package to an appropriate level unloading area and position the unloading crane at an optimum distance to facilitate offloading the cask and minimizing operator exposure 5 2 2 Remove upper impact limiter and secondary lid thermal shield Note Position cask and trailer on a level surface visual determination to facilitate impact limiter and lid removal 5 2 2 1 MAR 5 2 2 3 5 2 2 4 5 225 Note 5 2 2 6 5 2 2 7 5 2 2
209. must conform to the following provisions and limitations Not applicable the package is classified as a bulk package ER 01 004 Rev 1 Page 8 of 20 173 29 Empty packagings This section contains specifications that must be met by the shipper 173 30 Loading and unloading of transport vehicles A person who loads or unloads hazardous materials into or from a transport vehicle or vessel shall comply with the applicable loading and unloading requirements of parts 174 175 176 and 177 of this subchapter This section contains specifications that must be met by the shipper 173 31 Use of tank cars Not applicable 173 32 Requirements for the use of portable tanks Not applicable 173 33 Hazardous materials in cargo tank motor vehicles Not applicable 173 34 Qualification maintenance and use of cylinders i Not applicable 173 35 Hazardous materials in intermediate bulk containers Not applicable 173 40 General packaging requirements for poisonous materials required to be packaged in cylinders Not applicable 173 410 General design requirements In addition to the requirements of subparts A and B of this part each package used for the shipment of Class 7 radioactive materials must be designed so that a The package can be easily handled and properly secured in or on a conveyance during transport The cask is equipped with lifting attachments for handling Cask loading and unloading procedures are specified in
210. n the applicant updated the tables in Attachment 1 to Chapter 7 to increase all gamma contents by approximately 30 5 3 Shielding Model The staff reviewed the structural and thermal chapters of the application and found that conditions consistent with NCT and HAC were appropriately represented in the shielding model The staff requested additional information about the consideration of NCT tests on the impact limiter dimensions In response to this inquiry the applicant updated their model to include the impact limiter deformation as a result of NCT and updated all content limits 5 3 1 Source and Shielding Configuration The applicant evaluated the package using different models for NCT and HAC The components of the package are modeled at the minimum dimensions specified in the certificate drawing Credit is also taken for the 12 gauge steel cavity liner radial thermal barrier and presence of the impact limiters though the impact limiter foam material is still neglected For the top and bottom impact limiters the model includes a steel plate that covers the voided central area of the impact limiters The applicant uses minimum dimensions for the newly credited components For HAC models the impact limiter including the shield plate is neglected The HAC model was also modified to move the source up into the chamfer region of the lid to account for additional streaming The applicant did not model this chamfer region in its NCT models In
211. n marks indicate changes since Consolidated Revision 3 xiv 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 10 GENERAL INFORMATION 11 INTRODUCTION This Safety Analysis Report describes a reusable shipping package designed to protect radioactive material from both normal conditions of transport and hypothetical accident conditions The package is designated the Model 8 120B package 12 PACKAGE DESCRIPTION 1 2 1 PACKAGING The package consists of a steel and lead cylindrical shipping cask with a pair of cylindrical foam filled impact limiters installed on each end The package configuration is shown in Figure 1 1 The internal cavity dimensions are 61 Z inches in diameter and 74 7 inches high The cylindrical cask body is comprised of a 1 inch thick external steel shell and a 3 inch internal steel shell The annular space between the shells is filled with 3 35 inch thick lead The base of the cask consists of two 3 4 inch thick flat circular steel plates The cask lid consists of two 3 inch thick flat circular steel plates The lid is fastened to the cask body with twenty 2 8 UN bolts There is a secondary lid in the middle of the primary lid This secondary lid is attached to the primary lid with twelve 2 8 UN bolts A thermal shield protects the secondary lid The thermal shield consists of two polished stainless steel plates that are separated by a thin air gap with stand offs which provide an additional air
212. nal Pressure and Immersion Loading T M C 2 110 Figure 2 27 LS DYNA Model of the 8 120B Cask amp Rigid Pad ssessse 2 111 Figure 2 28 The finite element model for the drop tests ooooonoccnnoncccnonccononacononanonnnanonnan ns 2 112 Figure 2 29 End Drop The cask axis parallel to the drop direction 2 113 Figure 2 30 Side Drop The cask axis perpendicular to the drop direction 2 114 Figure 2 31 Corner Drop The C G of the cask directly over the impact point 2 115 Figure 2 32 Time History Result 1 Ft End Drop Cold Condition Resultant Force Plot 2 116 Figure 2 33 Time History Result 1 Ft End Drop Cold Condition Energy Plots 2 117 Figure 2 34 Finite Element Model of the 8 120B Cask Identifying the Cask Components with IVETE IG eese Mm RT EMO 2 118 Figure 2 35 The finite element grid of the lid seal plate bolts and the cask 2 119 Figure 2 36 The finite element grid of the cask body without the lead 2 120 Figure 2 37 Load Distribution on the Model During End Drop sse 2 121 Figure 2 38 Stress Intensity Plot 30 ft End Drop Hot Condition 2 122 Figure 2 39 Stress Intensity Plot 30 ft End Drop Cold Condition Max Heat Load 2 123 Figure
213. nance that may arise under normal conditions of transport without any deterioration in the effectiveness of the closing devices on the various recepta cles or in the integrity of the package as a whole and without loosening or uninten tionally releasing the nuts bolts or other securing devices even after repeated use see 173 24 173 24a and 173 24b The package is similar to many other proven casks with many years of operational use in a transport environment This experience demonstrates that vibrations normally incident to transport will have no effect upon the package ER 01 002 Rev 1 Page 10 of 15 g The materials of construction of the packaging and any components or structure will be physically and chemically compatible with each other and with the package con tents The behavior of the packaging and the package contents under irradiation will be taken into account The package is constructed of structural steel and the exterior is primed and painted As discussed in 2 4 1 of the SAR there will be no reactions between the package and contents or between the package components h All valves through which the package contents could escape will be protected against unauthorized operation Not applicable There are no valves in the package i For transport by air 1 The temperature of the accessible surfaces of the package will not exceed 50 C 122 F at an ambient temperature of 38 C 100 F with no account
214. nges incorporated in Revisions 4 and 5 of the 8 120B Consolidated Safety Analysis Report are not repeated below Summary of Changes 8 120B Consolidated SAR Revision 6 Section Page s Change Purpose Table 4 2 4 22 Corrected to refer to 8 120B Editorial correction Caption Table 4 2 4 22 Deleted note regarding exemption All shipments made in the Footnote from pre shipment leak testing 8 120B package now require requirement for LSA material and pre shipment leak testing SCO shipments 5 1 5 1 Revised referenced procedure step Editorial correction in the last sentence of first paragraph 5 7 5 18 Corrected revision number of Editorial correction Reference 5 7 2 7 1 10 7 3 7 4 Change step number from 7 1 9B Revised to avoid confusion through to 7 1 10 and renumbered all since A steps are associated 7 1 13 subsequent steps accordingly with loading through the cask secondary lid 7 1 10 7 3 Revised second sentence and Clarify conditions under which associated footnote the requirement is waived and the basis for waiving the requirement 7 1 14 7 4 7 5 Change step number from 7 1 12A Revised to avoid confusion through to 7 1 14 and renumbered all since A steps are associated 7 1 21 5 subsequent steps accordingly with loading through the cask secondary lid 7 1 14 7 4 Revised step and deleted note All shipments made in the regarding exemption from pre shipm
215. ngs included in Editorial for clarity SAR Added blank page Editorial formatting for two sided printing Purposes of drawing changes are as follows 1 Plate added for shielding 2 Editorial correction for consistency with safety analyses and 3 Removed dimensions not used in Safety Analyses 12 13 1 3 Changed maximum payload Reduced to offset additional weight weight Revised Dwg No C 110 E 0007 1 Added inch thick plate Item 56 to cover central region of the Lower Impact Limiter 2 Revised thickness of impact limiter skin and 3 Removed non critical dimensions on the impact limiter lift lug Items 45A and 46 iv 1 1 weight of plate added to lower 1 2 1 5 1 3 Deleted comma from section Editorial correction heading 1 7 2 Revised Impact Limiter section to discuss plates covering the central regions of the upper and lower impact limiters Revised for clarity ES NRC 13 026 November 13 2013 Page 2 of 9 Consolidated Summary of Changes 8 120B Consolidated SAR Revisions 4 through 7 Changed section for the following Purposes of revisions to section 2 4 1 Changed the word are as follows conservative to nominal in 1 Weights are based on a first sentence nominal dimensions Figure 2 1 Section plate added to lower impact 3 Simplify we
216. nnnos 36 60 RECORDS AND REPORTS comisaria 40 TO ATTACHMENTS aa 40 7 1 User Check Off I m 41 Page 2 of 41 Handling Procedure for Transport Cask TR OP 035 2 0 Model 8 120B C of C Number 9168 Revision 25 10 SCOPE 1 1 Purpose This procedure establishes instructions for routine handling loading and unloading of EnergySolutions Cask Model 8 120B 1 2 Applicability This procedure applies to all EnergySolutions Model 8 120B Casks operated under Certificate of Compliance Number 9168 Revision 20 see Reference 3 8 CASK DESCRIPTION The packaging is a carbon steel encased lead shielded cask with a pair of cylindrical foam filled impact limiter installed on the cask ends The cask is a right circular cylinder with a nominal internal cavity size of 61 13 16 inch by 74 7 8 inch high The walls of the cask contain a minimum lead thickness of 3 35 inches encased between a 0 75 inch thick inner steel shell and a 1 1 2 inch thick outer steel shell The exposed sides of the package between the impact limiters are provided with a thermal barrier consisting of a 5 32 inch diameter wire wrap on 12 inch centers and covered with 3 16 inch thick steel jacket The secondary lid is covered with a separate removable thermal shield The bottom weldment is made of two 3 1 4 inch thick carbon steel plates The primary lid is sealed with a double o rings and 20 equally spaced 2 inch diameter bolts The 29 inch diameter c
217. nse Co 60 and higher gamma energies that have the highest gamma dose rates at the package s axial mid plane were not affected Since this is bounding the staff found this acceptable 5 4 5 Application of Shielding Method Results The results of the shielding method are captured in Table 5 5 and Table 1 of Attachment 1 to Chapter 7 in the application Both Chapter 5 and Chapter 7 Attachment 1 describe how the results are to be applied by the package user to determine acceptability of the contents presented for a shipment This method has not changed since the last revision of the CoC and therefore the staff found it acceptable 5 5 Evaluation Findings Based on its review of the statements and representations in the application and independent confirmatory calculations the staff found reasonable assurance that the shielding design has been adequately described and evaluated and that the package meets the external radiation requirements of 10 CFR Part 71 6 0 CRITICALITY EVALUATION Not applicable 7 0 PACKAGE OPERATIONS The staff also reviewed the package operations to ensure that operations relevant to shielding are adequate These include the use of shoring to maintain the contents position within the package performance of dose rate surveys to ensure the package meets the regulatory dose rate limits which these radiation surveys are sufficient to account for non uniformity of the source distribution and that appropriate limits are
218. nsportation to ensure that such packagings are compatible with their lading This particularly applies to corrosivity permeability softening premature aging and embrittle ment 2 Packaging materials and contents must be such that there will be no significant chemical or galvanic reaction between the materials and contents of the pack age 3 Plastic packagings and receptacles i Plastic used in packagings and receptacles must be of a type compatible with the lading and may not be permeable to an extent that a hazardous condition is likely to occur during transportation handling or refilling ii Each plastic packaging or receptacle which is used for liquid hazardous mate rials must be capable of withstanding without failure the procedure specified in appendix B of this part Procedure for Testing Chemical Compatibility and Rate of Permeation in Plastic Packagings and Receptacles The procedure specified in appendix B of this part must be performed on each plastic pack aging or receptacle used for Packing Group materials The maximum rate of permeation of hazardous lading through or into the plastic packaging or re ceptacles may not exceed 0 5 percent for materials meeting the definition of a Division 6 1 material according to 173 132 and 2 0 percent for other hazard ous materials when subjected to a temperature no lower than A 18 C 64 F for 180 days in accordance with Test Method 1 in appendix B of this part B 50
