SAFETY ANALYSIS REPORT OP-100 PACKAGE

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SAFETY ANALYSIS REPORT OP-100 PACKAGE Docket No. 71-9185 Revision 6 October 2018 Industrial Nuclear Company, Inc. 14320 Wicks Blvd. San Leandro, California 94577 (510) 352-6767

Transcript of SAFETY ANALYSIS REPORT OP-100 PACKAGE

Page 1: SAFETY ANALYSIS REPORT OP-100 PACKAGE

SAFETY ANALYSIS REPORT

OP-100 PACKAGE

Docket No. 71-9185 Revision 6

October 2018

Industrial Nuclear Company, Inc. 14320 Wicks Blvd.

San Leandro, California 94577 (510) 352-6767

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INC OP-100 Package Safety Analysis Report

TABLE OF CONTENTS

Docket No. 71-9185 Revision 6, 10/2018

1.0 General Information .......... .. ..... .......... ... ..... ...... .... ..... .. ...... ...... ... ............... ...... ..... ............... 1

1.1 Introduction ....... .. .. .. .......... ...... .... .. ........ .... .... ... ........ ......... .... ...... ........ ... .... ...... .. ............. 1

1.2 Package Description .......... ... .......... ........ ... .... ... ........... .... .. ....... ... .................................... 1

1.2.1 Packaging ......................................................................................... ... ....................... 1

1.2.2 Contents of Packaging .. ...... .. ...... ........ ......... .......... .. ... ..... ....... ............. .. ...... .... .......... 2

1.2.3 Special Requirements for Plutonium ......... .... ............... ..... ........ ..... ......... ......... .... .... . 2

1.2.4 Operational Features ................................................ ...... ............................................ 2

1.3 Appendices .............. ...... .............. .......... ... ...... ... ........ .......... .... .................. .. ... .. ............... 6

1.3. l General Arrangement Drawings ................................................................................ 6

2.0 Structural Evaluation .. ... ..... ..... ....... .. ........ ........ .. ........... .... ... ..... ........ ..... ...... .................... 13

2.1 Description of Structural Design .................. ... ...................... ..... .............. ... .. ........ ....... 13

2.1. l Discussion .. .... .... .......... ....................... .. ........ ............... .. .................... .. .... ... .. ........... 13

2.1.2 Design Criteria .. ..... ................ ................. .. ............... ...... .... ....... ..... .............. .......... .. 16

2.1.3 Weights and Center of Gravity .......... .... ... ..... .. .... .. ... ............................................... 17

2.2 Materials ........ ...... ....... .. ........ ... ..... ... ........... .. ...................................................... ...... .... 17

2.2.1 Material Properties and Specifications .. ..................... .... ............... .... .. ...... .... ....... .. . 17

2.2.2 Chemical and Galvanic Reactions ............................................. .. ............. .............. . 17

2.2.3 Effects of Radiation on Materials .................. .......................................................... 17

2.3 Fabrication and Examination ........................................................................................ 18

2.3 .l Fabrication ............................................................................................................... 18

2.3 .2 Examination ....... ............. ..... ... ............. .. .... ......................................... .. ........... ..... ... 18

2.4 General Requirements for All Packages ... .. ....... ..................................................... .. .... 18

2.4.1 Minimum Package Size ........ .. ................... .... ... .. ........ ... ........ .......... .... ... .. .............. . 18

2.4.2 Tamper Indicating Device ...... .. ..... ................... .... ... ............. .... ................................ 18

2.4.3 Positive Closure .................... ... ......... ... .......................... .. .......... .. ..... ............... ........ 19

2.4.4 Valves ............................................................................. ....... .... .. ........ .... ... ...... .... ... 19

2.4.5 Package Design ............. .................................................... ........ .... .. ................ .... ..... 19

2.4.6 External Temperatures ....... ............ ................... ..... ........... ... ... ..... .. ........... ............ .. . 19

2.4.7 Venting ....................... .. .. .. .... .. ................... .... ........... ...... .................. .... ......... ........... 19

2.5 Lifting and Tie-down Devices for All Packages ... ... ........ .... .................................. .. .... . 19

2.5.1 Lifting Devices ..................... .. ........... ..................... .. .... .. ... ............. ....... ....... .. .......... 19

2.5.2 Tie-Down Devices ............................ .................... .. ..... .. ... ..... ... ....... ............ ........ .... 19

2.6 Normal Conditions of Transport .. ............... ..... ... ......... ........ .. ....... ................................ 20

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INC OP-100 Package Safety Analysis Report Docket No. 71-9185 Revision 6, 10/2018

2.6.1 Heat .. ..... .. ............ .......... .................... .. .................... .... .... .. ... ............................... .. ... 20

2.6.2 Cold .......................................................................................................................... 20

2.6.3 Reduced External Pressure ... ............. ........ ................... ........... ....... ............ ............. 20

2.6.4 Increased External Pressure .............................. ...................................................... . 20

2.6.5 Vibration .................................................................................................................. 20

2.6.6 Water Spray .. ........... ... ....... ................... .. ............ .... .......... ......... .............. ... ............. 20

2.6.7 Free Drop ........ .. ......... ... .................... .. ............. .............. ........ .......... .. ......... .... ......... 20

2.6.8 Comer Drop ............................................................................................................. 21

2.6.9 Compression ........ ............... ... ..................................................................... .... ......... 21

2.6.10 Penetration ............................................................................................................... 21

2.7 Hypothetical Accident Conditions ....... ... ........... .... ......... .. .. .................................. ....... . 21

2.7.1 Free Drop ................................................................................................................. 21

2. 7 .2 Crush ............. ................... .. ......... ..................... .... ... .. ........... ..... .................... ........... 23

2.7.3 Puncture .... ....... ....... .................................... ...... .................... ................................... 23

2. 7 .4 Thermal ............................................................................................... ..... ................ 28

2.7.5 Immersion- Fissile .................................................................................................. 28

2.7.6 Immersion -All Packages ....................................................................................... 28

2.7.7 Deep Water Immersion Test (for Type B Packages Containing More than 105 A2)28

2.7.8 Summary of Damage ........................ ........ ....... ............ ....... ............ ........ ................. 29

2.8 Accident Conditions for Air transport of Plutonium ........... .... ..... ................................ 29

2.9 Accident Conditions for Fissile Material Packages for Air Transport ......................... 29

2.10 Special Form Certification ............................................................................................ 29

2.11 Fuel Rods ................ ................ ..... .... ...................... .. ............ .... ............................ .. ....... 29

2.12 Appendix ....................................................................................................................... 30

2.12. l Certification Tests ......................... ....... ... .. ... .................... .. ...................................... 31

2.12.2 Supplementary Certification Tests ......................... ... ............................................... 72

3.0 Thermal Evaluation ................ .... ... ... .. .................................................. .. ............ ............... 89

3.1 Description of Thermal Design ................. ............................ ......... ..... .......................... 89

3.1 .1 DesignFeatures ......................... ... .. ..... ....... ............. ........ ...... .................. ....... .......... 89

3 .1.2 Content's Decay Heat .............................................................................................. 89

