ML19309G489
| ML19309G489 | |
| Person / Time | |
|---|---|
| Site: | 07109136 |
| Issue date: | 03/31/1980 |
| From: | Cunningham G GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML19309G490 | List: |
| References | |
| 15932, NUDOCS 8005070041 | |
| Download: ML19309G489 (9) | |
Text
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ENGINEERING GENEPAL ELECTRIC COVPANY P.O. BOX 460, PLEASANTON, CALIFORNIA 94566 DIVISION Re: Docket No. 71-9136 March 31, 1980 Mr. Charles E. MacDonald, Chief Transportation Branch U.S. Nuclear Regulatory Commission Washinaton, D.C.
20555
Dear Mr. MacDonald:
General Electric is deactivating its Fuels Laboratory at the Vallecitos Nuclear Center under SNM-960. The deactivation involves the transportation of decontani-nated clove boxes / hoods and equipment for disposal and/or retrievable storage.
General Electric hereby supersedes its applications dated September 27, 1979 and December 14, 1979 and requests certification or other authorization to use the G.E. Model 9136 packaaing, described and evaluated in Attachment A hereto, for the transport of approximately 30 packages, each containing a hood or glove box constitutina low-level solid radioactive material (LLS) as defined in Section 71(g)(2) of the proposed revision to 10CFR Part 71 of August 17, 1979.
i The request for exemption is filed at this time because of the uncertainty of the future date at which the proposed Part 71 amendments will become effec-tive and because of our urgent need to apply the new standards for the glove box shipments to meet G.E. commitments to the U.S. Department of Energy for deacti-vation of the Fuels Laboratory.
The new LLS classification is similar to the present " low specific activity" (LSA) material, except that the LLS concept permits more radioactive material in the contents of a package while imposing greater restrictions on the dispers-ibility and on the permissible method of shipment, i.e.,
exclusive use of vehicle.
We understand that no substantive objections have been raised in public comments regarding the LLS classification.
As stated in introducing the August 17,1979 Part 71 proposed revisions, "al-thouah substantive chances are proposed in order to provide a more uniform degree of safety for various types of shipments, the Commission's basic stan-dards for radioactive packaging would remain unchanged."
A check for $6,900.00 for application and approval fees enclosed in the Septem-ber 27, 1979 reouest for certification may be used for authorizations pursuant to this revised application.
1503.0 -
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GENERAL @ ELECTRIC Mr. Charles E. MacDonald Page 2 As you are aware, G.E.
has received the views of your st af f on a previous packacing desian for this service.
In response to those views, we have prepared and succ:csfully tested a substantially improved packaging.
We therefore urge your personal attention to the prompt evaluation of this application. An early authorizatian will enable retention of the current operating staff averaging 1
over five years of experience in the laboratory. To attempt the decontamination work at some future time with a new, inexperienced crew would not be in-the best interests of public health and safety.
Yours very truly, hbf G. E. Cunninanam Senior Licensing Enaineer Attachments (2) t j
3 e
ATTACHMENT A Introduction The G.E. Model 9136 is described and evaluated as required by 10 CFR Part 71, as follows:
71.22 'Packaae Description (a) General The package consists of a right rectangular box 120.5" wide X 86" hiah X 65.75" deep constructed of 3/4" 5-ply ACX external plywood over 2" X 4" wooden framework on a plywood covered 2" X 12" wooden plank base and fitted with 4" X 4" interior beam and column supports and external skids. The closure is of the same construc-tion and all parts are secured by means of bolts, screw nails and weather resistant adhesive. The packaging is shown on G.E. drawings 908E615, Rev. 1 and 908E617, Rev. 1.
(1)
Gross weicht (heaviest package):
3700 pounds (2)
Model Number:
G.E. Model 9136 (3)
==
Description:==
(i)
The contents to be transported will be limited to low level solids (LLS) as defined in 10 CFR 71.4(g)(2) proposed.
Specifically the LLS objects will be in the form of glove boxes or hoods constructed of stainless steel, the interiors of which are painted to opacity.
Glove boxes and hoods have windows of self-extinguishing (SE) plexialass. Glove boxes are provided with glove and bag ports. The gloves are 0.015" thick Hypalon and bags are 0.012" polyvinylchloride. Gloves and bags remain in place during shipment but the ports are covered with 1/4" plywood protective plate prior to packaging for shipment. The heaviest and largest glove box or hood is 1875 pounds and its dimensions are 73" X 57" X 112".
(ii) Neutron absorbers are not required.