219. ntainer s 12 22 Maximum quantity of material per package Type B quantity of radioactive material not to exceed 3000A gt 200 thermal watts and 14 430 pounds including weight of the contents secondary container s and shoring The contents may include fissile materials provided at least one of the paragraphs a through f of 10 CFR 71 15 is met Materials producing more than 1 x 10 neutrons sec in the total contents other than fissile materials as allowed in the preceding sentence are not authorized The activity of beta and gamma emitting radionuclides shall not exceed the limit determined per the procedure in Chapter 7 Attachment 1 Powdered or dispersible solid radioactive materials must have a mass of at least 60 grams or a specific activity of 50 A g or less 1 2 2 3 Loading Restrictions Contents shall be packaged in secondary containers Except for close fitting contents shoring must be placed between the secondary containers or activated components and the cask cavity to prevent movement during accident conditions of transport Explosives non radioactive pyrophorics and corrosives pH less than 2 or greater than 12 5 are prohibited Pyrophoric radionuclides may be present only in residual amounts less than 1 weight percent Materials that may auto ignite or change phase 1 e change from solid to liquid or gas at temperatures less than 350 F not including water shall not be included in the contents In addition a
220. ntensities in 8 120B Cask under 30 ft Side Drop Cold Condition 2 80 Table 2 22 Stress Intensities in 8 120B Cask under 30 ft Corner Drop Hot Condition 2 81 viii 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Table 2 23 Stress Intensities in 8 120B Cask under 30 ft Corner Drop Cold Condition 2 82 Table 2 24 Maximum Impact Limiter Attachment Force during Various HAC Drop Tests 2 83 Table 2 25 Maximum Stress Intensities in 8 120B Cask HAC Fire eese 2 84 Table 3 1 Summary of Maximum NCT Temperatures o oococcoocccnonnncnoncnononcnnnnncconnnccnnnnccnnnnccnnnos 3 12 Table 3 2 Summary of Maximum Hypothetical Fire Temperatures eesssss 3 13 Table 3 3 Summary of Maximum Pressures during NCT and HAC Fire Test 3 14 Table 3 4 Temperature Independent Metal Thermal Properties esses 3 14 Table 3 5 Temperature Dependent Metal Thermal Properties eese 3 15 Table 3 6 Temperature Dependent Air Thermal Properties eee 3 16 Table 4 1 Bolt and Cap Screw Torque Requirements ooooonoocccnoncccnoncnonnoncnononccnonnccnnn cocoa ncnonnnoss 4 2 Table 4 2 Leakage Tests of the 8 120B Package io he atri ued aca gees ete Geese 4 22 Table 5 1 Summary of Maximum Dose Rates mrem hr seen 5 2 Table 5 2 Gamma Energy and Abundance
221. o the Thermal Evaluation Section 3 0 of this report 8 2 8 MISCELLANEOUS TESTS No miscellaneous testing will be performed on the 8 120B packaging 8 5 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 83 MAINTENANCE PROGRAM EnergySolutions operates an ongoing preventative maintenance program for all shipping packages The 8 120B package will be subjected to routine and periodic inspection and tests as outlined in this section and the approved procedure based on these requirements Defective items are replaced or remedied including testing as appropriate Examples of inspections performed prior to each use of the cask include e Cask Seal Areas O rings are inspected for any cracks tears cuts or discontinuities that may prevent the O ring from sealing properly O ring seal seating surfaces are inspected to ensure they are free of scratches gouges nicks cracks etc that may prevent the O ring from sealing properly Defective items are replaced or remedied as appropriate and tested in accordance with Section 8 3 2 e Cask bolts bolt holes and washers are inspected for damaged threads severe rusting or corrosion pitting Defective items are replaced or remedied as appropriate e Lift Lugs and visible lift lug welds are inspected to verify that no deformation of the lift lug is evident and that no obvious defects are visible Defective items are replaced or remedied as appropriate and tested in accordance
222. o the o rings Ensure that the o ring sealing surfaces are clean Acetone or an equivalent cleaning solution works very well to clean the o ring sealing surfaces Inspect the o rings and ensure they are in good condition and properly installed Gently clean the o rings and clear any unwanted debris before re lubricating The o rings should be lubricated with a small amount of o ring lubricant or petroleum jelly Parker O ring Lube works very well A thin coat of o ring lubricant or petroleum jelly may be applied to the o ring sealing surface Ensure the air test port and the connection line to the air test annulus are free all foreign materials A small wire should be pushed through the test port line This will ensure that the line does not have any internal blockage that could restrict airflow to the annulus Ensure the air test port and the air test port o ring sealing surface is clean and free of any foreign materials Foreign materials and debris may prevent the o ring on the leak test adapter test manifold from properly sealing The cask lids must be torqued in accordance with the cask handling procedure This torquing sequence ensures the lids are evenly seated and tightened Inspect the o ring that is on the air test port adapter test manifold to ensure it is in good condition and will properly seal The o ring should be lubricated with a small amount of o ring lubricant or petroleum jelly Parker O ring Lube works very well Insta
223. oad configuration on the package center of gravity is not significant and does not require separate evaluations of payload configurations Changed discussion to include the plate added to the lower impact limiter 2 6 10 2 28 Changed to include thicknesses of Address impact of penetration the weather cover on the impact test on impact limiter cover limiter and the plate added to the plates lower impact limiter 2 7 8 2 57 Add discussion of damage to Added for completeness and impact limiter covers resulting consistency with existing safety from HAC puncture test analyses Figure 2 1 2 85 Changed graphic to show cover More accurately depict design plate on lower impact limiter configuration Figure 2 5 Added figure caption Editorial figure caption missing in previous SAR revision Added for completeness and consistency with existing safety analyses ES NRC 13 010 May 23 2013 Page 3 of4 Summary of Changes 8 120B Consolidated SAR Revision 4 Section Page s Change Purpose 3 4 3 6 Added discussion of potential Added for completeness and damage to impact limiter cover consistency with existing safety plates resulting from the HAC analyses puncture test and the damaged configuration considered in the HAC fire evaluation 3 38 Added blank page Editorial formatting for two sided print
224. of the cask Note Shore drums if necessary to limit movement during normal transport conditions 5 1 2 5 5 Repeat Steps 5 1 2 5 1 through 5 1 2 5 4 to load other pallet into the cask 5 1 2 6 Replace the primary lid Caution Care should be taken during handling operations to prevent damage to cask sealing surfaces Note Confirm that the bolts on the secondary lid are torqued to a lubricated value of 500 50 ft Ibs refer to Steps 5 1 4 4 6 through 5 1 4 4 8 for torquing bolts before the cask leaves the facility Bolt torque does not have to be checked on bolts with security seals Page 14 of 41 Handling Procedure for Transport Cask Model 8 120B C of C Number 9168 5 1 2 6 1 Note 5 1 2 6 2 5 1 2 6 3 Warning 5 1 2 6 4 Caution 5 1 2 6 5 Note TR OP 035 Revision 25 Attach the lifting sling to the three 3 lifting lugs on the primary lid The cables used to lift the primary lid must have a true angle of not less than 45 with respect to the horizontal Attach the crane hook to the lifting sling The primary lid O Ring seals shall be visually inspected for serviceability ensuring that they are in the proper position and free of cracks tears cuts or discontinuities which may prevent them from sealing properly The seal seating surface shall be visually inspected to ensure that they are free of damage debris gravel or any foreign matter which might damage the seals or prevent the
225. ogically contaminated Remove security seals Properly dispose of removed seals Use of impact wrenches to remove cask lid bolts is limited to breaking initial torque on the bolt Once the bolt is free to rotate stop using impact wrench Final removal of lid bolts is to be done by hand Loosen and remove the twenty 20 2 inch hex head bolts from the primary cask lid using a star pattern Do not leave bolts in lid during removal Retain them for reinstallation Pneumatic or hydraulic torque wrenches non impacting may be used to remove the bolts Attach crane hook to lifting lugs on primary cask lid using appropriate lifting hardware The cables used to lift the primary lid must have a true angle not less than 45 with respect to the horizontal Use care during handling operations to prevent damage to cask sealing surfaces Slowly raise the cask lid to clear cask and set the lid down on absorbent material or plastic sheeting if required Warning Treat the underside of the lid the inside surfaces of cask and any bolts or seals removed as potentially radiologically contaminated Page 26 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 5 2 4 5 2 5 5 2 6 Note 5 2 7 5 2 3 5 Visually inspect the cask lid bolts for defects and obtain replacement bolts from EnergySolutions CMF for any lid bolts that show cracking or other visual defects Lubricate bolt thread
226. onment from the opening to which the closure is applied and ii The closure is secure and leakproof 2 Except as otherwise provided in this subchapter a closure including gaskets or other closure components if any used on a specification packaging must con form to all applicable requirements of the specification As discussed in the Chapter 4 of the SAR under the requirements of 10CFR 71 871 43 and 71 51 the package meets the requirements of this section g Venting Venting of packagings to reduce internal pressure which may develop by the evolution of gas from the contents is permitted only when 1 Transportation by aircraft is not involved 2 Except as otherwise provided in this subchapter the evolved gases are not poisonous likely to create a flammable mixture with air or be an asphyxiant un der normal conditions of transportation 3 The packaging is designed so as to preclude an unintentional release of hazard ous materials from the receptacle and 4 For shipments in bulk packagings venting is authorized for the specific hazard ous material by a special provision in the 172 101 Table or by the applicable bulk packaging specification in part 178 of this subchapter Not applicable h Outage and filling limits 1 General When filling packagings and receptacles for liquids sufficient ullage outage must be left to ensure that neither leakage nor permanent distortion of the packaging or receptacle will o
227. onsolidated Revision 7 November 2013 9 24 Leakage Testsaiodue iD RR TOI ER id 8 4 8 45 Component and Material Tests eot edes ona Ein leo io Pre Polo UIN 8 4 8 56 Shielding Tests osos aid e ae E S RU NIS E HSNE SE AUR TE eve Peau Vea ede vo ute 8 5 Bg VXhetnil Testa rita io tito 8 5 8 2 8 Miscellaneous Tests a dede e ERI LR ERA DU ED MU HUE Diet i Ee ved ede ida 8 5 53 Mumtenance PIOSEdITI S cda ri Qe ki eee n Ida 8 6 S Structural and Pressure T8868 lil oae ED acie eiae an a ad Rer ae ipe adus 8 6 5 9 4 E O 8 6 8 3 3 Component and Material DeStsi odo ee pre tiet eductus ton out seca sume ed 8 9 8 3 4 hermal Leste xe nt o odio cla 8 10 8 3 3 JMiscellaneous TOS cal Piet oed erede abies are An d pae od 8 10 A LE A A au dc I ahi Cd um dv addet E vds 8 11 vii 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 LIST OF TABLES TABLE PAGE Table 2 1 Summary of Load Combinations for Normal and Accident Condition Loading 2 60 Table 2 2 Allowable Stresses inni ere Et bear o osa gia LH he ica 2 61 Table 2 3 Stress Component Definition ecce linia ie De naa e tuo daban de 2 62 Table 2 4 Material Properties eoo iot A A tg edu dude 2 63 Table 2 5 Stress Intensities in 8 120B Cask under Hot Environment Loading 2 64 Table 2 6 Stress Intensities in 8 120B Cask under Cold Environment Loading 2 65 Table 2 7 Nil Ductility Temperature Requir
228. ontamination The size of the grout chunks ranges from 0 1 cm to 10 cm The grout contains 137Cs at a maximum concentration of 350 Ci ft The remaining 95 of the material is soil with a activity of 10 Ci ft of Cs The density of the soil and grout are both 100 Ib f Activities were determined by analysis of samples of the most active representative waste Step 1 Characterize Source Given in the problem statement Step 2 Convert Beta Source to Equivalent Gamma Source Not applicable Cs 137 is not a pure beta emitter Step 3 Calculate Gamma Source Strengths and Source Strength Densities We will evaluate the payload two ways one treating the entire payload as a single item with a bounding source strength y sec and source strength density y sec g and the second assuming we will treat the payload as two separate items grout and soil If there is a potential for the contamination to redistribute then it would be appropriate to qualify the source using only the y sec limits For this example the grout physically prevents its contamination from redistribution and for simplicity we assume that the soil which has a much lower source strength density also physically binds its contaminants For both payload items we will therefore perform the qualification using both source strength y sec and source strength density y sec g Note that this example does account for the possibility that the grout will redistribute or concentrate itself
229. or ner drop The analyses show that the package can successfully withstand and maintain package integrity for the specified one foot drop 2 For packages containing fissile material the free drop test specified in paragraph c 1 of this section must be preceded by a free drop from a height of 0 3 meter 1 foot on each corner or in the case of cylindrical packages onto each of the quarters of each rim Not applicable for the CNS 8 120B package 3 For fiberboard or wood rectangular packages with a mass of 50 kilograms 110 pounds or less a separate specimen must be subjected to a free drop onto each comer from a height of 0 3 meter 1 foot Not applicable for the CNS 8 120B package ER 01 004 Rev 1 Page 17 of 20 4 For cylindrical fiberboard packages with a mass of 100 kilograms 220 pounds or less a separate specimen must be subjected to a free drop onto each of the quarters of each rim from a height of 0 3 meter 1 foot Not applicable for the CNS 8 120B package 5 The target for the free drop test must be a flat horizontal surface of such mass and rigidity that any increase in its resistance to displacement or deformation upon impact by the specimen would not significantly increase the damage to the specimen The analyses performed was for a drop onto an essentially unyielding surface according to Section 2 6 6 of the SAR d Stacking test 1 The specimen must be subjected for a period of at least 24 hour