3.1.3 Summary Tables of Temperatures ........................................................................... 89

3.1.4 Summary Tables of Maximum Pressures ................................................... .. ........... 89

3 .2 Material Properties and Component Specifications .............................. ........................ 89

3.2.1 Material Properties ................................................................................................... 89

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3.2.2 Component Specifications ..... .. ......... .. ....... .... ..... .. ....... .... .. .. ....... .......... ............... .... 90

3.3 Thermal Evaluation under Normal Conditions of Transport .. ...... ...................... .......... 90

3.3.l Heat and Cold .... ...... ....... ................ .... ................................... ... ............................... 90

3.3.2 Maximum Normal Operating Pressure .................................................................... 90

3.3.3 Maximum Thermal Stresses ............. .. .... .... .............. ........ ... ............ .............. .......... 90

3.3.4 Evaluation of Package Performance for Normal Conditions of Transport .............. 91

3 .4 Thermal Evaluation under Hypothetical Accident Conditions ....... .... .... .. .... ..... ........... 91

3.4.1 Initial Conditions .. .... ...................................... .... ........... ........... .... ........ .. ....... .......... 91

3.4.2

3.4.3

3.4.4

3.4.5

3.5

Fire Test Conditions ................ ......... ......... ............... ...... ... .... ...... ... .. ..................... ... 91

Maximum Temperatures and Pressures ................................. ... .............. .. ........ ..... .. 91

Maximum Thermal Stresses ...................................... ...... ........................................ 92

Accident Conditions for Fissile Material Packages for Air Transport .................... 92

Appendix .. ....................... .... ....... ....... ............................................................................ 93

3.5.1 Determination of Maximum Surface Temperature for OP-100 Package ................ 93

4.0 Containment ... .. ................... ... ... .. ...... .. ....... ..... ...... .......................................................... 101

5.0 Shielding Evaluation ......... ........................................... .... ............. ....... .... ..... ... ............... 102

5 .1 Description of Shielding Design ................................. ............. ........ .. .. .......... ............. 102

5 .1.1 Design Features ......... .. ... .. .................... .. ...................................................... ...... .... 102

5.1.2 Summary Table of Maximum Radiation Levels .......................................... .......... 102

5 .2 Source Specification ........... .... .... ........ ....... ..... ....... .... ... ................... ........................... 102

5.2.1 Gamma Source ....................................................................................................... 102

5.2.2 Neutron Source ......... ............................................................................................. 103

5 .3 Shielding Model .......... .......................................................... .. .. ............ ...................... 103

5.4 Shielding Evaluation ................................................................................................... 103

5.4.1 Methods ...... .... .............. ...... ...... ....... ............. .......................................................... 103

5.4.2 Input and Output Data ......... ... ................................................................ .............. .. 103

5.4.3 Flux-to-Dose-Rate Conversions ............. ............................................................ .... 103

5.4.4 External Radiation Levels ........ .. .. .................. .... .. ........ ........ .. ................................ 103

6.0 Criticality Evaluation ............ ..... .... .......... ........... ... ......................................................... 104

7.0 Package Operations ............ .... .. .. ..... .... .. ........ ..... .. .... ............ ............... .. ..................... .... . 105

7 .1 Package Loading ..... ..... ......... ... .............. .. ............ ............................ ........ ... ........ .... .. .. 105

7 .1.1 Preparation of the OP-100 Package for Loading ......................................... .... ...... 105

7.1.2 Loading the Special Form Payload into the IR-1 OO/IR-50 ...... ... ......... ... ..... .......... 105

7 .1.3 Preparation for Transport ........ ......... .... ........... .... .. .. .. ... .. ............................. ........... 106

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7 .2 Package Unloading ............... ...... ................... ... ............................ ..... .... .. ...... .... ... ...... 107

7.2.l Receipt of Package from Carrier .. ...................... .................... .. ..... ........... ... .... ....... 107

7.2.2 Removal of Contents from the OP-100 Package ................................................... 107

7 .2.3 Final Package Preparations for Transport of Unloaded OP-100 Package ......... .... 107

7 .3 Preparation of an Empty Package for Transport ......... ...... ...... .. ............ .... .. .. ... ........... 108

8.0 Acceptance Tests and Maintenance Program .. ..... .... .......... ....... ....... ............................. . 109

8 .1 Acceptance Tests .......... .............. .. ... ............ .......... ........... ... .. ..... ....... ......... .... ......... ... 109

8 .1.1 Visual Inspections and Measurements .... .... .... .. ...... .. ... ... ....... .... ....... .... .. ............... 109

8.1.2 Weld Examinations ...... .... ......... ....... ........ .......... .... ....... .................... ... .................. 109

8.1.3

8.1.4

8.1.5

8.1.6

8.1.7

8.1 .8

8.2

8.2.1

8.2.2

8.2.3

8.2.4

8.2.5

Structural and Pressure Tests ................................. .................. ........ .. .................... 109

Leakage Tests ............................. ........ .................................................................... 109

Component and Material Tests .......... .. ...... ............ .......... ........ .. .... ........................ 109

Shielding Tests .. ........ .. ... ......... ...... .... ........ .. ......... .. ........... .... ........... ........ .. ............ 109

Thermal Tests ........ ...... ...... .... ......... ................... .... ...... ... ... ........ ...... .... ...... ..... ..... ... 110

Miscellaneous Tests ... ..... ............ ...... .. ................. .. ........ ..... ..... ..... .... ............ .. ..... .. 110

Maintenance Program ............. .. ........ .. ... ... .. ................................................................ 110

Structural and Pressure Tests ....................................... ... ....... .... ...... .. ... ... ..... ......... 110

Leakage Tests .. ... ... ..... ........... .. .................................. ..... .. ... ... ................................ 110

Component and Material Tests .. ................... .... ........................... .. ........................ 110

Thermal Tests .... ...... .... ........... ...... .. ...................................... ........ ...... .. ......... .... ..... 110

Miscellaneous Tests - Shielding ........... ....... ...... ...................... .............................. 110

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INC OP-100 Package Safety Analysis Report

1.0 GENERAL INFORMATION

Docket No. 71-9185 Revision 6, 10/2018

This chapter of the OP-100 Package Safety Analysis Report presents a general introduction and description of the OP-100 Package. A detailed description of the major packaging and payload components is presented in the following sections. Detailed drawings are presented in Appendix 1.3 .1, General Arrangement Drawings.

1.1 Introduction

The Industrial Nuclear Co. (INC) Model OP-100 package consists of a 10-gallon steel drum, which houses either a plywood or polyurethane foam support structure, and either an INC Model IR-100 Exposure Device (NRC Docket No. 71-9157) or an INC Model IR-50 Source Changer. The drum is certified to comply with either DOT/UN Standard No. 1A2/X150/S (steel drum w/ removable head, satisfies Packaging Groups I, II, & III Tests, intended for solids [Gross Weight = 150 kg] or inner packagings) or DOT/UN Standard No. 1A2/X120/S (steel drum w/ removable head, satisfies Packaging Groups I, II, & III Tests, intended for solids [Gross Weight= 120 kg] or inner packagings). The plywood or polyurethane foam support structure centrally locates the Model IR-100 or the Model IR-50 payloads within the steel drum overpack. The steel drum lid is secured by either a 12-gauge or 13-gauge, ASTM A366, or A1008 carbon steel closure ring that is secured with a 5/8-inch diameter x 4 inch long carbon steel hex bolt. Although the bolt threads into the closure ring lug, a hex jam nut is added for additional security. The drum lid and body are fabricated using 20-gauge, ASTM A366 or Al008 carbon steel. An overall view of the OP-100 package is shown in Figure 1-1.