(iii) Internal Support Structures The contents of the package (glove box or hood) are restrained in the outer packaging (box) with four 1/4" stranded type wire ropes that cross over the glove box or hood and are secured to 1/2" steel eye bolts that penetrate the floor of the box. The wire rope is tightened with 1/2" steel turnbuckles. The eye bolts are secured to the underside of the floor through l
3
. 71.22 (Continued)
(iii) (Continued) 1/4" thick by 4" X 4" steel plates. The holes in the floor for eye bolts are slightly undersized to provide a tight fit and the holes are filled with RTV, (silicon rubber mastic) before eye bolts are inserted, to maintain packaging integrity. Additional cribbing may be cut to fit and applied to the packaging provided the maximum gross weight is not exceeded.
(iv) There are no valves, sampling ports, lif ting devices or tie-down devices.
(v)
There is no requirement to dissipate heat because the quantity of radioactive material is thermally insig-nificant.
(4)
The package uses no coolant.
(b) Package Contents (1)
Radioactive constituents are plutonium and uranium, fixed on the interior surfaces of the glove box or hood. The maximum 2
2 radioactivity is < 2uci/cm averaged over 1 m. The interior surf ace area of the largest glove box is approximately 20 square meters.
(2)
All radioactive contents are < 1 gram fissile.
(3)
Solid residues of plutonium-uranium precipitates, salts and oxides constituting low level solids as defined in 71.4(g)(2).
(4)
Non-fissile neutron absorbers are not required.
(5)
Maximum weight of the heaviest contained glove box or hood is 1,875 pounds.
(6)
There is insionificant decay heat.
71.23 Packaoe Evaluation The description under 71.35 b'elow demonstrates that the package satisfies the standards in Subpart C.
A determination of fissile classification is not applicable.
71.24 Ouality Assurance (a) Design, f abrication and testing were performed under specific written quality assurance plan QAPl.
.M 71.24 (Continued)
(b) Codes and standards used in fabrication are referenced on G.E.
Drawinas 908E615, Rev. 1 and 908E617, Rev. 1.
Assembly of each pacFage will be assured for quality by independent inspection to the requirements of QAPl. No packaging will be reused; refurbishing quality assurance is therefore unnecessary.
(c) There are no specific provisions to be contained in the quality assurance program which are applicable to the particular package design under consideration.
71.31 (a) Packaging materials of construction produce no chemical, galvanic or other reaction between packaging components or components and packaging contents.
(b) Packaging cle. Jre is effected by gluing, nailing, and bolting the packaae lid to the package body. The completed packaae is covered with a Fiberglas coating and the package cannot be inadvertently opened.
(c) There are no lifting devices.
(d) There are no tie-down devices.
71.32 Structural standards for Type B and large quantity packaging Not applicable 71.33 Not applicable - exempted by Paragraph 71.9(a).
71.34 Evaluation of a Sinale Packaae (a)
(1)
The package was evaluated to withstand conditions likely to occur in normal transport by subjecting a full-sized sample package to the conditions specified in Appendix A to Part 71 and by other assessment. That evaluation is described in 71.35 below.
(2)
Not applicable.
(b) The shipment is evaluated without the transporting vehicle.
(c) All conditions ref normal transport set forth in Paragraph 71.35 were used in evaluating the package.
71.35 Packeae Evaluation (a) The G.E. Model 9136 is designed specifically and solely as a single trip package (thus each packaging will be new) consisting of its content, a glove box or fume hood, supported in all directions within an outer wooden container designed and constructed to survive the environment and rough handling tests of Appendix A to Part 71.
The residual radioactive contamination is extremely low level 2
(1 2 pci/cm ), isolated within a previously decontaminated hood or glove box, and further immobilized by bonding to the inner surf aces with paint *. This hood or glove box, in effect, is a receptacle or containment device which in turn is carried within a secondary outer wooden container which remains closed under all Appendix A conditions.
It is clear therefore, there will be no release of radioactive material and the effectiveness of the packaging will not be sub-stantially reduced. The bases for this evaluation are set forth in the following treatment of the package under Appendix A conditions.
1.
Heat The outer container is constructed of wood and either painted or coated with Fiberglas. There are no materials on which the structure depends that would be adversely affected by prolonged temperatures up to 130*F.
2.
Cold Similarly, the wooden container is unaffected by extremely cold temperature.
Mr. William James of the Forest Products Service of the U.S. Department of Agriculture, Madison, Wisconsin (608-264-5708) was contacted regarding the Department's tests of structural properties of wood at low temperatures, i.e., -20F and lower.
Mr. James confirmed that, in general properties of toughness, shock resistance, and energy absorption have been determined by " pendulum testing" to increase as temperatt.re is descreased from ambient.
- A metal test specimen was spray painted with Rust-Oleum #964 after the thickness of the bare metal was measured. The paint was applied only until an opaque layer was formed. After drying, the thickness of the specimen was again measured to determine the thickness of the paint requited to produce an opaque coating. That thickness is 0.004" and will be used as the criteria for application of paint to the interiors of decontaminated glove boxes and hoods.