230. oreign materials i e silicone vacuum grease petroleum jelly etc Treat all debris removed from the bottom surface of the lid as potentially radiologically contaminated Care should be taken during handling operations to prevent damage to cask sealing surfaces Place secondary lid on cask using alignment marks and or alignment pins Visually inspect secondary cask lid bolts for defects and obtain replacement bolts from EnergySolutions CMF for any bolts that show cracking or other visual defects Lubricate bolt threads if required The use of impact wrenches for the installation of cask lid bolts is not permitted Replace and hand tighten the twelve 12 2 inch bolts Tighten all bolts hand tight before starting torque sequence If EnergySolutions security seals on primary lid are intact removal of primary lid for O Ring inspection is not required Bolt torque does not have to be checked on bolts with security seals Torque all the bolts to 250 25 ft Ibs lubricated using a star pattern It is recommended that the bolts be torqued a second time to 250 x 25 ft Ibs repeating the star pattern Pneumatic or hydraulic torque wrenches non impacting may be used to install the bolts Page 22 of 41 Handling Procedure for Transport Cask Model 8 120B C of C Number 9168 5 1 4 5 7 5 1 4 5 8 Note 51459 Note 5 1 4 5 10 5 1 4 5 11 5 1 4 5 12 5145 13 TR OP 035 Revision 25 Re torque a
231. orner Pt MCNP Case Location NCT 117 fullcav NCT 117 25ft3t NCT 117 55gal2 ctr tcor side Relative Error for Max Response RE Surface Side Side I L 0 3 1 0 0 4 0 3 1 4 0 3 0 6 1 0 0 6 Surface Surface Side body Top 0 6 0 7 1 8 0 4 1 3 0 3 0 8 0 3 0 8 4 4 1 8 Surface Bottom Side 0 7 1 1 0 9 0 9 N A 4 1 1m Bottom N A N A alv 14 N A N A N A N A A N A N A N A A A A A 1 8 3 2 2 2 2 0 N N N N N ES NRC 13 017 Enclosure 1 Responses to Request for Additional Information Docket No 71 9168 Allowable Source Derivation for 0 9 MeV or lower photons Transport Condition NCT HAC Source Case Full Cavity 2 5 f Centered Pt Corner Pt Side Point 55 gal Full Cavity Corner Pt MCNP Case NCT 090 NCT 090 NCT 090 NCT 090 pt4 NCT 090 pt4 NCT 090 pt4 HAC 090 HAC 090 pt fullcav 25ft3s 55gal2 ctr tcor side fullcav tcor Relative Error for Max Response ES Location Side 1 8 0 3 0 3 1 8 Surface Surface Side 1 L mo 2 0 0 9 0 4 2 0 1 5 0 3 0 4 0 3 0 5 3 5 Surface Surface Bottom 1 0 0 4 0 8 0 6 0 6 1 5 1 1 0 0 9 0 6 0 6 N A N A N A 8 2 2 1 N A O eee MUMN Side Allowable Source
232. over 0 1 were acceptable However in order to eliminate any doubts as to the adequacy or reliability of the dose rate results the cases which produced those results with relative error levels over 0 1 were re performed with longer computer runtimes for this submittal In the revised shielding analyses presented in Rev 7 of the NU 391 calculation package none of the over 10 000 individual dose rate results have relative error levels over 0 1 A set of tables similar to Tables 9 3 1 through 9 3 11 of the NU 391 calculation are attached to this RAI response In each box of each table the relative error level for each result as opposed to the dose response itself is presented Refer to Tables 9 3 1 through 9 3 11 of the Rev 7 NU 391 calculation package to see the dose rate responses in mrem hr per source gamma sec Note that the relative error levels presented in the attached tables correspond to the Rev 7 calculations None of the relative error levels exceed 0 1 Also note that although they appear in some of the boxes in Tables 9 3 1 through 9 3 11 none of the dose rate responses with relative error levels between 0 05 and 0 1 govern any of the payload source limits All source limits are governed by dose rate results with error levels under 0 05 MCNP Statistical Checks The MCNP User s Manual states that if several of the 10 statistical checks for a given tally do not pass the confidence intervals output by the code for the ind
233. p wise instructions l Determine the number of types of material payload items in the payload For each item determine the configuration i e general or discrete isotopic source strength in y sec isotopic source strength density in y sec g for the hottest portion of the payload item dimensions volume mass and maximum mass density Determine the payload totals for each parameter For payloads that include pure beta emitters with maximum beta energies gt 0 3 MeV and by S 2 2E 12 B sec convert each beta source to an equivalent gamma source for each payload item Confirm that no isotope peak beta energies are 3 5 MeV materials with beta energies 3 5 MeV are unacceptable The equivalent gamma source for each payload item Sy equals 3 5E 04 Sg Zw Epave in gammas per sec where Sp is the beta source strength in B sec Zw is the weighted average Z of the beta absorbing material for a single material absorber use the Z of the material for compounds or mixtures use a weighted average Zw Zo 2 di z il Moral Zw is determined as described above for both the waste payload and the wall of the secondary container liner that the waste resides in the higher of the two Z values is used and Epavg is the average energy of the beta in MeV The resulting equivalent gamma source has strength S at an energy of Egmax the maximum beta energy Include the equivalent gamma source along with the other gamm
234. package it must be securely closed by a positive fastening device that is independent of any other part of the package e As discussed in Sections 1 2 1 2 4 2 and 4 1 4 of the SAR the cask is equipped with adequate positive fastening devices that cannot be opened unin tentionally e The amount of pressure expected during normal conditions of transport dis cussed in Sections 2 6 1 and 3 4 4 of the SAR will not deletiourlously affect the containment system e This package is not intended to transport special form radioactive material e For each component of the containment system account is taken where applicable of radiolytic decomposition of materials and the generation of gas by chemical reaction and radiolysis When this package contains water and or organic substances which could radiolytically generate combustible gases a determination must be made by tests and measure ments or by analysis of a representative package that the following criteria are met over a period of time that is twice the expected shipment time 1 The hydrogen generated must be limited to a molar quantity that would be no more than 5 by volume or equivalent limits for other inflammable gases of the secon dary container gas void if present at STP i e no more than 0 063 ere at 14 7 psia and 70 F or 2 The secondary container and cask cavity must be inerted with a diluent to assure that oxygen is limited to 5 by volume in those portions of th
235. pe B B U or B M packaging authorized pursuant to 173 416 The CNS 8 120B is a Type B package d Any foreign made packaging that meets the standards in IAEA Safety Series No 6 and bears the marking Type A and was used for the import of Class 7 radioactive materials Such packagings may be subsequently used for domestic and export shipments of Class 7 radioactive materials provided the offeror obtains the appli cable documentation of tests and engineering evaluations and maintains the docu mentation on file in accordance with paragraph a of this section These packagings must conform with requirements of the country of origin as indicated by the packag ing marking and the IAEA regulations applicable to Type A packagings Not applicable to the CNS 8 120B package 173 465 Type A packaging tests a The packaging with contents must be capable of withstanding the water spray free drop stacking and penetration tests prescribed in this section One prototype may be used for all tests if the requirements of paragraph b of this section are met b Water spray test The water spray test must precede each test or test sequence prescribed in this section The water spray test must simulate exposure to rainfall of ER 01 004 Rev 1 Page 16 of 20 approximately 5 centimeters 2 inches per hour for at least one hour The time interval between the end of the water spray test and the beginning of the next test must be such that th
236. pecifications that must be met by the shipper 173 31 Use of tank cars Not applicable u 173 32 Requirements for the use of portable tanks Not applicable 173 33 Hazardous materials in cargo tank motor vehicles Not applicable 173 34 Qualification maintenance and use of cylinders Not applicable 173 35 Hazardous materials in intermediate bulk containers Not applicable 173 40 General packaging requirements for poisonous materials required to be packaged in cylinders Not applicable 173 410 General design requirements In addition to the requirements of subparts A and B of this part each package used for the shipment of Class 7 radioactive materials must be designed so that a The package can be easily handled and properly secured in or on a conveyance during transport ER 01 002 Rev 1 Page 9 of 15 The cask is equipped with lifting attachments for handling Cask loading and unloading procedures are specified in Chapter 7 of the SAR During transport the cask is tied down to the trailer deck The tiedown system is evaluated structurally in Section 2 4 4 of the Safety Analysis Report SAR b Each lifting attachment that is a structural part of the package must be designed with a minimum safety factor of three against yielding when used to lift the package in the intended manner and it must be designed so that failure of any lifting attach ment under excessive load would not impair the ability of the packag
237. perations to ensure that it is properly closed and secured Record the compliance of this step in attachment 7 1 step 1 This requirement is waived for uniformly distributed resins filters and for solidified wastes with no dimension less than 1 cm 4 3 10 Before an empty cask leaves the shipper s facility the following shall be confirmed 4 3 10 1 4 3 10 2 4 3 10 3 4 3 10 4 4 3 10 5 4 3 10 6 4 3 10 7 Cask verified to be empty of radioactive waste For foreign material exclusion concerns cask internals must also be verified clean and clear of all non radioactive debris All cask lifting lugs are removed and properly stored with cask for transport Trailer placarding and cask labeling and marking meet D O T specifications see References 3 1 and 3 2 as applicable Exterior radiation levels do not exceed limits per 49 CFR 173 441 and 10 CFR 71 47 see References 3 2 and 3 5 Cask internal and external removable contamination does not exceed Site Release Limits 49 CFR 173 428 49 CFR 173 443 and 10 CFR 71 87 as applicable see References 3 2 and 3 5 Cask lid bolts and vent port socket head cap screw are properly torqued That the cask lids and impact limiters are sealed with security seals 4 3 11 The inspection tag attached to the primary or secondary lid shall be reviewed to verify none of the maintenance inspection or testing activities has passed the due dates recorded on the tag If any dates
238. perature changes it may be necessary to adjust the pressure back to 18 psig The pressure should not drop when the regulating shut off valve is closed It may take up to 30 minutes for the temperature to equalize Once 18 psig 1 0 psig is obtained on the Test Pressure Gauge close the Leak Test Supply Valve Set the Air Regulator to O psig or OFF and close the Air Regulator Inlet Valve Disconnect the air supply from the manifold Record the time on the Air Leak Test Inspection Form Appendix A After a period of fifteen 15 minutes 5 0 pressurized at 18 psig 1 0 psig and no drop in pressure greater than the minimum detectable amount record time on Appendix A Connect off gas header if required by plant procedure to the control side of the test manifold Slowly open valves on the test manifold and bleed air from cask Note Air bled from cask is potentially contaminated Take appropriate health physics precautions If pressure drop test fails the secondary lid may be pulled and inspected The o rings and seating surface condition lid tightness etc shall be checked corrected and the test repeated Refer to Appendix B for air leak test troubleshooting In the event of subsequent air pressure drop test failures refer to Appendix B for troubleshooting and contact EnergySolutions CMF for assistance 1f needed After successfully completing the required air pressure drop test of the secondary lid o rings r
239. properly handled exhibit this potential safety hazard during off load Chem Nuclear recommends that additional care be taken at any time a liner is removed from a cask fitted with a shield insert Furthermore Chem Nuclear recommends that all shield inserts used with the 14 170LPRCT in particular be inspected and gauged for roundness prior to assembly into a cask It is our understanding that Customers may be using several older model LPRCT liners without the smaller OD with casks fitted with shield inserts provided from sources other than Chem Nuclear We recommend that all end users and intermediate handlers incorporate cautionary steps into appropriate procedures for the inspection and gauging of these assemblies before use ACTIONS TAKEN BY CHEM NUCLEAR Chem Nuclear has taken the following actions to prevent the described scenario e Designed a no go gauge for shield inserts to be used with the 14 170LPRCT e Developed a procedure for use of the no go gauge which in addition stipulates pertinent inspection criteria and cautions to be taken during shield insert handling and cask loading and off loading e Revised the 14 170LPRCT shell baseplate interface design to provide an additional inch of clearance Chem Nuclear is confident that the implementation of these recommendations will help prevent the inadvertent removal of shield inserts when off loading liners from casks For additional information please contact Patrick Paquin at