Authorization is sought for shipment of a single, special form iridium-192 (Ir-192) or selenium-75 (Se-7 5) source capsule (per package) as a Type B(U), special form material package per the definitions delineated in 10 CFR § 71. 41

• The transport index (Tl) for the package, determined in accordance with the definition of 10 CFR § 71.4, is determined for each shipment. The TI is based on the radiation dose rate at 1 meter from the package surface (method for the transport index is defined in Chapter 7.0, Paclwge Operations).

1.2 Package Description

1.2.1 Packaging

The OP-100 package is a Type B(U) package designed for the transportation of an Ir-192 or Se-75 special form capsule. The maximum gross weight of the package is 77 pounds and its primary components of construction are identified in Figures 1-1 and 1-2. The payloads, the IR-100 Exposure Device and the IR-50 Source Changer, are illustrated in Figures 1-4 and 1-5, respectively. The radioactive source contained by either payload is a special form capsule containing a maximum of 144 curies (Ci) [5.3 terabecquerels (TBq)] oflr-192 or Se-75, and is described in Section 1.2.2, Contents of Paclwging. Primary shielding is provided by depleted uranium (DU). The DU gamma shield, which is composed approximately of 0.2 wt% U-235, 99.8 wt% U-238, is a solid form casting, as illustrated in Figures 1-3, 1-4, and 1-5. The shield

1 Title 10, Code of Federal Regulations, Part 71 (10 CFR 71), Packaging and Transportation of Radioactive Material, 1-1-18 Edition.

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INC OP-100 Package Safety Analysis Report Docket No. 71-9185 Revision 6, 10/2018

contains 0.0042 Ci (0.00016 TBq) of DU. Detailed drawings of the OP-100 package are provided in Appendix 1.3.1 , General Arrangement Drawings, OP-100 Package.

1.2.2 Contents of Packaging

The OP-100 package is designed to transport either an IR-100 Exposure Device or an IR-50 Source Changer, which are illustrated in Figure 1-4 and Figure 1-5, respectively. Either payload may contain a maximum of 144 Ci ( 5 .3 TBq) of Ir-192 or Se-7 5 within a single, special form capsule. The capsule is attached to a pigtail assembly that, along with the lock box and lockball, secures the capsule within the center of the DU gamma shield of the IR-100 or IR-50 packages.

1.2.3 Special Requirements for Plutonium

This section does not apply, since plutonium is not shipped in the OP-100 package.

1.2.4 Operational Features

There are no operationally complex features of the OP-100 package. The contents (described in the following section) are confined within the steel drum that provides the overall protection of the payload. In addition to the secured steel drum closure, the lock box, which is integral to the IR-1 OO/IR-50 stainless steel housing and DU gamma shield, prevents unauthorized removal or unshielded exposure of the contents. The lock box assembly, which allows access to the contents, also conforms to the requirements of 10 CFR § 34 .222

• Each housing incorporates a handle to facilitate manual handling of the payload. Sequential steps of operation are provided in Chapter 7.0, Package Operations.

2 Title 10, Code of Federal Regulations, Part 34 (10 CFR 34), Licenses for Radiography and Radiation Safety Requirements for Radiographic Operations, 7-1-17 Edition.

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INC OP-100 Package Safety Analysis Report

BODY 20 GAUGE

---¢140 "--+-------

WELDED DRUM SEAM

Figure 1-1 - INC OP-100 Packaging

IR- 100 OR IR-50 PAYLOAD

------'---

Docket No. 71-9185 Revision 6, 10/2018

BOLT RING 12 OR 13GAUGE WITH 05/8 X 4.0 HEX BOLT & NUT

17·1/2" OR 189'' (BODY HEIGHT)

10 GALLON STEEL DRUM

3/ 4 INCH THIC K PLYWOOD SUPPORT STRUCTURE

Figure 1-2 - Sectional View of OP-100 Packaging (Plywood Support Structure)

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INC OP-100 Package Safety Analysis Report

IR-1000R IR 50 PAYLOAD

Docket No. 71-9185 Revision 6, 10/2018

10GAU.ON STEEL DRUM

FOAM SUPPORT .STRUCTURE

Figure 1-3 - Sectional View of OP-100 Packaging (Polyurethane Foam Support Structure)

POLYURETHANE FOAM

LOCK BOX

¢.75 VENT

HANDLE

DU SHIELD

SAFETY PLUG

RADIOACTIVE SOURCE CAPSULE/PIGTAIL ASSEMBLY

Figure 1-4- Sectional View of the IR-100 Exposure Device

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INC OP-100 Package Safety Analysis Report

POLYURETHANE FOAM

OPTIONAL: SPACER PLATE (TYP 2 PLACES)

¢.75 VENT

HANDLE

DU SHIELD

I ___ __ _ J

Docket No. 71-9185 Revision 6, 10/2018

LOCK BOX (TYP 2 PLACES)

RADIOACTIVE SOURCE CAPSULE/PIGTAIL ASSEMBLY

Figure 1-5 - Sectional View of the IR-50 Source Changer

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INC OP-100 Package Safety Analysis Report

1.3 Appendices

1.3.1 General Arrangement Drawings

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Security-Related Information Withheld Under 10 CFR 2.390

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INC OP-100 Package Safety Analysis Report

2.0 STRUCTURAL EVALUATION

Docket No. 71-9185 Revision 6, 10/2018

This chapter presents the structural design criteria, weights, mechanical properties of material, and structural evaluations which demonstrate that the OP-100 package meets all applicable structural criteria for transportation as defined in 10 CFR 71 3

2.1 Description of Structural Design

The primary evaluation of the OP-100 package is performed with various tests. The results of the tests are provided in the following sections. Supporting analyses and analyses of non-tested structural aspects are also provided.

The OP-100 package consists of five major fabricated components: 1) a standard, DOT/UN Standard No. 1A2/X150/S or 1A2/X120/S 10-gallon drum, 2) a plywood or polyurethane dunnage for positioning the payload in the drum, 3) a stainless steel housing and lock assembly that enclose and secure the radioactive contents, 4) polyurethane foam that provides protection of the DU from moisture, and 5) the DU gamma shield that provides shielding.

