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