240. pter 3 0 of the report 82 ACCEPTANCE TESTS CONFIGURATION 3 CASKS FABRICATED AFTER APRIL 1 1999 Prior to the first use of an 8 120B package fabricated to Configuration 3 the following tests and evaluations will be performed 8 2 1 VISUAL INSPECTIONS AND MEASUREMENTS Throughout the fabrication process confirmation by visual examination and measurement are required to be performed to verify that the 8 120B packaging dimensionally conforms to the drawing referenced in the current Certificate of Compliance for the 8 120B The packaging is also required to be visually examined for any adverse conditions in materials or fabrication that would not allow the packaging to be assembled and operated per Section 7 0 or tested in accordance with the requirements of Section 8 0 Throughout the fabrication process the fabricator shall request approval from EnergySolutions prior to implementation of any options allowed in the drawing 8 2 8 120B Safety Analysis Report Consolidated Revision 7 8 2 2 8 2 3 November 2013 WELD EXAMINATIONS 8 2 2 1 All welding of the Containment Boundary identified on drawing C 110 E 0007 will be done in accordance with ASME Code Section III Division I Subsection ND except as follows Due to the geometry of the joint configuration between Item 17 and 18 NDE of the 4 bevel groove weld and the 1 bevel groove weld may be done by progressive surface examination utilizing the MT method in lieu of RT o
241. quivalent information c In order to acquire such information a competitor would also require considerable time and inconvenience d The information consists of detailed descriptions properties and test data The availability of such information to competitors would enable them to modify their product to better compete with EnergySolutions take marketing or other actions to improve their product s position or impair the position of EnergySolutions product and avoid developing fabrication data in support of their processes methods and or apparatus e In pricing EnergySolutions products and services significant research development engineering analytical licensing fabrication quality assurance and other costs must be included The ability of EnergySolutions competitors to utilize such information without similar expenditure of resources may enable them to sell their product at prices reflecting significantly lower costs Further the deponent sayeth not I declare under penalty of perjury that the forgoing is true and correct Executed on Z3 May 7013 Date Steven E Sisley Licensing Manager EnergySolutions Products and Technology Group Page 4 of 4 um ENERGYSOLUTIONS Letterbook No ES NRC 13 013 Docket No 71 9168 July 3 2013 Mr Pierre Saverot U S Nuclear Regulatory Commission Division of Spent Fuel Storage and Transportation Licensing Branch 3 White Flint North Building 11601 Landsdown Street
242. r UT Due to the geometry of the joint configuration between Item 3 and 5A NDE of the 34 v groove weld may be done by progressive surface examination utilizing the MT method in lieu of RT or UT Due to the geometry of the joint configuration between Item 3 and 4 NDE of the 4 v groove weld may be done by utilizing the UT MT methods in lieu of RT 8 2 2 2 All welding of Non Containment Boundary items identified on drawing C 110 E 0007 will be done in accordance with ASME Code Section III Division I Subsection NF Class 3 except as follows The Root Pass and the Final Pass of the v groove weld between Item 5A Cask Bottom Plate and Item 5B Cask Bottom Plate Outer Ring shall be done in accordance with ASME Code Section III Division I Subsection NF 5230 by magnetic particle examination MT with acceptance requirements of ASME Code Section III Division I Subsection NF Article NF 5340 The Root Pass and the Final Pass of the bevel groove weld between Item 5B Cask Bottom Plate and Item 1 Outer Cask Shell shall be done in accordance with ASME Code Section IIL Division I Subsection NF 5230 by magnetic particle examination MT with acceptance requirements of ASME Code Section III Division I Subsection NF Article NF 5340 8 2 2 3 Welding on lifting and tiedown lugs identified on drawing C 110 E 0007 will be done in accordance with ASME Code Section III Division I Subsection NF Class 3 and shall be inspected b
243. rce terms for all such shipments are qualified in accordance with Consolidated Revision 3 of the Safety Analysis Report for Model 8 120B Type B Shipping Package Basis Modifications to add the steel plate to the lower impact limiters of all 8 120B casks in service will be made in a timely manner after the CoC is amended A transition period of 90 days is requested to implement this change such that cask operations can continue using the package design authorized under CoC Revision 19 with the appropriate contents radiological limits In addition to the changes requested above an inconsistency has been identified between the cask reference leakage rate provided in Consolidated Revision 3 of the SAR and that stated in Section 4 1 of the SER for CoC Revision 19 In Section 4 4 of Consolidated Revision 3 of the SAR the reference leakage rate Lg for the cask under Normal Conditions of Transport which is conservatively based on Irradiated Hardware is 2 2E 06 cm sec whereas in Section 4 1 of the SER for CoC Revision 19 a value of 1 54x10 ref cm sec is quoted While this inconsistency should not directly affect the requirements of the Certificate it should be corrected for the CoC amendment if it is included in the SER z ENERGYSOLUTIONS August 9 2013 ES NRC 13 017 Docket No 71 9168 ATTN Document Control Desk Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U S Nucl
244. rections to the 8 120B SAR Reference 2 Finally the application deletes the July 2012 SAR Addendum as it will no longer be applicable under the requested CoC amendment A summary of the specific proposed changes to the 8 120B SAR is provided in Attachment 1 of this letter Enclosure 1 contains one 1 paper copy of the non public version of the revised SAR that contains security related sensitive information that should be withheld under 10 CFR 2 390 Enclosure 2 contains one 1 paper copy of the public version of the revised SAR in which all proprietary information and security related sensitive information is redacted Enclosure 3 contains one 1 paper copy of the revised shielding analysis for the 8 120B cask which contains proprietary information An affidavit containing a full statement of the reasons that the proprietary information should be withheld from the public pursuant to the requirements of 10 CFR 2 390 is included in Attachment 2 of this letter 2105 South Bascom Ave Suite 230 Campbell California 95008 408 558 3500 Fax 408 558 3518 www energysolutions com ES NRC 13 010 May 23 2013 Page 2 of2 Should you or your staff have questions please contact the undersigned Sincerely Steven E Sisley Licensing Manager EnergySolutions Products and Technology Group 408 558 3509 E Mail ssisley energysolutions com Attachments 1 Summary of Changes 8 120B Consolidated SAR Revision 4 4 pages 2 Affidavi
245. references specifications 1 and 3 bullets All Chapter 4 has been re typeset in Editorial change its entirety Formatting changes are not marked as revisions All other changes are described below 4 Deleted CNS from the model Editorial change designation 4 5 Corrected referenced equation Editorial correction numbers for Fm Dmax and Fon Dmax 4 6 Clarified basis for assumed weight Editorial correction used in containment calculation u B e 4 7 4 7 1 4 7 Revised heading text Editorial change 4 19 Corrected equation to divide Editorial correction Lue Tr by 2 4 19 Revised 2 sentence to clarify Pre shipment leak test required that the pre shipment leak test of for all Type B shipments the vent port is not a condition of except for LSA material and whether the vent port plug has or SCO material that is exempt has not been removed under 10 CFR 71 14 b 3 1 4 20 Corrected units for parameter L Editorial correction Appendix 4 1 4 30 Added blank page for 2 sided Editorial change printing ES NRC 13 026 November 13 2013 Page 6 of 9 Consolidated Summary of Changes 8 120B Consolidated SAR Revisions 4 through 7 5 1 Revised 1 paragraph to discuss Revised in response to RAI 5 2 presence of cask cavity cladding Section Deleted last sentence of paragraph 5 2 Dose rates updated based on Revised in response to RAI 5 6 revised shi
246. resent or future EnergySolutions or customer funded development plans and programs of potential commercial value to EnergySolutions f The information contains patentable ideas for which patent protection may be desirable g The information is third party Proprietary Information The information is being transmitted to the Commission in confidence and under the provisions of 10 CFR Section 2 390 it is to be received in confidence by the Commission The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief The proprietary information sought to be withheld in this submittal is that which is appropriately marked and being transmitted by EnergySolutions to the Document Control Desk The proprietary information has been presented to the Nuclear Regulatory Commission and is being voluntarily provided by EnergySolutions Public disclosure of the information is likely to cause substantial harm to the competitive position of EnergySolutions because a Similar products are manufactured and sold by competitors of EnergySolutions Page 3 of 4 b The development of this information by EnergySolutions is the result of a significant expenditure of staff effort and a considerable sum of money To the best of my knowledge and belief a competitor would have to undergo similar
247. rfaces prior to reinstalling the primary lid on the cask body or may be performed after primary lid is replaced on cask body Refer to Steps 5 1 4 2 1 through 5 1 4 2 8 for secondary lid removal After lid removal refer to Steps 5 1 4 4 1 through 5 1 4 4 13 for replacement of secondary lid 5 2 12 1 Note 5 2 12 2 Attach the crane hook to the three 3 lifting lugs on the primary lid The cables used to lift the primary lid must have a true angle of not less than 45 with respect to the horizontal The primary lid O Ring seals shall be visually inspected for serviceability ensuring that they are in the proper position and free of cracks tears cuts or discontinuities which may prevent them from sealing properly The seal seating surface shall be visually inspected to ensure that they are free of damage debris gravel or any foreign matter which might damage the seals or prevent the seals from properly sealing If any defects are detected that may prevent the seals from forming a seal contact EnergySolutions CMF Inspect and clean the O Ring seating surfaces A very thin coat of vacuum grease or petroleum jelly should be applied to the sealing surface of the O Ring prior to installing and torquing the lid Inspect the air test annulus and leak test port to assure that they are free of foreign materials i e silicone vacuum grease petroleum jelly etc Page 29 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 1
248. rt 7 13 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Example 1 Cs 137 Source Capsule Problem Determine the acceptability of a 50 Ci 157Cs source to be centrally shored The source is a metal capsule 2 cm in diameter by 10 cm long and the Cs source pellet weighs 50 g Step 1 Characterize Source Given in the problem statement Step 2 Convert Beta Source to Equivalent Gamma Source Not applicable Cs 137 is not a pure beta emitter Step 3 Calculate Gamma Source Strengths and Source Strength Densities The qualification Table has specific limits for Cs so it is not necessary to do the qualification by energy line The source s Ci source strength must be converted to y sec and y sec g in order to calculate the source limit fractions ICs produces 0 85 gammas per decay with an energy of 0 66 MeV The total source strength is 0 857 E A cher ed soe qot Ci d sec and dividing by 50 g the total source strength density is 3 14E10 y sec g Step 4 Select the Limits Since this payload is to be shipped in a shored configuration the payload is a discrete type payload The size fits within the defined envelope for the 2 5 f payload therefore the column and O limits apply for y sec and y sec g respectively Steps 5 7 Sum the Fractions For this example there is only one fraction to calculate Shape Energy Payload Source Term o Payload Item Type Discrete MeV or F 2 5ft3 C
249. rtainty is treated and how convergence is ensured Due to the large number of calculations used to determine the content limit tables the staff was unable to review every output file to determine proper convergence In response to the staff s request the applicant provided the relative error uncertainty for each calculation as well as information on how this uncertainty is treated Based on the information submitted by the applicant the staff determined that the uncertainties are relatively low and treated in a conservative manner The applicant stated that almost all of the MCNP tallies calculations have passed all 10 of MCNP s statistical checks For tallies that did not pass all of the statistical checks the applicant provided the procedure they used to determine that each calculation has converged Each of these calculations was reviewed individually by an analyst In many cases the tally was not used to determine source limits and would have to increase substantially to affect the content limit curves In a few cases where tallies were used to calculate content limits these only missed one statistical check showed good behavior in relation to other tallies with similar locations and source strengths and had low uncertainty levels Therefore the staff found the information submitted by the applicant demonstrated that each calculation had converged properly 5 4 3 Flux to Dose Rate Conversion The applicant used conversion factors that wer
250. rts treating all parts as potentially contaminated and inspect the set screw plug to ensure that there are no defects 1 e cracks deformed or stripped threads etc If the set screw plug is defective obtain a replacement from EnergySolutions 5 2 15 Clean the set screw plug of all debris thread tape ect and reinstall in the primary lid Hand tighten until the set screw plug is snug 5 3 Pressure Drop Test For Vent Port Note Review thetroubleshooting guide listed in Appendix B prior to performing the air pressure drop leak test Following the instructions in Appendix B should help obtain a successful air leak test of the cask Page 9 of 15 Air Pressure Drop Test for 8 120B Cask TR TP 002 Certificate of C onformance USA 9168 B U Revision 20 Note If the vent port seal o ring is damaged contact E nergySolutions cask 5 3 1 5 3 2 5 3 3 5 3 4 5 3 5 5 3 6 5 3 7 5 3 8 5 3 9 maintenance group The cask shall receive an annual leak test anytime the seal o ring needs replaced Ensure cask is assembled in accordance with Reference 2 1 and applicable drawings listed in Reference 2 2 Verify cask lid bolts and vent port socket head cap screw are properly torqued to values listed in the cask handling procedure Using a 3 4 inch allen wrench remove the set screw plug from the vent port Retain for reinstallation Remove any debris foreign materials from the vent port Using a 3 8 allen wrench by