2.1.1 Discussion

2.1.1.1 OP-100 Packaging

The OP-100 package consists of a 10-gallon steel drum that houses a plywood or polyurethane support structure, and either a Model IR-100 Exposure Device or a Model IR-50 Source Changer. The drum is certified to comply with DOT/UN Standard No. 1A2/X150/S (steel drum w/ removable head, satisfies Packaging Groups I, II, & III Tests, intended for solids [Gross Weight= 150 kg] or inner packagings) or DOT/UN Standard No. 1A2/X120/S (steel drum w/ removable head, satisfies Packaging Groups I, II, & III Tests, intended for solids [Gross Weight = 120 kg] or inner packagings). The plywood or polyurethane foam support structure centrally locates the Model IR-100 or the Model IR-50 within the steel drum overpack. The steel drum lid is secured by either a 12-gauge or 13-gauge, ASTM A366 or A1008 carbon steel closure ring, which is secured with a 5/8-inch diameter x 4 inch long carbon steel hex bolt. Although the bolt threads into the closure ring lug, a hex jam nut is added for additional security. The drum lid and body are fabricated using 20-gauge, ASTM A366 or A1008 carbon steel. The gross weight of the OP-100 package overpack is 77 pounds, and is illustrated in Figure 2-1. Note that the outer drum and inner dunnage are sacrificial, and are not included in the shielding evaluation for the payloads (refer to Chapter 5.0, Shielding Evaluation).

2.1.1.2 IR-100 Exposure Device

The Model IR-100 Exposure Device consists of a Zircaloy or titanium source tube surrounded by an enamel-coated depleted uranium (DU) shield. The DU shield assembly is encased within a welded, stainless steel housing. Stainless steel support brackets, welded to the inner housing surface, capture the DU gamma shield between the support bracket and the inner surface of the stainless steel housing. Copper shim stock is installed in the DU-stainless steel interfaces to preclude a reaction

3 Title 10, Code of Federal Regulations, Part 71 (10 CFR 71), Packaging and Transportation of Radioactive Material, 1-1-18 Edition.

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INC OP-100 Package Safety Analysis Report Docket No. 71-9185 Revision 6, 10/2018

between the two dissimilar metals. The void space between the DU shield assembly and the inner stainless steel housing is filled with approximately 2 pounds of rigid polyurethane foam, which prevents moisture from contacting the DU material. The Model IR-100 Exposure Device is illustrated in Figure 2-2.

The stainless steel housing is fabricated from 11-gauge (0.120 inch) thick Type 304 stainless steel sheet. The stainless steel sheet joints are continuously welded so that the DU shield assembly is fully encased in the stainless steel housing.

The radioactive source is a special-form, encapsulated capsule assembly that is attached to a source wire or "pigtail" assembly. The pigtail assembly is secured in the package by the stainless steel lock box that is welded to the rear end plate. The pigtail assembly maintains the radioactive source in a central location within the DU gamma shield, which provides maximum shielding to the public. Maintaining the location of the radioactive source is an important safety requirement since significant displacement of the source from the stored position would elevate the surface and I-meter dose rates.

2.1.1.3 IR-50 Source Changer

The Model IR-50 Source Changer utilizes the same DU shield assembly and welded stainless steel housing as the Model IR-100 Exposure Device. The difference between the two units is that the Model IR-50 Source Changer has a bolted lock box on each end of the housing. Each lock box is attached to the stainless steel housing by (4) 1/4 - 20 UNC x 2 inch stainless steel socket head cap screws, which thread into a 1/4 inch thick stainless steel plate that is welded on the inner surface of the housing. The Model IR-50 Source Changer is illustrated in Figure 2-3 .

The radioactive source is a special-form, encapsulated capsule assembly that is attached to a source wire or "pigtail" assembly. The pigtail assembly is secured in the package by one of the carbon steel lock boxes that are attached to the front or rear end plates. To accommodate various length pigtail assemblies, a carbon steel spacer plate, maximum 0.950 inches thick, may be installed between the lock box and the stainless steel housing. The pigtail assembly maintains the radioactive source in a central location within the DU gamma shield, which provides maximum shielding to the public. Maintaining the location of the radioactive source is an important safety requirement since significant displacement of the source from the stored position would elevate the surface and I-meter dose rates.

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INC OP-100 Package Safety Analysis Report

BODY .20 GAUGE

Docket No. 71-9185 Revision 6, 10/2018

BOLT RING 1<' OR 13 GAUGE WITH 05/S X 4.0 HEX BOLTS NUT

----¢14.0 "·--+-------

17-112" OR 18.9" (BODY HElGt-tn

WELOED DRUM SEAM

Figure 2-1 - OP-100 Packaging

r/J .75 VENT

HANDLE

SAFETY PLUG

POLYURETHANE FOAM

-- --- ---~~~~~~~~

DU SHIELD

Figure 2-2 - Sectional View of the IR-100 Exposure Device

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/

/ /

RADIOACTIVE SOURCE CAPSULE/PIGTAIL ASSEMBLY

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INC OP-100 Package Safety Analysis Report

POLYURETHANE FOAM

OPTIONAL: SPACER PLATE (TYP 2 PLACES)

r/J.75 VENT

HANDLE

DU SHIELD

I I I I

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LOCK BOX (TYP 2 PLACES)

RADIOACTIVE SOURCE CAPSULE/PIGTAIL ASSEMBLY

Figure 2-3 - Sectional View of the IR-50 Source Changer

2.1.2 Design Criteria

2.1.2.1 Basic Design Criteria

The OP-100 package is primarily demonstrated to satisfy the requirements of 10 CPR 71 via full­scale tests.

2.1.2.2 Miscellaneous Structural Failure Modes

2.1.2.2.1 Brittle Fracture

The structural materials of the 0 P-100 packaging include carbon steel sheet, stainless steel and DU. Although carbon steel can be subject to brittle fracture, the thin, 12-gauge carbon steel material used in the construction of the drum is not susceptible to brittle fracture since the thickness is below 0. 625 inches per NUREG/CR-18154

. The carbon steel lock box and steel spacer plates for the IR-50 package are also thinner than 0.625 inches. These components experience compressive loads only from the stainless steel socket head cap screws that secure them to the IR-50 stainless steel body. Additionally, the brittle fracture resistance of these carbon steel components was demonstrated by the full-scale testing of the IR-50 package at temperatures less than -20 °P (-29 °C), with no evidence of brittle fracture. The other materials are not susceptible to brittle fracture at temperatures as low as -20 °P (-29 °C) as described below.

4 NUREG/CR-1815, Recommendations for Protecting Against Failure by Brittle Fracture in Ferritic Steel Shipping Containers Up to Four Inches Thick.

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The housing, lock boxes, and spacer plates of the IR-100 package are fabricated from austenitic stainless steel sheet, bar, and plate respectively. This material does not undergo a ductile-to­brittle transition in the temperature range of interest [i.e., down to -40 °F (-40 °C)], and thus does not require evaluation for brittle fracture.

The DU shield material, which is enclosed by the stainless steel housing of the IR-100, IR-50, has been free drop and puncture tested at temperatures less than-20 °F (-49 °F to -23 °F). As documented in Section 2.7.1, the OP-100 package satisfactorily passed all the tests, which included cumulative damage effects, with no loss of shielding or confinement capability. Based on the low temperature testing of the OP-100 package, the brittle fracture of the DU gamma shield is not of concern.