The metal specimen was bent into a semicircle with an approximate 5" radius. No spalling or cracking of the painted surf aca was observed.
i I
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, 71.35 (Continued) 3.
Pressure Since the size and weight of the package precludes consider-ation of air transport, the package is not likely to encounter pressures lower than about 0.8 of an atmosphere. Nevertheless, both the contents and the outer wooden container will allow enoug'n slow diffusion of air molecules to preclude any possibility of a sudden rupture of a seam or joint.
4 Vibration The contents are of welded steel and therefore. unaffected by vibration. The six f aces of the outer wooden box are joined with screw nails, bolts and glue providing structural strength superior to crates used commonly for transport of heavy motors and industrial machinery.
5.
Water Spray A sanple package was prepared for the water spray, free drcp and penetration tests. The test package included a typical, although non-contaminated glove box prepared as follows:
Since the heaviest piece of equipment to be shipped is 1875 pounds, approximately 680 pounds of sheet lead ballast was installed and rigidly fixed to the interior of the glove box to approximate the weight of the heaviest glove box.
Windows with glove ports were installed after the lead ballast was fixed in place and all gasket material was caulked on the inside and outside surf aces. All caulking material was sprayed with the red enamel paint. The windows and glove ports were covered with 1/4" plywood.
The window covers were fixed to the glove box by steel banding straps and the glove port covers with masking tape.
The glove box was centered within the packaging and anchored to the floor with four 1/4" diameter wire cables crossed over the glove box and attached to eight eyebolts mounted in the floor of the packaging.
The glove box was not fixed or restrained by the cribbing support beams and columns of the outer wooden container, but only by the cables tightened by turnbuckles to absorb the energy on impact during the free f all.
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4.
71.35 (Continued)
The closure (lid), f abricated and reinforced in the same manner as the sides and top of the packaging, was installed and sealed by gluing the lid flange edge to the front framework of the packaging and f astened by bolts and screw nails. Four garden hoses sprayed water uniformly over the sides and top for an hour, producing over 5 inches of water. There were no visible signs of distortion nor other adverse effects.
6.
Free Drop Since the heaviest package will be less than 10,000 pounds, the test drop was designed so that one corner was four (4) feet above the pad to receive all of the initial impact. Also, since this corner included the lid, it is considered to be the area here the maximum impact damage would occur.
Thus oriented, the assembled package was lifted to the four foot elevation, quick-released and dropped. The test was photographed in video, motion. picture and stills.
Upon impact, the package sustained relatively minor damage at the corner of impact and no opening in any part of the entire structure could be found by visual inspection.
After the box lid was removed by sawing around the edge of the lid, but inside the seal surfaces between the lid and the package frame, no visual evidence of any struc-tural damage was visible within the package at the corner of impact or in any other area. No interior seals sustained damage nor had any water penetrated the seals. The packaging structure withstood the impact with no observed damage that would reduce the effec-tiveness of the packaging.
Visual inspection of the glove box showed that the wire cables and eye bolts had absorbed the energy due to impact.
The glove box shifted in ttie direction of impact by 5".
The glove box shifted tight against the downside eye bolts and corners were dented by impact with the two eye bolts.
A small spot ( = 1/2" square area) where impact with one of the eye bolts occurred was chipped in the glove box interior. All other painted surf aces were intact.
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71.35 (Continued)
No other visible damage had occurred to the glove box. The integrity of bag port, glove port and window seals was maintained.
Some moisture was observed at the impacted end of the packaging and inside the glove box, but later inspection revealed it had entered through a knot in the plywood which had not been thorouchly caulked.
7.
Corner Drop Not required. Exceeds 110 pounds.
8.
Penetration Test The packaging was penetration tested by impacting the hemi-spherical end of a vertical cylinder 1-1/4 inches in diameter and weighing 13 pounds, dropped from a height of 40 inches onto the most vulnerable area of the top of the packaging.
There was a very slight indentation of the surf ace but there was no puncture or other damage of significance.
9.
Compression - 5 times the Weight of the Package Applied Uniformly Acainst the Top and Bottom of the Package A structural analysis was conducted on the package with a uniform load of 2.5 psi applied against the top in the position in which the package normally would be transported.
Horizontal 4" x 4" wood beams and 4" X 4" wood columns were installed within the package to provide support to the top side of the package (see Dwg. 908E617, Rev. 1).
Analyses were made without the glove box providing support to the top side.
Maximum spacing of the support is 29" and the packaging top transmits load through the columns to the heavy (2"X12" planking) wood support base.
Stress on the beams, columns and plywood f ace are well j
within the allowable unit stress on the wood - Douglas Fir.
See Attachment B, " Stress Evaluation of Model 9136, G.E. Dwg.
908E615, Rev.1" for details and calculations.
71.35 (a), (b) and 71.36-71.41 Not applicable to this LLS package.
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