251. s and 2 09E 05 Ci of Co Fe can be neglected since it does not emit any gammas 0 3 MeV We can only use the y sec limit for qualification The source inputs are therefore Energy Payload Source Term MeV or p Nuclide y sec y sectg 1 55E 06 Cs 137 9 88E 05 Step 4 Select the Limits The 100g activated item would meet the size criteria for the 55 gallon discrete shored configuration if both the container were shored and the item was shored within the container in which case its limits would be columns 6 and for y sec and y sec g respectively Otherwise since it would be unshored the limits in columns O and would apply for y sec and y sec g respectively The remaining activated metal does not meet the definitions of either of the two discrete shored configurations 2 5 ft or 55 gal so it is a general type payload item The limits in columns O and apply for y sec and y sec g respectively MicroShield Version 8 01 Grove Engineering 7 20 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 The crud is free to move within the cavity and is therefore a general type payload item Also as discussed in the first section of this Attachment crud must be qualified using the y sec limit Thus the limit in column in y sec applies for the crud Steps 5 7 Sum the Fractions 3 5 3 4 5 First we will try qualifying the payload without shor
252. s if required 5 2 3 6 Visually inspect lid bolt holes for damage defects and accumulation of debris Remove debris if required Contact EnergySolutions CMF for any bolt holes that show signs of cracking or visual signs of distress 5 2 3 7 Visually inspect and clean the O Ring seating surfaces The Health Physics Technician shall conduct a radiation survey to determine offloading precautions If directed by the Health Physics Technician vacate all personnel from the immediate area except for the crane operator and rigger The rigger shall stand in clear view of the crane operator or have proper communications with crane operator Prepare to remove contents of the cask The cask may contain a filled liner or pallets If the cask contains pallets follow the procedure for unloading pallets Step 5 2 8 and skip Step 5 2 7 Procedure for Unloading a Liner Caution Care should be taken during handling operations to prevent 5 2 8 damage to cask sealing surfaces 5 2 7 1 Attach crane hook to the cables or grapple ring on the liner 5 2 7 2 Lift liner straight up out of cask and allow any liquid to drip off into the cask 5 2 7 3 Place the liner in position for disposal or future handling Procedure for Unloading Pallets Caution Confirm that the safety hook if installed on the pallet sling remains attached to the lifting ring Caution Care should be taken during handling operations to prevent damage to cask sealing
253. s 137 1 57E 12 3 15E 10 Cs 137 e 5 77E 12 0 1 28E 09 2 73E 01 2 46E 01 2 73E 01 Sum 2 73E 01 Since the sum is less than 0 95 the source is an acceptable payload gt Always perform calculations with the full precision for the limits shown in Table In these examples full precision data was used but the number of digits is reduced for presentation purposes 7 14 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Example 2 Solidified Process Waste Problem Step 1 Step 2 Step 3 Step 4 Steps 5 7 Determine the acceptability of a 100 iE secondary container containing solidified process waste The activity is uniformly distributed The measured weight of the filled container is 13 100 Ibs and the weight of the empty container is 1 100 Ibs The isotopic activity determined by analysis of samples of the waste is 5 Ci of Co 10 Ci of Cs 50 Ci of Fe 4 Ci of Mn and 20 Ci of Sr Characterize Source Given in the problem statement Convert Beta Source to Equivalent Gamma Source Sr emits beta radiation through its own decay plus the decay of its short lived daughter product y So the beta production rate is 20 Ci 3 7E 10 d Ci 2 1 5E 12 B sec Since this is below the threshold of 2E 12 B sec the beta production is not significant and can be disregarded Calculate Gamma Source Strengths and Source Strength Densities The qualification Table has specific limits for Co
254. s are a structural part of the package From the General Arrangement Drawing shown in Appendix 1 3 it can be seen that two removable lifting ears are provided which attach to the cylindrical cask body Three lifting lugs are also provided for removal and handling of the lid Similarly three lugs are provided for removal and handling of the secondary lid Refer to Section 2 5 1 for a detailed analysis of the structural integrity of the lifting devices 1 3 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 1 2 1 7 Tie downs From the General Arrangement Drawing shown in Appendix 1 3 it can be seen that the tie down arms are an integral part of the external cask shell Consequently tie down arms are considered a structural part of the package Refer to Section 2 5 2 for a detailed analysis of the structural integrity of the tie down arms 1 2 1 8 Heat Dissipation There are no special devices used for the transfer or dissipation of heat 1 2 1 9 Coolants There are no coolants involved 1 2 1 10 Protrusions There are no outer or inner protrusions except for the tie down arms described above Lifting lugs are removed prior to transport 1 2 1 11 Shielding Cask walls provide a shield thickness of 3 35 inches of lead and 2 inches of steel Cask ends provide a minimum of 6 inches of steel The contents will be limited such that the radiological shielding provided 4 inches lead equivalent will assure compliance with
255. s required by 10 CFR 71 43 d the contents shall not include any materials that may cause any significant chemical galvanic or other reaction Powdered solids shipments shall be performed only when the most recent periodic leak test meets the requirements of Chapter 4 Section 4 9 Powdered solid radioactive material shall not include radioactive forms of combustible metal hydrides 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 For any package containing water and or organic substances which could radiolytically generate combustible gases a determination must be made that over a period of time that is twice the expected shipping time the hydrogen generated must be limited to a molar quantity that would be no more than 5 by volume or equivalent limits for other inflammable gases of the 1 5 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 secondary container gas void if present at STP 1 e no more than 0 063 g moles ft at 14 7 psia and 70 F The determination of hydrogen generation will be made using the methods in NUREG CR 6673 Hydrogen Generation in TRU Waste Transportation Packages NUREG CR 6673 has equations that allow prediction of the hydrogen concentration as a function of time for simple nested enclosures and for packages containing multiple contents pack
256. s specified below Packaging 1 Model No 8 120B 2 Description A oylindrical carbon steel lead shielded packaging designed for the transport of radioactive waste materials The packaging has four tie down and two removable lifting devices and is transported in the upright position with cylindrical foam filled impact limiters 102 inches outside diameter OD installed at each end of the packaging The overall height of the package with the impact limiters attached is 132 4 inches The maximum gross weight of the package is approximately 74 000 pounds Ibs as follows Packaging Body 42 220 lbs Lid l 7 080 Ibs Payload 14 150 Ibs Impact Limiters 4 860 Ibs each Miscellaneous 830 Ibs Package 74 000 Ibs The cavity of the packaging is a right circular cylinder with an internal diameter of 61 13 16 inches and a height of 74 7 8 inches The package body consists of two shells both fabricated of ASTM A516 Grade 70 steel The annular space between the 1 inch thick external shell and the inch thick internal shell is filled with 3 35 inch thick lead The primary lid is attached to the packaging body with twenty equally spaced 2 inch diameter bolts A supplemental 14 gauge stainless steel sheet is welded to the inside surface of the primary lid NRC FORM 618 U S NUCLEAR REGULATORY COMMISSION 8 2000 10 CFR 71 CERTIFICATE OF COMPLIANCE FOR RADIOACTIVE MATERIAL PACKAGES 1 a CERTIFICATE NUMBER b REVISION NUMBER c DOCKET NUMBE
257. s to a compres sive load equivalent to the greater of the following i Five times the mass of the actual package or ii The equivalent of 13 kilopascals 1 9 pounds per square inch multiplied by the vertically projected area of the package 2 The compressive load must be applied uniformly to two opposite sides of the specimen one of which must be the base on which the package would normally rest 88 0 in Case i above 5 times package wt e se HA 5 x 74 000 Ibs 370 000 lbs IM A A ILIA Case ii above 1 9 Ibs in x vertically 1 5 in MEME EE LIE projected area 1 9 Ib in x 88 0 in x 73 2 in 12 239 Ibs d1 732 jn Case i is more severe Analyze the cask as a beam with the WEN NIE eee uniform load of 370 000 Ibs applied along the axial length of the wall T AUT T n assume simple end supports ous oz The outer shell is fabricated from A516 for conservatism assume where F 32 000 psi M E _ MC reas M 5x Ms APRES 4 07 x 10 in lbs ER 01 004 Rev 1 Page 18 of 20 1 A a di 04906 73 2 70 2 2 17 x 105 in Therefore _ 4 07 x10 in Ib 39in _ 732 psi which yields the following margin of safety b 2 17x10 in 32 000 SS LX 1 42 M S 335 4 42 7 This calculation is conservative since the structural support of the lead and inner shell is not considered The same compressive load acting vertically on the lid is also consid
258. se of hazardous materials to the environ ment 2 The effectiveness of the package will not be substantially reduced for example impact resistance strength packaging compatibility etc must be maintained for the minimum and maximum temperatures encountered during transportation 3 There will be no mixture of gases or vapors in the package which could through any credible spontaneous increase of heat or pressure significantly reduce the effectiveness of the packaging This specification is demonstrated to be met in Section 2 6 10 in the CNS 8 120B SAR c Authorized packagings A packaging is authorized for a hazardous material only if 1 The packaging is prescribed or permitted for the hazardous material in a packag ing section specified for that material in Column 8 of the 172 101 Table and conforms to applicable requirements in the special provisions of Column 7 of the 172 101 Table and for specification packagings but not including UN standard packagings manufactured outside the United States the specification require ments in parts 178 and 179 of this subchapter or 2 The packaging is permitted under and conforms to provisions contained in 8171 11 171 12 171 12a 173 3 173 4 173 5 173 7 173 27 or 176 11 of this subchapter Column 8 of the 172 101 Table specifies the applicable packaging specifications and exceptions for a hazardous materials being addressed for example Radioactive Material LSA
259. seals from properly sealing If any defects are detected that may prevent the seals from forming a seal contact EnergySolutions CMF Refer to the provisions of Step 4 4 2 for leak test requirements Inspect and clean the O Ring seating surfaces A very thin coat of vacuum grease or petroleum jelly should be applied to the sealing surface of the O Ring prior to installing and torquing the lid Inspect the air test annulus and leak test port to assure that they are free of foreign materials i e silicone vacuum grease petroleum jelly etc Treating all debris removed from the bottom surface of the lid as potentially radiologically contaminated Lift the primary lid clean the bottom surface and lower into position using alignment marks and alignment pins The use of impact wrenches for the installation of cask lid bolts is not permitted Replace and hand tighten the twenty 20 2 inch hex head primary lid bolts Tighten all the bolts hand tight before starting torque sequence Page 15 of 41 Handling Procedure for Transport Cask Model 8 120B C of C Number 9168 5 1 2 7 Caution 5 1 2 6 6 Note 5 1 2 6 7 5 1 2 6 8 Note 5 1 2 6 9 Note 5 1 2 6 10 5 1 2 6 11 5 1 2 6 12 5 1 2 6 13 TR OP 035 Revision 25 Torque all the bolts to 250 25 ft Ibs lubricated using a star pattern It is recommended that the bolts be torqued a second time to 250 x 25 ft Ibs repeating the star pattern Pn
260. servations Remove security seal s as required Impact Limiter Removal 7 2 4 1 Loosen and disconnect ratchet binders from upper impact limiter 7 2 4 2 Using suitable lifting equipment remove upper impact limiter assembly Care should be exercised to prevent damage to impact limiter during handling and storage Secondary Lid Thermal Shield Removal 7 2 5 1 Remove the ball lock pins from each of the three retaining pins and remove the retaining pins from secondary lid lift lugs 7 2 5 2 Using suitable lifting equipment remove the secondary lid thermal shield Care should be taken to prevent damage to thermal shield during handling and storage If cask must be removed from trailer refer to Step 7 1 3 Loosen and remove the twenty 20 primary lid bolts NOTE The cables used for lifting the lid must have a true angle with respect to the horizontal of not less than 45 degrees Using suitable lifting equipment lift lid from cask using care during handling operations to prevent damage to cask and lid seal surfaces Remove contents NOTE Radioactively contaminated liquids may be pumped out or removed by use of an absorbent material Removal of any material from inside the cask shall be performed under the supervision of qualified health physics personnel with the necessary H P monitoring and radiological health safety precautions and safeguards 7 6 8 120B Safety Analysis Report Consolidated Revision 7 7 3 7 2 10