2.1.2.2.2 Fatigue

Since the payloads of OP-100 package are essentially a rigid body, no structural failures of the confinement boundary due to fatigue will occur.

2.1.2.2.3 Buckling

The OP-100 package, with either the IR-100 or IR-50 payload, provides only a confinement boundary. For normal condition and hypothetical accident conditions, the confinement boundary (i.e., the DU gamma shield) will not buckle due to free or puncture drops. This conclusion has been demonstrated via full-scale tests of the OP-100 and IR-100 packages.

2.1.3 Weights and Center of Gravity

The maximum gross weight of the OP-100 package is 77 pounds. The center of gravity is approximately at the geometric center of the 10-gallon drum.

2.2 Materials

2.2.1 Material Properties and Specifications

Since the evaluation of the OP-100 package is via test, it is not necessary to specify the material properties for evaluation by analysis.

2.2.2 Chemical and Galvanic Reactions

The carbon steel drum communicates only with the plywood or polyurethane foam dunnage within the drum. The housing that contains the DU gamma shield casting is fabricated from Type 304 stainless steel. The stainless steel housing does not have significant reactions with the interfacing components, air, or water. The DU casting, which is painted, is further encased by polyurethane foam. Copper shims are placed between the interface between the DU and stainless steel to prevent a eutectic reaction. The "S" tube (made of either titanium or Zircaloy) does not react or form a galvanic corrosion cell between the DU gamma shield material and the stainless steel.

2.2.3 Effects of Radiation on Materials

The gamma radiation associated with the Ir-192 or Se-7 5 radioactive material will have no effect on the carbon steel of the OP-100 package, or the austenitic stainless steel and DU comprising the structural materials of the IR-100 or IR-50 payloads. As discussed in Section 2.1.1,

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Discussion, the interior polyurethane foam utilized in both the IR-100 and IR-50 devices provides moisture protection of the DU gamma shield. The effect of the radiation on the polyurethane foam to provide this function is negligible.

2.3 Fabrication and Examination

2.3.1 Fabrication

The 10-gallon steel drum for the OP-100 package is fabricated and certified to comply with DOT/UN Standard No. 1A2/X150/S (steel drum w/ removable head, satisfies Packaging Groups I, II, & III Tests, intended for solids [Gross Weight= 150 kg] or inner packagings) or DOT/UN Standard No. 1A2/X120/S (steel drum w/ removable head, satisfies Packaging Groups I, II, & III Tests, intended for solids [Gross Weight= 120 kg] or inner packagings). The IR-100 and IR-50 devices are fabricated utilizing conventional metal forming and joining techniques. Materials for these payloads are procured in accordance with the standards delineated on the drawings in Appendix 1.3 .1, General Arrangement Drawings. All welding procedures and welding personnel are qualified in accordance with Section IX of the ASME Boiler and Pressure Vessel (B&PV) Code5

.

2.3.2 Examination

The primary safety function of the IR-100 and IR-50 devices is to provide gamma shielding of the special form a radioactive material. To verify this function, each DU gamma shield is examined by performing a shielding test, as delineated in Section 8.1.6, Shielding Tests, prior to being used in the fabrication of an IR-100 device. In addition, all welds are visually inspected in accordance with the notes identified in Appendix 1.3.1, General Arrangement Drawings.

2.4 General Requirements for All Packages

The OP-100 is evaluated, with respect to the general standards for all packaging specified in 10 CFR § 71.43 3. Results of the evaluations are discussed in the following sections.

2.4.1 Minimum Package Size

The smallest overall dimension of the OP-100 package is 14 inches. This dimension is greater than the minimum dimension of 4 inches specified in 10 CFR §71.43(a). Therefore, the requirements of 10 CFR §71.43(a) are satisfied by the OP-100 package.

2.4.2 Tamper Indicating Device

A tamper indicating seal (wire/lead security seal) is attached to the 5/8 x 4 inch bolt on the drum closure ring, which provide visual evidence that the closure was not tampered. Thus, the requirements of 10 CFR §71.43(b) are satisfied.

5 American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code, Section IX, Qualification Standard for Welding and Brazing Procedures, Welders, Brazers, and Welding and Brazing Operators, 1995 edition, 1997 Addenda.

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2.4.3 Positive Closure

Docket No. 71-9185 Revision 6, 10/2018

The OP-100 package cannot be opened inadvertently. Positive closure of the OP-100 package is provided by the drum closure ring that is secured with a 5/8-inch x 4 inch hex bolt. In addition, the lock box assembly secures the source pigtail assembly in its proper shielded position in the IR-100 or IR-50 devices. The lock box assembly, which permits access to the contents, conforms to the requirements of 10 CFR §34.222

. Thus, the requirements of 10 CFR §71.43(c) are satisfied.

2.4.4 Valves

Since the OP-100 package is a confinement system and designed to transport only a special form radioactive material, there are no valves or other pressure retaining devices on the package. Two 1/8-inch diameter vent holes are drilled into the side wall of the drum to preclude pressure buildup within the drum cavity. Therefore, the requirements of 10 CFR §71.43(e) are satisfied.

2.4.5 Package Design

As shown in Section 2.6, 3.4, and 5.6, the OP-100 package design satisfies the requirements of 10 CFR §71.71. Thus, the requirements of 10 CFR §71.43(f) are satisfied.

2.4.6 External Temperatures

The decay heat load of the Ir-192 or Se-7 5 special form capsule is negligible. Therefore, the surface temperature does not exceed 122 °F (50 °C) in still air and shade during transport for a nonexclusive use shipment. Thus, the requirements of 10 CFR §71.43(g) are satisfied by the OP-100 package.

2.4. 7 Venting

With an Ir-192 or Se-7 5 special form source capsule encapsulating the radioactive material, the package does not incorporate any feature that would permit continuous venting during transport. Thus, the requirements of 10 CFR §71.43(h) are satisfied by the OP-100 package.

2.5 Lifting and Tie-down Devices for All Packages

2.5.1 Lifting Devices

The OP-100 package does not incorporate any lifting device in its design. The steel drum is manually lifted without any special devices and/or tools. Therefore, the requirements of 10 CFR §71.45(a) are not applicable to the OP-100 package.

2.5.2 Tie-Down Devices

The OP-100 package design has no tie-down devices. Therefore, the requirements of 10 CFR § 71.45(b) are not applicable.

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2.6 Normal Conditions of Transport

2.6.1 Heat

Docket No. 71-9185 Revision 6, 10/2018

The IR-100 and IR-50 devices were exposed to a maximum temperature of250 °P (121 °C) over 3 hours during the foam curing process. No loss in operational capability or damage occurred. The maximum steady state temperature of any component of the OP-I 00 package in an ambient environment of 100 op (38 °C) and full insolation is 137 op (58 °C).

2.6.2 Cold

The OP-100 packaging was exposed to -40 °P (-40 °C) for two hours in an environmental chamber without negative effects.

2.6.3 Reduced External Pressure

The OP-100 package is a confinement boundary for a special form payload and does not have a pressure boundary. Therefore, the effect of reduced external pressure is not applicable.