261. sk Revision 19 e DWG CSK 12CV01 EG 0001 8 120B Cask Secondary Lid Thermal Shield Details Revision 3 Drawings withheld on the basis that they are Security Related Information 1 7 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 This page intentionally blank 1 8 Sections 2 0 through 6 0 are not included in the Cask Book since they are not required for the operations and maintenance of the package and need not be in the possession of the licensee during use of the package 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 7 0 OPERATING PROCEDURE This chapter describes the general procedure for loading and unloading of the 8 120B Cask The maximum permissible activity is the lesser of the activity determined by 1 Attachment 1 for beta and gamma emitters 2 3000 A or 3 having a decay heat of 200 watts Radioactive contents are to be transported as exclusive use per 10 CFR 71 4 For contents that could radiolytically generate combustible hydrogen see Attachment 2 for instructions on determination of hydrogen concentration Powdered solids shipments require that the most recent periodic leak test meets the requirements of Section 8 3 2 1 for leaktight status 7 1 LOADING THE PACKAGING NOTE Prior to loosening the impact limiter ratchet binders inspect the exterior of the package for damage e g large dents gouges tears to the impact limiter skin and thermal shie
262. st the pressure back to 18 psig The pressure should not drop when the regulating shut off valve is closed It may take up to 30 minutes for the temperature to equalize 5 2 8 Once 18 psig 1 0 psig is obtained on the Test Pressure Gauge close the Leak Test Supply Valve 5 2 9 Set the Air Regulator to O psig or OFF and close the Air Regulator Inlet Valve 5 2 10 Disconnect the air supply from the manifold Record the time on the Air Leak Test Inspection Form Appendix A 5 2 1 After a period of fifteen 15 minutes 5 0 pressurized at 18 psig 1 0 psig and no drop in pressure greater than the minimum detectable amount record time on Appendix A Connect off gas header if required by plant procedure to the control side of the test manifold Slowly open valves on the test manifold and bleed air from cask Note Air bled from cask is potentially contaminated Take appropriate health physics precautions 5 2 12 If pressure drop test fails the o rings and seating surface condition lid tightness etc shall be checked corrected and the test repeated Refer to Appendix B for air leak test troubleshooting 5 2 13 In the event of subsequent air pressure drop test failures refer to Appendix B for troubleshooting and contact EnergySolutions CMF for assistance if needed 5 2 14 After successfully completing the required air pressure drop test of the primary lid o rings remove the air test manifold and all associated pa
263. system to ensure that it is properly closed and secured This requirement is waived for uniformly distributed resins filters and for solidified wastes larger than 1 cm We will add a footnote indicating that the basis for the size is that the source for certain shielding models was assumed to be 1 cm in size Summary of SAR changes e Revise Step 7 1 9B 10 ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information Attachment Relative Error Tables For Revision 7 of NU 39 Allowable Source Derivation for Co 60 Transport Condition NCT HAC Source Case Full Cavity 2 5 f 55 gal Centered Pt Corner Pt Side Point Full Cavity Corner Pt MCNP Case NCT Co60 NCT Co60 NCT Co60 NCT Co60 NCT Co60 NCT Co60 HAC Co60 HAC Co60 fullcav 25ft3t 55gal pt ctr pt tcor pt side fullcav VERENA HN M OHNE el N A 3 1 3 0 9 1 9 N A N A N A sw wa wa N A A x NCT Allowable Source Derivation for Cs 137 Transport Condition NCT HAC Source Case Full Cavity 2 5 f Centered Pt Corner Pt Side Point Full Cavity Corner Pt NCT Cs 137 NCT Cs 137 NCT Cs 137 NCT Cs137 fullcav 25ft3s pt ctr Relative Error for Max Response RE NCT Cs137 NCT Cs137 MCNP Case pt tcor pt side Surface Side I L 2 9 2 6 1 9 1 7 0 7 N A N A N A 0 8 N A N A N A Surface Surface Top 1 0 0 5 0 5 4 0 5 1 Surfa
264. t manifold volume Therefore the 20 minute hold time still provided a substantial margin for detecting any leakage from the vent port and there was no safety significance associated with this issue The staff recognizes that new lids are used on the packages after August 31 2013 using different testing procedures in the previous Revision 19 of the CoC ANSI N14 5 provides acceptable methods for demonstrating that Type B packages designed for transport of normal form radioactive material comply with the regulatory containment requirements specified in 10 CFR Part 71 According to ANSI N14 5 a pre shipment leakage rate test is to be performed on containment boundary seals that have been opened Based on a 2005 information notice released by Energy Solutions the containment boundary vent port seal could be opened and closed for the shipment of Low Specific Activity LSA material or Surface Contaminated Objects SCO In previous revisions of the application a pre shipment leakage rate test would not have to be performed if the package contained LSA SCO contents that meet the exemption standards in 10 CFR 71 14 b 3 i However a potential scenario could occur where Type B contents could be shipped without performing a pre shipment leakage rate test ze on a vent port seal that remained closed during the Type B loading operations even if the vent port had been opened during a prior loading of LSA SCO contents The vent port could also be opened wh
265. t of the test manifold and the quick disconnect 6 Check the cask lid bolts to ensure they are torqued to 500 50 0 ft Ibs Page 15 of 15 DURATEK ENGINEERING REPORT ER 01 002 Revision 1 T I RP d Approvals Page Conformance of CNS 8 120B Cask with Specifications for Industrial Packaging Type 1 and Type 2 Prepared by Signature on File 10 8 02 Shayne Merritt Project Engineer Date Independent Reviewer Signature on File 10 8 02 Patrick L Paquin General Manager Date 2 0 3 0 4 0 5 0 TABLE OF CONTENTS INTRODUCTION ii Rita 3 DISCUSSION pu E 3 RESULTS eiri irer E io 4 CONCLUSIONS AND RECOMMENDATIONS sssee mee ene 15 REFERENCES E RP ticaipot n 15 ER 01 002 Rev 1 Page 2 of 15 1 0 Introduction This report evaluates the CNS 8 120B cask s conformance with 49CFR173 411 Industrial Packaging Reference 5 1 This report fulfills the requirement of 49CFR173 411 for IP 2 packages which specifies that Except for IP 1 packages each offeror of an industrial package must maintain on file for at least one year after the latest shipment and shall provide to the Associate Administrator for Hazardous Materials Safety on request complete documentation of tests and an engineering evaluation or comparative data showing that the construction methods packaging design and materials of construction comply with that specification 2 0 Discussion The CNS 8 120B is licensed by the US NRC un
266. t pursuant to 10 CFR 2 390 Enclosures 1 Safety Analysis Report for the Model 8 120B Type B Shipping Packaging Consolidated Revision 4 May 2013 Non Public Version 1 paper copy Security Related Information Withhold Under 10 CFR 2 390 2 Safety Analysis Report for the Model 8 120B Type B Shipping Packaging Consolidated Revision 4 May 2013 Public Version 1 paper copy 3 EnergySolutions Calculation Package 8 120B Shielding Response Document No CALC NU 391 Revision 6 1 paper copy Proprietary Withhold Under 10 CFR 2 390 cc Mr Pierre Saverot Division of Spent Fuel Storage and Transportation Mr Dan Shrum EnergySolutions ES NRC 13 010 Attachment 1 May 23 2013 Page 1 of4 Summary of Changes 8 120B Consolidated SAR Revision 4 Section Change Purpose Front Matter Added blank page Editorial formatting for two sided printing Expanded description of impact Revised for clarity limiter skin and cover plates Changed maximum payload Reduced to offset additional weight weight of plate added to lower impact limiter in order to maintain maximum package weight 121 5 1 3 Deleted comma from section Editorial correction heading 1 3 1 7 Added list of drawings included in Editorial for clarity SAR 1 8 Added blank page Editorial formatting for two sided printing 1 3 Revised Dwg No C 110 E 0007 Purposes of
267. taken for in sulation 2 The integrity of containment will not be impaired if the package is exposed to ambient temperatures ranging from 40 C 40 F to 55 C 131 F and 3 Packages containing liquid contents will be capable of withstanding without leakage an internal pressure that produces a pressure differential of not less than 95 kPa 13 8 Ib ir Not Applicable 173 411 a b and c industrial packagings a General Each industrial packaging must comply with the requirements of this section which specifies packaging tests and record retention applicable to In dustrial Packaging Type 1 IP 1 Industrial Packaging Type 2 IP 2 and Indus trial Packaging Type 3 IP 3 The CNS 8 120B Cask complies with the requirements for an Industrial Packaging Type 1 or Type 2 packaging b Industrial packaging certification and tests B 1 Each IP 1 must meet the general design requirements prescribed in 8773 410 s A See 2 below 2 Each IP 2 must meet the general design requirements prescribed in 5173 410 and when subjected to the tests specified in 8173 465 c and d or evaluated against these tests by any of the methods authorized by 8773 4671 a must prevent i Loss or dispersal of the radioactive contents and ER 01 002 Rev 1 Page 11 of 15 ii A significant increase in the radiation levels recorded or calculated at the external surfaces for the condition before the test Compliance was demonstrate
268. tatus from Section 4 9 leak test requirements for are added to Chapter 8 powdered solid shipments 7 1 14 7 4 Added word every before Added clarification and basis shipment and added footnote 2 for requirement 7 1 21 6 New requirement added Requirement added to assure cask has received the required periodic leak testing prior to shipment 8 3 2 1 8 6 8 7 Revised to include leak testing Leak test requirements for requirements for powdered solid leaktight status from Section 4 9 shipments are added to Chapter 8 Table 8 1 Added Note 1 Clarify the periodic leak testing requirements for shipments of powdered radioactive materials 8 3 22 d Deleted last sentence Pressure gauge graduation requirement is not necessary ES NRC 13 025 November 13 2013 Enclosure 1 Safety Analysis Report for the Model 8 120B Type B Shipping Packaging Consolidated Revision 7 November 2013 Non Public Version 1 paper copy Security Related Information Withhold Under 10 CFR 2 390 ES NRC 13 025 November 13 2013 Enclosure 2 Safety Analysis Report for the Model 8 120B Type B Shipping Packaging Consolidated Revision 7 November 2013 Public Version 1 paper copy ENERGYSOLUTIONS Letterbook No ES NRC 13 026 Docket No 71 9168 November 13 2013 Mr Pierre Saverot U S Nuclear Regulatory Commission Division of Spent Fuel Storage and Transportation Licensing Branch 11555 Rockville Pike MS 3WFEN 14A44 Rockville MD
269. ted content this omission only applies when using the cask as a Type B packaging The analysis that follows considers the contents to be in liquid or solid state However a liner primary container is required when shipping liquids See 49CFR 173 412 k The shipper is also responsible for ensuring that the contents do not exceed any of the limits placed on the contents by the analyses in this report or by 49CFR173 431 The applicable requirements for DOT 7A packagings is given in 49CFR178 350 which is as follows Each packaging must meet all applicable requirements of subpart B of Part 173 of this subchapter and be designed and constructed so that it meets the requirements of 173 403 173 410 173 412 173 415 and 173 465 of this subchapter for Type A packaging Also 173 410 requires packages transporting Class 7 radioactive materials to meet Subparts A and B of 8173 Therefore in addition to 178 350 the requirements for DOT 7A packagings are given in the following sections of 8173 ER 01 004 Rev 1 Page 3 of 20 Subpart A General Subpart B Preparation of Hazardous Materials for Transportation 173 403 Definitions 173 410 General Design Requirements 173 412 X Additional Design Requirements for Type A Packages 173 415 Authorized Type A Packages 173 465 Type A Packaging Tests The CNS 8 120B is assessed in Section 3 0 below of this report against each the above requirements The requirements of 173 403 ar
270. than 0 95 the container is an acceptable payload 7 18 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Example 4 Activated Waste with Non Fixed Contamination Problem Step 1 Step 2 Step 3 Determine the acceptability of a 100 ft steel secondary container containing activated metal The measured weight of the filled container is 7 100 Ibs the weight of the empty container is 1 100 Ibs The metal is composed of mildly activated steel with non fixed surface contamination The contaminated surface area is estimated to be 500 ft There is one small piece of activated steel with a significantly higher activity Determine whether this smaller item can be included in the shipment and whether it needs to be shored The isotopic activities determined by analysis of samples of the waste are as follows e Most of the steel has similar radiological properties Based on an analysis of the highest activity sample the constituents are 20 Ci of Co 30 Ci of Co and 20 Ci of Mn e The small activated metal item has a mass of 100 g dimensions of 1 x 1 x 24 with an activity of 6 Ci of Co e The non fixed crud contamination level based on the highest activity sample is 50 000 dpm which has been determined to be 50 Fe 30 Cs and 20 Co The contaminated surface area is 500 ft Characterize Source Given in the problem statement Convert Beta Source to Equivalent Gamma Source
271. that which applies for the grout i e 0 950 If the single payload approach is used the y sec g value is set to that which applies for the hottest item the grout so the total fraction for the entire payload would be 0 950 Separating small high source strength density items from the overall payload only helps if those small low mass items are qualified under the y sec limit and not the y sec g limit 7 24 8 120B Safety Analysis Report Consolidated Revision 7 10 11 November 2013 Attachment 2 Determination of Hydrogen Concentration Determine the radionuclide concentration in the contents For any package containing materials with radioactivity concentration not exceeding that for LSA ensure the shipment occurs within 10 days of preparation or within 10 days of venting the secondary container For packages which satisfy the previous conditions go to step 11 otherwise continue with step 2 Determine the secondary package s void volume and the cask cavity void volume Identify the secondary container s vent path if applicable Determine the quantity of hydrogenous contents Determine the G value of the hydrogenous contents per NUREG CR 6673 Section 3 Determine the energy deposition rate in the hydrogenous contents Determine the hydrogen generation rate per NUREG CR 6673 Section 4 2 Determine the effective hydrogen transport rate due to diffusion for the vent path see NUREG CR 6673 Section 4 1