2.6.4 Increased External Pressure

The OP-100 package is a confinement boundary for special form payload and does not have a pressure boundary. Therefore, the effect of increased external pressure is not applicable.

2.6.5 Vibration

The package has been subjected to both normal conditions of transport as well as rugged field use over an extended period of time (1982 to present). The packages have not experienced any damage or effects due to the vibrations induced by normal conditions of transport identified in 10 CPR §71.71(c)(5).

2.6.6 Water Spray

The materials of construction utilized for the OP-100 package are such that the water spray test identified in 10 CPR § 71. 71 ( c )( 6) will have a negligible effect on the package. The two vent holes are covered by adhesive tape during transport to preclude the intrusion of water into the drum cavity.

2.6. 7 Free Drop

Since the gross weight of the 0 P-100 packaging is less than 11, 000 pounds, a 4 foot ( 1.2 meter) free drop is required per 10 CPR §71.71(c)(7). As discussed in Appendix 2.12.1, Certification Tests, a NCT, 4 foot (1.2 meter) bottom drop was performed on an OP-100 packaging certification test unit (CTU) as an initial condition for subsequent hypothetical accident condition (HAC) tests. A radiation survey following certification testing demonstrated the ability of the OP-100 packaging to protect the IR-100 or IR-50 devices and maintain their shielding integrity. Therefore, the requirements of 10 CPR § 71. 71 ( c )(7) are satisfied.

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2.6.8 Corner Drop

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This test does not apply, since the exterior materials of construction do not include wood or fiberboard, as delineated in 10 CFR § 71. 71 ( c )(8).

2.6.9 Compression

A 399-pound force, which is greater than five times the gross package weight, was applied to the OP-100 package top surface while sitting in its normal upright position for a period of 24 hours. No observable deformation and damage was detected. Therefore, the requirements of 10 CFR § 71. 71 ( c )(9) are satisfied.

2.6.10 Penetration

A 1 ~inch (3.2 cm) diameter, 13 pound (6 kg), hemispherical end steel rod was dropped from a height of one meter ( 40 inches) onto the package in an effort to pierce the housing, and possibly bend the lock assembly. These orientations were an effort to shift the source out of the "safe" area of the DU gamma shield. Three drop tests were performed on an OP-100 package using an IR-50 payload. The first two drop tests were onto the outlet end (safety plug end) and the lock box end. Both drops resulted in a 3/16-inch spherical dent in the impacted surface. The third drop test was onto the side of the drum body. The result of the third drop was a 3/16-inch spherical dent in the impacted surface. There was no loss in operational capability of the OP-100 package due to any of the impact events. Therefore, the requirements of 10 CFR §71.71(c)(10) are satisfied.

2.7 Hypothetical Accident Conditions

When subjected to the hypothetical accident conditions (HAC) as specified in 10 CFR §71.73, the 0 P-100 package meets the performance requirements specified in Subpart E of 10 CFR 71. This conclusion is demonstrated in the following subsections, where each accident condition is addressed and the package is shown to meet the applicable design criteria. The method of demonstration is primarily by test. The tests specified in 10 CFR § 71. 73 are applied sequentially, per Regulatory Guide 7.8.

Test results are summarized in Section 2.7.7, Summary of Damage, with details provided in Appendix 2.12.1, Certification Tests. Note that all tests were performed with the plywood support structure rather than the 4 lbm/ft3 polyurethane support structure, which totally surrounds the IR-100 or IR-50 devices. Since the polyurethane foam provides greater protection of the payload than the plywood, the testing of the OP-100 with the plywood support structure is conservative, and bounds the package response with the polyurethane foam support structure for all HAC tests, as demonstrated in the supplementary certification tests.

2. 7 .1 Free Drop

Subpart F of 10 CFR 71 requires that a 30 foot (9-meter) free drop to be considered for the OP-100 package. The free drop is to occur onto a flat, essentially unyielding, horizontal surface, and the package is to strike the surface in an orientation for which the maximum damage is expected. The free drop is addressed by test, in which several orientations are used. The free drop proceeds both the puncture and fire tests.

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2.7.1.1 Technical Basis for the Free Drop Tests

Docket No. 71-9185 Revision 6, 10/2018

The drop orientations selected for testing are intended to maximize the damage to the Model OP-100 package and cause a potential opening or separation of the drum lid from the drum body. Once the drum lid opens or separates from the drum body, the Model IR-100 Exposure Device or the IR-50 Source Changer is assumed to be fully exposed (i.e., separated from the drum overpack and plywood support structure).

2.7.1.2 Test Sequence for the Selected Tests

Based on the above discussions, and to maximize the damage to the Model OP-100 package and potentially opening the drum lid or damaging the IR-100 or IR-50 device, the OP-100 package was tested for six specific, HAC 30 foot (9 meter) free drop conditions:

1. Bottom Drop on Drum: This orientation will result in the maximum inertia loading of the drum with the IR-50 Source Changer as the payload. The intent ofthis drop orientation is to develop maximum impact forces in the packaging to attempt to separate the Source Changer from the drum/plywood support structure. The bottom drop orientation was also selected for the normal condition drop since this orientation is the most probable to occur in actual use in the field.

2. Side Drop on Drum Closure Ring Bolt (0° Circumferential Orientation): This orientation targets the 5/8-inch diameter drum closure ring bolt that secures the steel closure ring and the drum longitudinal weld seam. The closure ring in tum secures the steel lid to the drum body. Failure of the closure ring bolt could result in a failure of the closure ring and hence, allow the steel drum lid to open or separate from the drum body. Failure of the drum weld seam could also fully expose the payload. This orientation further targets the lock box of either the IR-100 Exposure Device or the IR-50 Source Changer.

3. Side Drop on Opposite Side of Drum Closure Ring Bolt (180° Circumferential Orientation): This orientation targets the Safety Plug of the IR-100 Exposure Device due to its minimal distance between the drum side wall and the plug. Failure of the Safety Plug could potentially result in movement of the DU shield assembly and/or cause a radiation streaming problem which would exceed the maximum allowable dose rate permitted by 10 CFR 71.

4. CG Over Drum Closure Ring Bolt: This orientation again targets the 5/8-inch diameter drum closure bolt, but results in maximum deformation of the closure bolt/ring assembly. Should this deformation be sufficiently severe, the steel closure ring potentially may be dislodged and/or broken and allow the steel drum lid to separate from the drum body. This orientation will be applied only to the IR-50 Source Changer.

5. Top Drop on Drum Lid: This orientation targets the steel drum lid and the lock box of the payload. The cold test condition (-20 °F [-29 °C]) will maximize the impact forces on the payload. Should this impact be sufficiently severe, the IR-50 lock box may be damaged, which could result in significant movement of the source. This orientation will be applied to the IR-50 Source Changer, which has the smallest clearance between the lock box and the outer drum for the polyurethane foam support structure.