272. the manifolds trunk down into test port Next hand tighten the threaded bushing until it is snug If needed a wrench may be used to tighten the bushing but only turn or less until snug Note Over tightening can cause damage to the test manifolds o ring and the test port threads Use caution and proceed slowly to ensure test manifold bushing is not over tighten 5 1 5 Ensure the Air Regulator Inlet Valve located on the inlet side of the Air Regulator and the Leak Test Supply Valve located on the inlet side of the Test Pressure Gauge are closed Connect the adaptor test manifold to the secondary lid test port Note Use extreme caution when connecting adapter test manifold to test port to prevent damage to test port threads 5 1 6 Set the Air Regulator located on the manifold to 0 psig or OFF and connect the air supply to the manifold Caution A very small volume is being pressurized Use extreme care and do not exceed 20 psig 5 1 7 Slowly open the Air Regulator Inlet Valve Page 6 of 15 Air Pressure Drop Test for 8 120B Cask TR TP 002 Certificate of C onformance USA 9168 B U Revision 20 5 1 8 5 1 10 5 1 11 5 1 12 5 1 13 5 1 14 5 1 15 5 1 16 Slowly open the Leak Test Supply Valve After the Leak Test Supply Valve is open slowly adjust the Air Regulator to obtain 18 psig 1 0 psig on the Test Pressure Gauge Use extreme care so the Test Pressure Gauge is not over pressurized Note Dueto tem
273. the secondary lid bolts will be 83 75 20 15 _ 1502 Ibs m 4 12 According to ASTM specification A 354 the tensile strength for the 2 8UN secondary lid bolts is 415 446 Ibs ER 01 004 Rev 1 Page 13 of 20 The margin of safety is M S 415446 1502 1 275 For the cask body Conservatively assume that the 20 15 psig internal pressure is entirely contained by the inch thick inner shell 20 15 62 PR _ 20 15 72 350 tos longitudinal stress 0 75 in hoop stress z3 aay De Assuming the stresses are additive the maximum stress in the cask inner wall is 1250 The margin of safety is m 1032 These analyses show the cask can safely withstand a reduction of external pressure to 3 6 psi g Each valve other than a pressure relief device is provided with an enclosure to retain any leakage Not applicable There are no valves on the package h Any radiation shield that encloses a component of the packaging specified as part of the containment system will prevent the unintentional escape of that component from the shield The outer shell and lead act as shielding and contain the inner shell which forms part of the containment i Failure of any tie down attachment that is a structural part of the packaging under both normal and accident conditions must not impair the ability of the package to meet other requirements of this subpart Failure of the tie down lugs will be by loc
274. tion 5 1 4 for processing a liner through the secondary lid Page 17 of 41 Handling Procedure for Transport Cask TR OP 035 Warning Model 8 120B C of C Number 9168 Revision 25 5 1 3 1 Remove upper impact limiter and secondary lid thermal shield Follow Steps 5 1 2 1 through 5 1 2 2 2 5 1 3 2 Remove primary cask lid Follow Steps 5 1 2 3 through 5 1 2 3 8 Caution Care should be taken during liner handling operations to prevent damage to cask sealing surfaces 5 1 3 3 Load the liner into the cask As the liner is lowered into the cask the air in the cask will cushion and slow the liner Be alert to the possibility of radiological airborne contamination escaping from the cask during this operation 5 1 3 3 1 Visually inspect the interior of the cask for any defects which may affect the integrity of the cask or shielding provided by the cask Also inspect for loose material or moisture Report any noted defects to EnergySolutions CMF for resolution before proceeding with the cask loading Remove any liquids or foreign materials from the cask cavity Caution Radioactively contaminated liquids may be pumped out or removed by use of an absorbent material Removal of any material from inside the cask shall be performed under the supervision of qualified Health Physics personnel with the necessary H P monitoring and radiological health safety precautions and safeguards 5 1 3 3 2 Inspect and clean if required the externa
275. tions in References 3 1 and 3 2 as applicable That radiation levels conform to requirements as established in Site radiation and contamination release procedures 49 CFR 173 441 and and 10 CFR 71 47 as applicable see References 3 2 and 3 5 That the cask lids and impact limiters are sealed with security seals That all lifting lugs are removed or properly covered for transport RECORDS AND REPORTS The following reports should accompany all loaded shipments and be maintained in accordance with Reference 3 4 or other facility applicable records requirements Shipping papers per 49 CFR Part 172 see Reference 3 1 prepared and certified by Vehicle Radiation Survey prepared and certified by the shipper User Check Off Sheet or equivalent form prepared and signed by the shipper Prior Notification Forms if required Statement that air leak test of cask has been completed 6 1 the shipper 6 2 6 3 see Attachment 7 1 6 4 6 5 State Permit Forms if required 6 6 ATTACHMENTS 7 1 User Check Off Sheet Page 40 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 Attachment 7 1 USER CHECK OFF SHEET Date Shipment Number Waste Identification Operator s HP Technician s Cask ID Serial Number Shipper Driver Time of arrival on site Time of departure from site O S 1 Two independent physical verifications of secondary container s closure system if required
276. to 250 ft lbs 25 ft lbs 7 1 12 2A Re torque using a star pattern the twelve 12 secondary lid bolts lubricated to 500 ft lbs 5 O ft lbs Replace the vent port cap screw and seal if removed and torque to 20 ft lbs 2 ft lbs Leak test the primary lid and secondary lid O rings and the vent port in accordance with Section 8 3 2 2 prior to every shipment If cask has been removed from trailer proceed as follows to return cask to trailer 7 1 15 1 Using suitable lifting equipment lift and position cask into lower impact limiter on trailer in the same orientation as removed 7 1 15 2 Unbolt and remove cask lifting ears 7 1 15 3 Reconnect cask to trailer using tie down equipment Installation of Upper Impact Limiter and Secondary Lid Thermal Shield 7 1 16 1 Using suitable lifting equipment lift inspect for damage and install the secondary lid thermal shield 7 1 16 2 Install the three secondary lid thermal shield retaining pins into the secondary lid lift lugs and insert the ball lock pins into the retaining pins 7 1 16 3 Using suitable lifting equipment lift inspect for damage and install upper impact limiter on cask in the same orientation as removed The pre shipment leak test of the primary lid secondary lid and vent port seals is required before every 8 120B cask shipment even if the lid bolts or vent port socket head cap screw have not been loosened during loading operations This requirement is ne
277. to determine when and whether to hold certain types of information in confidence The application of that system and the substance of that system constitute EnergySolutions policy and provide the rational basis required Under that system information is held in confidence if it falls in one or more of several types the release of which might result in the loss of an existing or potential competitive advantage as follows a The information reveals the distinguishing aspects of a process or component structure tool method etc and the prevention of its use by EnergySolutions competitors without license from EnergySolutions gives EnergySolutions a competitive economic advantage b The information consists of supporting data including test data relative to a process or component structure tool method etc and gives EnergySolutions a competitive economic advantage e g by optimization or improved marketability c The information if used by a competitor would reduce the competitor s expenditure of resources or improve the competitor s advantage in the design manufacture shipment installation assurance of quality or licensing of a similar product Page 2 of 4 iii iv v vi d The information reveals cost or price information production capacities budget levels or commercial strategies of EnergySolutions its customers or suppliers e The information reveals aspects of past p
278. tress 7 1 3 2 Attach cask lifting ears and torque bolts to 200 ft lbs 20 ft lbs lubricated NOTE Thecables used for lifting the cask must have a true angle with respect to the horizontal of not less than 60 7 1 3 3 Using suitable lifting equipment remove cask from trailer and the lower impact limiter and place cask in level loading position NOTE In certain circumstances loading may be accomplished through the secondary lid into a pre positioned waste liner that has been properly shored or into pre positioned shoring while the primary lid remains on the cask Alternate A y steps have been included to accommodate this situation Loosen and remove the twenty 20 bolts which secure the primary lid to cask body Loosen and remove the twelve 12 bolts which secure the secondary lid to the primary lid Inspect the bolts for defects Obtain replacement bolts as specified on the drawing listed in 5 a 3 of the CoC for any bolts that show cracking or other visual signs of distress NOTE The cables used for lifting either lid must have a true angle with respect to the horizontal of not less than 45 Remove primary lid from cask body using suitable lifting equipment Care should be taken during lid handling operations to prevent damage to cask or lid seal surfaces Remove secondary lid from cask body using suitable lifting equipment Care should be taken during lid handling operations to prevent damage
279. tributed resins filters and solidified wastes with no dimensions less than 1 cm Contents with any form of isotope sources or with highly activated fines swarf crud or other particles with less than 1 cm in size are not exempt from this requirement Regarding step 7 1 21 6 a new requirement was added to ensure that the package has received the required periodic leak testing prior to shipment i e Prior to shipping a loaded package confirm that the periodic leak test described in Section 8 3 2 1 has been performed For shipments of powdered radioactive materials confirm that the most recent periodic leak test of the 8 120B cask demonstrated leaktight status Practically this could be accomplished by checking the tag on the package that gives the date on which the latest period leak test was performed and whether or not it was to leaktight standards The applicant claimed that it is not practical for the user to confirm that that the most recent periodic leak test meets the requirements of Section 8 3 2 1 i e confirm the test parameters that were used but only necessary to confirm that the test was performed and whether or not it was to leaktight criteria The staff agreed with that interpretation Based on these findings the staff concludes that the operating procedures both meet the requirements of 10 CFR Part 71 and are adequate to assure the package will be operated in a manner consistent with its evaluation for approval 8 0 ACCE
280. tructed of structural steel and the exterior is primed and painted As discussed in 2 4 1 of the SAR there will be no reactions between the package and contents or between the package components h All valves through which the package contents could escape will be protected against unauthorized operation Not applicable There are no valves in the package i For transport by air 1 The temperature of the accessible surfaces of the package will not exceed 50 C 122 F at an ambient temperature of 38 C 100 F with no account taken for in sulation 2 The integrity of containment will not be impaired if the package is exposed to ambient temperatures ranging from 40 C 40 F to 55 C 131 F and 3 Packages containing liquid contents will be capable of withstanding without leakage an internal pressure that produces a pressure differential of not less than 95 kPa 13 8 Ib in Not applicable 173 412 Additional design requirements for Type A packages In addition to meeting the general design requirements prescribed in 173 410 each Type A packaging must be designed so that a The outside of the packaging incorporates a feature such as a seal that is not readily breakable and that while intact is evidence that the package has not been opened In the case of packages shipped in closed transport vehicles in exclusive use the cargo compartment instead of the individual packages may be sealed Tamper indicating
281. u eV eee tees ate 4 23 Pieure l Cas Model us eae A eee 5 5 Figure 5 2 HAC Cask Model ia 5 6 Figure 5 3 Payload Gamma Source Strength Limit vs Gamma Energy 5 12 Figure 5 5 Payload Qualification Flow Chart eene 5 17 Figure 7 1 Payload Qualification Flow Chart eese 7 13 xiii 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 REVISION CONTROL SHEET TITLE Safety Analysis Report for Model 8 120B Type B Shipping Packaging AFFECTED PAGE S REVISION AND DATE REMARKS As indicated Consolidated Revision 3 July 2012 Approved version Certificate of Compliance Revision 19 As indicated Consolidated Revision 4 May 2013 Submitted to NRC May 2013 with initial amendment request Revision marks indicate changes since Consolidated Revision 3 As indicated Consolidated Revision 5 August 2013 Submitted to NRC August 2013 in response to RAIs Revision marks indicate changes since Consolidated Revision 3 As indicated Consolidated Revision 6 September 2013 Submitted to NRC September 2013 in response to second RAI Revision marks indicate changes since Consolidated Revision 3 1 5 7 1 7 4 7 5 and 8 6 through 8 9 Consolidated Revision 7 November 2013 Submitted to NRC October 2013 to support issuance of Certificate of Compliance Revision 20 Revisio