6. CG Over Bottom Comer: This orientation targets the lock box assembly of the IR-50 payload and the steel drum body. The cold test condition (-20 °F [-29 °C]) maximizes the impact forces on the steel drum and the payload. The intent of this orientation is to attempt to damage the lock box, and possibly ovalize the drum body to attempt to separate the steel drum lid from the drum body. Should this impact be sufficiently severe, the deformation may dislodge the

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steel drum lid from the drum body and possibly cause the payload to separate from the drum body. This orientation will be applied to the IR-50 Source Changer.

Although only a single "worst case" 30 foot (9 meter) drop is required by 10 CFR §71.73(c)(l), multiple tests were performed to ensure that the most vulnerable package features were subjected to "worst case" loads and deformations. The specific conditions selected for the OP-100 Certification Test Units (CTUs) are summarized in Table 2.7-1.

2.7.1.3 Summary of Results from the Free Drop Tests

Successful HAC free drop testing of the CTUs indicates that the various OP-100 packaging design features are adequately designed to withstand the HAC 30 foot (9 meter) free drop event. The most important result of the testing program was the demonstrated ability of the OP-100 package to maintain the shielding integrity of the IR-100 or IR-50 payloads. Significant results of the free drop testing are as follows:

• No failure of the drum closure lid/closure ring bolt occurred that would have permitted the potential separation of the payload from the protective overpack, for either the plywood or the polyurethane foam support structures.

• No evidence of excessive distortion of the lock box occurred that would have significantly displaced the special form source from its desired shielded position.

• There was no evidence of rupturing of the stainless steel housing that could have resulted in thermal degradation of the DU gamma shield by excessive oxidation in a subsequent fire event.

Further details of the free drop test results are provided in Appendix 2.12.1, Certification Tests.

2.7.2 Crush

The crush test specified in 10 CFR §71.73(c)(2) is required only when the specimen has mass not greater than 1,100 lbs. (500 kg), an overall density not greater than 62.4 lb/ft3 (1,000 kg/m3

), and radioactive contents greater than 1,000 A2, not as special form. The payload of the OP-100 package is special form. Therefore, the dynamic crush test of 10 CFR §71.73(c)(2) is not applicable to the OP-100 package.

2.7.3 Puncture

Subpart F of 10 CFR 71 requires performing a puncture test in accordance with the requirements of 10 CFR §71.71(c)(3). The puncture test involves a 40 inch (1 meter) drop onto the upper end of a solid, vertical, cylindrical, mild steel bar mounting on an essentially unyielding, horizontal surface. The bar must be 6 inches (15 cm) in diameter, with the top surface horizontal and its edge rounded to a radius of not more than 114 inch (6 mm). The minimum length of the bar is to be 8 inches (20 cm). The ability of the OP-100 package to adequately withstand this specified drop condition is demonstrated via testing of four, full-scale, OP-100 test packages.

2.7.3.1 Technical Basis for the Puncture Drop Tests

The drop orientations selected for puncture testing are intended to maximize the damage to the Model OP-100 package and cause a potential opening or separation of the drum lid from the drum body. Once the drum lid opens or separates from the drum body, the Model IR-100 Exposure

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Device, or IR-50 Source Changer is assumed to be fully exposed (i.e. , separated from the drum overpack and plywood or polyurethane foam support structure).

For the above reasons, testing included orientations that affect the closure ring (which secures the drum lid), the lock box (which secures the special form source), and the Safety Plug outlet end (which may result in an excessive opening into the housing cavity for a subsequent fire event). Therefore, an orientation that places the CG over each of these three items was included in the test sequence.

These orientations were also utilized for the RAC 30 foot (9 meter) free drops and hence, would expect to produce the worst-case cumulative damage to the package.

2.7.3.2 Test Sequence for the Selected Tests

Separate orientations were identified for the OP-100 package with the IR-100 Exposure Device and the IR-50 Source Changer for the puncture bar tests. For the OP-100 package with the Model IR-100 Exposure Device, the two orientations selected are:

1. Side Drop on Drum at 0° Circumferential Orientation: This side orientation compounds the damage sustained by the 30-foot free drop and continues to attack the welded lock box of the IR-100 Exposure Device.

2. Side Drop on Drum at 180° Circumferential Orientation: This side orientation compounds the damage sustained by the 30-foot free drop and continues to attack the Shield Plug of the IR-100 Exposure Device.

For the OP-100 package with the IR-50 Source Changer, the two orientations selected are:

1. Side Drop on Drum at 180° Circumferential Orientation: This side orientation compounds the damage sustained by the 30-foot free drop and continues to attack the bolted lock box of the IR-50 Source Changer.

2. CG Over Drum Closure Ring Bolt: This orientation compounds the damage sustained by the 30-foot free drop and continues to attack the 5/8-inch diameter drum closure bolt of the OP-100 package with the IR-50 Source Changer. Should this deformation be sufficiently severe, the steel closure ring potentially may be dislodged and/or broken and allow the steel drum lid to separate from the drum body.

Based on the above general discussions, the CTUs were specifically tested for four RAC puncture drop conditions as part of the certification test program. Although only a single "worst case" puncture drop is required by 10 CFR §71.73(c)(3), multiple tests were performed to ensure that the most vulnerable package features were subjected to "worst case" loads and deformations. The specific conditions selected for the OP-100 Certification Test Units (CTUs) are summarized in Table 2.7-1.

2.7.3.3 Summary of Results from the Puncture Drop Tests

Successful RAC puncture drop testing of the CTUs indicates that the various OP-100 packaging design features are adequately designed to withstand the RAC puncture drop event. The most important result of the testing program was the demonstrated ability of the OP-100 package to maintain the shielding integrity of the IR-100 or IR-50 payloads. Significant results of the puncture drop testing are as follows:

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• No failure of the drum closure lid/closure ring bolt occurred which would have permitted the potential separation of the payload from the protective overpack.

• No evidence of excessive distortion of the lock box occurred that would have significantly displaced the special form source from its desired shielded position.

• There was no evidence of excessive rupturing of the stainless steel housing that could have resulted in thermal degradation of the DU gamma shield by excessive oxidation in a subsequent fire event.

Further details of the free drop test results are provided in Appendix 2.12.1, Certification Tests, and Appendix 2.12.2, Supplementary Certification Tests.

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Table 2.7-1 - Summary of OP-100 Certification Test Unit (CTU) Tests

Test Unit Angular Orientation

Test Test Description Temperature Longitudinal Circumferential No. (Certification Test Unit No.) (as measured) (0° = vertical) (0° = closure bolt )

1 4 foot bottom drop w/ IR-50 (CTU-1) 93 - 97 °P oo NA

2 30 foot bottom drop w/ IR-50 (CTU-1) 93 - 106 °P oo NA

30 foot side drop on drum closure ring -22/-32 op (interior)

3 73 - 110+ 0P 90° oo bolt, weld seam w/ IR-100 (CTU-2)

(surface)

30 foot side drop on side opposite drum -22/-32 °P (interior) 4 73 -110+ 0P 90° 180° closure ring bolt w/ IR-100 (CTU-3)

(surface)

5 30 foot side drop on drum closure ring bolt

99 - 125 °P 90° oo w/ IR-50 (CTU-1)

6 30 foot, CG over drum closure ring bolt w/

107 - 118 °P 131° oo IR-50 (CTU-4)

7 Puncture drop on drum side w/ IR-100 -24/-25 °P (interior)

90° oo (CTU-2) 72- 88 op (surface)

8 Puncture drop on drum side w/ IR-100 -23/-25 °P (interior)

90° 180° (CTU-3) 74 - 91 op (surface)

9 Puncture drop on drum side w/ IR-50

105-ll5°P 90° 180° (CTU-1)

10 Puncture drop, CG over drum closure ring

103 - 110 °P 131° oo bolt w/ IR-50 (CTU-4)

11 Thermal Test (CTU-3) Ave. 1,553 °P oo NA

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Remarks

NCT impact on most probable orientation in field to cause damage.