282. ubmitted by gt ENERGYSOLUTIONS 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 This page intentionally blank 11 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 TABLE OF CONTENTS 1 0 GENERAL INFORMA TION is eekeeesetosa is eno nth ean F ena Rae esae oA PEE VENUES S ERR n RP econo 1 1 I ds introductions iess ted bois atri PEG hd lo o o ect a bout LES DA 1 1 1 27 Package DOSGHIDDUDO Us see os cn ero A a c d Mes 1 1 Dd PACK ARIS oo ee eco gol ep e ee diana dette daten dal dd biens 1 1 1222 Contents or Package ot ies 1 5 1 2 3 special Requirements Por Pluto At 1 6 1 24 Operational Eeatutes i re rh eS e ia 1 6 1 3 Voc T E H H 1 7 2 0 STRUCTURAL EVALUATION ci sccsscccsccssssoesesacssnccopsosssesssoccceseccacenstoccosscosseeddescecsdeceoes 2 1 2 1 Description of Structural Design eese tto tt or enoede v ge tur etat en Masaemssecnsenequanes 2 1 2 1 l Di scusstonz annee e a ee d Ud nde Rhee doi eae 2 1 2 12 A sette tonne tees cto edu i E let Dp och e oti 2 2 2 1 3 Weight and Center of Gravity usse ridad Bee aee peor e ovre gna 2 4 2 1 4 Identification of Codes and Standards for Package Design 2 4 2 2 Mat A E e RI e ed cu ea 2 4 2 2 1 Material Properties and SpecitiCallong zos AS 2 4 2 2 2 Chemical Galvanic and Other Reactor ito ita 2 5 2 2 3 Effects of Radiation on Matera 2 6 2 3 Fabrication and Examination 5 do E de
283. using a test manifold that may be constructed from tubing fittings isolation valves and a pressure gauge Any test apparatus used for this test must have an internal volume with isolation valves closed and the apparatus connected to the test port location of less than or equal to 10 cm to achieve the required test sensitivity for the hold time specified in Section 8 3 2 2 d Note If air is used for the test the air supply should be clean and dry If it is not or if the quality of the air supply is uncertain the test should be performed with nitrogen to ensure reliable results c The test shall be performed using a pressure gauge accurate within 1 or less of full scale d The test pressure shall be applied for at least 15 minutes for the lid or vent port A drop in pressure of greater than 0 1 psig shall be cause for test failure e Sensitivity at the test conditions is equivalent to the prescribed procedure sensitivity of 10 ref cm sec based on dry air at standard conditions as defined in ANSI N14 5 1997 Table 8 2 summarizes pre shipment leak test requirements for the 8 120B Table 8 2 Pre Shipment Leak Test of 8 120B Components Component Hold Time Procedure Connect test manifold to the test port Pressurize void between O rings with the test gas close the isolation valves and hold for the minimum hold time A drop in pressure of greater than the minimum detectable amount shall be cause for test failure Lid 15
284. vember 2013 Attachment 1 Determination of Acceptable Beta and Gamma Source Strength see Chapter 5 for the derivation of the beta and gamma source strength limits Background and Definitions 8 120B contents payloads have acceptable beta and gamma sources when they can be shown to meet the requirements in Table 7 1 using the procedure described in this Attachment Source qualification is based on a sum of fractions method where sources are broken down into separate gamma energy lines and compared to the corresponding limit for that group For some payloads it may be necessary to subdivide the payload into separate items determining fractions for each item by energy group then summing the fractions to determine acceptability Table 7 1 categorizes the limits into source strength y sec and source strength density y sec g For each energy the fraction to be summed is the lowest of the y sec and y sec g fractions Table 7 1 has five columns of limits denoted O through Depending on the nature of the payload the user must select a pair of columns to use for each payload item one y sec column and one y sec g column The general payload columns 0 0 are the most conservative and are suitable for any payload item Higher limits are acceptable for special cases where a reduced volume item is shored about the centroid of the package cavity e g an isotope source These are termed discrete payload items and are distinguish
285. vita qu eie dta ua epatis q nb dus o de duse ao pe qur TR er TEAN S 3 33 Figure 3 18 8 120B Cask Secondary Temperature Contour Plot at the Time When the Secondary Lid Seal Reaches the Peak Value With Thermal Shield 3 34 Figure 3 19 8 120B Cask Secondary Lid with Thermal Shield Damaged FEM 3 35 Figure 3 20 8 120B Cask Secondary Lid Seal Temperature Time History Plot With Thermal A A RO 3 36 xil 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 Figure 3 21 8 120B Cask Secondary Temperature Contour Plot at 5 400 Seconds after the hired alc PME 3 37 Figure 4 1 Allowable He Air Mixture Test Leakage cm sec versus test temperature F 4 13 Figure 4 2 Allowable R 134a Test Leakage cm sec versus Test Temperature F 4 13 Figure 4 3 Allowable R 134a Test Leakage oz yr versus Test Temperature F 4 14 Figure 4 4 Allowable R 134a test leakage sensitivity oz yr versus test temperature F 4 15 Figure 4 5 Allowable R 134a Air Mixture Test Leakage cm sec versus test temperature F 4 17 Figure 4 6 Allowable He Test Leakage cm sec versus test temperature F 4 18 Figure 4 7 Allowable helium test leakage sensitivity cm sec versus test temperature F 4 19 Figure 4 8 Periodic Leak Test of Closure Lidia 4 23 Figure 4 9 Periodic Leak Test of Vent PO one ep
286. when they do not pass all statistical checks the results are questioned and evaluated as described below ES NRC 13 017 Enclosure 1 Docket No 71 9168 Responses to Request for Additional Information Relative Error Levels Table 2 4 from the MCNP User s Manual see below describes the tally quality associated with different ranges of relative error Tallies with high relative errors are disregarded if there is good reason to neglect them e g not an area of interest If there is no justification to disregard them the model is corrected and re run Table 2 4 Guidelines for Interpreting the Relative Error R Range of R Quality of the Tally 0 5 to 1 Garbage 0 2 to 0 5 Factor of a few 0 1 to 0 2 Questionable 0 10 Generally reliable except for point detector 0 05 Generally reliable for point detector R S X and represents the estimated statistical relative error at the 10 level These interpretations of R assume that all portions of the problem phase space have been well sampled by the Monte Carlo process Please use statistical checks for detailed information All of the dose rate results presented in the NU 391 shielding calculation are calculated using area detectors as opposed to point or ring detectors Thus results with relative error levels under 0 1 are generally reliable Results with MCNP output relative error levels over 0 1 are examined to determine if they have any potential to affect the conc
287. within the soil since the single payload approach will use the higher source strength density y sec g of the grout in the qualification Grout Payload Item The grout gamma source strength is 350 Ci ft 1 ft 100 Ib 9 000 Ib 0 05 3 7E 10 d sec Ci 0 85 y d 4 95E 13 y sec Dividing by the mass 450 Ib or 2 04E 05 g the source strength density would be 2 43E 08 y sec g ayload Source Term y sec y secig 4 95E 13 2 43E 0 7 22 8 120B Safety Analysis Report Consolidated Revision 7 Step 4 Steps 5 7 November 2013 Soil Payload Item The soil gamma source strength is 10 i ft 1 ft 100 Ib 9 000 Ib 0 95 3 7E 10 d sec C1 0 85 y d 2 2 69E 13 y sec Dividing by the mass 8550 Ib or 3 88E 06 g the source strength density would be 6 93E 06 y sec g Energy Payload Source Term MeV or Cs 137 2 69E 13 6 93E 06 Combined Grout Soil Payload Item If the payload is treated as a single item the y sec is set equal to the sum of the y sec for both the grout and soil components The y sec g is set equal to that of the hottest component i e the grout Thus the gamma source strength would be 5 66E 13 y sec 4 95E 13 2 69E 13 The y sec g equals the 2 43E 08 value that applies for the grout y secig 2 43E 0 Select the Limits Since none of these payload items meets the definition of either of the two discrete shored configurations 2 5 ft or 55 gal they are general type pay
288. would not significantly increase the damage to the specimen The analyses performed was for a drop onto an essentially unyielding surface as specified in Section 2 6 6 in the SAR d Stacking test 1 The specimen must be subjected for a period of at least 24 hours to a compres sive load equivalent to the greater of the following 1 Five times the mass of the actual package or ii The equivalent of 13 kilopascals 1 9 pounds per square inch multiplied by the vertically projected area of the package 2 The compressive load must be applied uniformly to two opposite sides of the specimen one of which must be the base on which the package would normally rest Case i above 5 times package wt 5 x 74 000 Ibs 370 000 lbs Case ii above 1 9 Ibs in x vertically projected area 1 9 Ib in x 87 5 in x 73 5 in 12 219 lbs Case i is more severe Analyze the cask as a beam with the uniform load of 370 000 lbs applied along the axial length of the wall assume simple end supports The outer shell is fabricated from 880m A m A516 for conservatism assume y j vum ad si M E where F 32 000 psi a ili 1 5 in 7 MC b 1 M 5x M G4 000 88 24 07 x 108 in Ibs 77 ZZ e cee EU in 77777 LE e a CNS 8 1208 Package I x d d 04906 73 2 70 2 2 17 x 10 in ER 01 002 Rev 1 Page 14 of 15 Therefore _ 4 07 x10 in Ib 39in _ 732 psi which yields th
289. wrenches and open end wrench set Page 5 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 4 2 4 Lifting sling compatible with cask lids filled liner and loaded drum pallets 4 2 5 Acceptable bolt lubricant Moly Z Neolube or Anti Seize 4 2 6 Health Physics HP instrumentation and support materials 4 2 8 120B cask O Rings O ring seals 4 2 8 Vacuum grease for example Parker Super O Lube or petroleum jelly 4 3 Handling Precautions Warning If the lid or vent port o rings require replacement the cask will need to be unloaded and shipped back to the EnergySolutions Cask Maintenance Facility CMF for o ring replacement and maintenance leak testing 4 3 1 4 3 2 Treat the inside of the cask the bottom of the cask lids and any materials removed as potentially radiologically contaminated DO NOT attempt to lift the cask by the lifting lugs on the impact limiter primary cask lid or secondary cask lid Caution The cask must be lifted using the two 2 diametrically opposed 4 3 3 4 3 4 4 3 5 4 3 6 4 3 7 primary lifting lugs that are bolted onto the cask body Items 41 42 and 43 of Reference 3 8 The optional redundant lifting lugs may also be used to lift the cask body if required Survey the cask cavity for radiation and radiological contamination levels after the cask contents have been removed Decontaminate as required by the Health Physics D
290. y be performed after primary lid is replaced on cask body Refer to Steps 5 1 4 2 1 through 5 1 4 2 8 for secondary lid removal After lid removal refer to Steps 5 1 4 4 1 through 5 1 4 4 13 for replacement of secondary lid Page 36 of 41 Handling Procedure for Transport Cask TR OP 035 Model 8 120B C of C Number 9168 Revision 25 5 5 3 1 Note 5 5 3 2 Warning 5 5 3 3 5 5 3 4 Caution 5 5 3 5 Attach the crane hook to the three 3 lifting lugs on the primary lid The cables used to lift the primary lid must have a true angle of not less than 45 with respect to the horizontal The primary lid O Ring seals shall be visually inspected for serviceability ensuring that they are in the proper position and free of cracks tears cuts or discontinuities which may prevent them from sealing properly The seal seating surface shall be visually inspected to ensure that they are free of damage debris gravel or any foreign matter which might damage the seals or prevent the seals from properly sealing If any defects are detected that may prevent the seals from forming a seal contact EnergySolutions CMF Inspect and clean the O Ring seating surfaces A very thin coat of vacuum grease or petroleum jelly should be applied to the sealing surface of the O Ring prior to installing and torquing the lid Inspect the air test annulus and leak test port to assure that they are free of foreign materials i e silicone vacuum grease p
291. y lid lifting lugs using appropriate lifting hardware The cables used to lift the secondary lid must have a true angle of not less than 45 with respect to the horizontal Care should be taken during handling operation to prevent damage to cask sealing surfaces Slowly remove secondary lid from cask and place it on absorbent material or plastic sheeting if required Treat the underside of the lid the inside surfaces of cask and any bolts or seals removed as potentially radiologically contaminated Page 20 of 41 Handling Procedure for Transport Cask Model 8 120B C of C Number 9168 5 1 4 3 5 1 4 4 Note 5 1 4 5 5 1 4 2 6 3 1 2E 2 7 5 1 4 2 8 TR OP 035 Revision 25 Visually inspect the secondary lid bolts for defects and obtain replacement bolts from EnergySolutions CMF for any lid bolts that show cracking or other visual defects Lubricate bolt threads if required Visually inspect lid bolt holes for damage defects and accumulation of debris Remove debris if required Contact EnergySolutions CMF for any bolt holes that show signs of cracking or visual signs of distress Visually inspect and clean the O Ring seating surfaces Process liner as necessary and cap using standard capping devices Perform two independent physical verifications of the liner s closure system to ensure that it is properly closed and secured Record the compliance of this step in attachment 7 1 step 1 This r
292. y magnetic particle examination MT with acceptance requirements of ASME Code Section III Division I Subsection ND Article ND 5340 or NF Article NF 5340 Inspection shall be before and after 150 load test STRUCTURAL AND PRESSURE TESTS A pressure test of the containment system will be performed as required by 10CFR71 85 As determined in Section 3 4 4 the maximum normal operating pressure for the cask cavity is 35 psig therefore the minimum test pressure will be 1 5 x 35 2 52 5 psig The hydrostatic test pressure will be held for a minimum of 10 minutes prior to initiation of any examinations Following the 10 minute hold time the cask body lid and lid body closure shall be examined for leakage Any leaks except from temporary connections will be remedied and the test and inspection will be repeated After depressurization and draining the cask cavity and seal areas 8 3 8 120B Safety Analysis Report Consolidated Revision 7 November 2013 will be visually inspected for cracks and deformation Any cracks or deformation will be remedied and the test and inspection will be repeated 8 2 4 LEAKAGE TESTS 8 2 4 1 General requirements e Testing method Per ANSI N 14 5 in accordance with ASTM E 427 if using a halogen leak detector or ASTM E 499 if using a helium leak detector e Test Sensitivity the test method must be capable of meeting the appropriate sensitivity requirements specified in Figures 4 4 or 4 7 in Section 4 0

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