HAC impact on region to cause maximum inertia loading.

HAC impact producing maximum load on closure bolt/drum seam.

HAC impact to attack the Safety Plug opposite the lock box.

HAC impact producing maximum load on closure bolt/drum seam.

HAC impact to cause maximum deformation of drum closure ring.

Puncture in area expected to increase damage of drum/IR-100 resulting from free drop.

Puncture in area expected to increase damage of drum/IR-100 resulting from free drop.

Puncture in area expected to increase damage of drum/IR-50 resulting from free drop.

Puncture in area expected to increase damage of drum/IR-50 resulting from free drop.

Thermal testing of most damaged CTU.

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Test Test Description Temperature No. (Certification Test Unit No.) (as measured)

12 30 foot bottom drop w/ IR-50, foam 101 Of

support structure (CTU-5) (Foam)

13 30 foot, CG over closure ring w/ IR-50, 95.9 Of

foam support structure (CTU-5) (Foam)

14 30 foot top drop w/ IR-50, foam support -37.5 Of

structure (CTU 6) (Foam)

15 30 foot, CG over bottom comer w/ IR-50, -37.5 Of

foam support structure (CTU-6) (Foam)

Test Unit Angular Orientation

Longitudinal Circumferential (0° = vertical) (0° = closure bolt )

oo NA

141° oo

180° NA

45° oo

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Remarks

RAC impact on most probable orientation in field; hot condition maximizes deformation.

RAC impact on lid closure ring and closure ring bolt; hot condition maximizes deformation.

RAC impact on lid; cold condition maximizes impact deceleration on payload.

RAC impact on bottom comer; cold condition maximizes deformation and impact deceleration on payload.

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2.7.4 Thermal

Docket No. 71-9185 Revision 6, 10/2018

Subpart F of 10 CFR 71 requires performing a thermal test in accordance with the requirements of 10 CFR §71.7l(c)(4). To demonstrate the performance capabilities of the OP-100 packaging when subjected to the HAC thermal test specified in 10 CFR §71.71(c)(4), a full scale CTU was exposed to a minimum of 1,475 °F (800 °C) for 30 minutes in a vented electric oven. The selected CTU was subjected to a number of 30-foot free drop and puncture tests prior to being placed in the oven, as discussed in Section 2.71, Free Drop, and Section 2.7.3, Puncture.

To ensure that there was adequate oxygen available for combustion of the flammable material in the packaging (i.e., plywood, polyurethane foam), a source of air was supplied into the furnace. Two K type thermocouples were installed on the surface of each side of the packaging to monitor the package' s temperature during the test.

The package was orientated such that the through-wall piercing in the carbon steel drum shell and the gap in the closure lid would result in the possible formation of a chimney. Thus, complete combustion of the interior plywood, and possibly the foam and the DU material, would result.

The thermal test was initiated when the temperature of the packaging was a minimum of 1,4 7 5 °F (800 °C) after the forced introduction of air. This test condition conservatively addressed the effects of the convective heat transfer that would naturally occur in a fully engulfing fire test. Following 30 minutes, the CTU was removed from the oven and allowed to naturally cool in air, without any active cooling systems.

Successful HAC thermal testing of the CTU indicates that the various OP-100 packaging design features are adequately designed to withstand the HAC thermal test event. The most significant result of the testing program was the demonstrated ability of the OP-100 packaging to maintain the shielding integrity of the IR-100 or IR-50 payloads, as demonstrated by an actual radiation post-test survey.

Further details of the thermal test results are provided in Appendix 2.12.1, Certification Tests.

2.7.5 Immersion- Fissile

The OP-100 package does not transport fissile material, and therefore, this section does not apply.

2.7.6 Immersion -All Packages

The OP-100 package is a confinement boundary for special form payload and does not have a pressure boundary. Therefore, the effect of pressure from immersion is not applicable.

2.7.7 Deep Water Immersion Test (for Type B Packages Containing More than 105 A2)

The OP-100 package contains a maximum of 144 Ci (5 .3 TBq) oflr-192 or Se-75, which have Ai values of 16 Ci (0.6 TBq) and 81 Ci (3.0 TBq), respectively. Since the OP-100 package does not contain more than 105 Ai quantities of radioactive material, this section does not apply.

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2.7.8 Summary of Damage

Docket No. 71-9185 Revision 6, 10/2018

As discussed in the previous sections, the cumulative damaging effects of free drop, puncture drop, and thermal tests were satisfactorily withstood by the OP-100 packaging certification testing. Subsequent radiation post-test survey and destructive examinations of the CTUs confirmed that shielding integrity was maintained throughout the test series. Therefore, the requirements of 10 CFR § 71. 73 have been adequately satisfied.

2.8 Accident Conditions for Air transport of Plutonium

This section does not apply, since plutonium is not transported in the OP-100 package.

2.9 Accident Conditions for Fissile Material Packages for Air Transport

This section does not apply, since plutonium is not transported in the OP-100 package.

2.10 Special Form Certification

The contents of the OP-100 package are a special form Ir-192 or Se-75 source capsule. All source capsules are limited to a maximum of 144 Ci (5.3 TBq). The special form certifications for the Ir-192 and Se-7 5 capsule are as follows:

Manufacture Model Number Certification Number

A1 USA/0297 /S-96 Industrial Nuclear Co., Inc.

791 1 USA/0393/S-96

Source Production & VSe Source Capsule2 USA/0785/S-96

Equipment Co., Inc.

Notes: 1. Source capsule is limited to a maximum of 144 Ci (5 .3 TBq) oflr-192 material 2. Source capsule is limited to a maximum of 144 Ci (5.3 TBq) oflr-192 or Se-75 material.

2.11 Fuel Rods

This section does not apply, since fuel rods are not transported in the OP-100 package.

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2.12 Appendix

2.12.1 Certification Tests

2.12.2 Supplementary Certification Tests

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2.12.1 Certification Tests

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Presented herein are the results of normal conditions of transport (NCT) and hypothetical accident condition (HAC) test that address free drop, puncture, and thermal test performance requirements of 10 CFR 71 6

. The Certification Tests are fully documented in the certification test report 7.

2.12.1.1 Introduction

The OP-100 packaging, when subjected to the sequence ofHAC tests specified in 10 CFR §71.73, subsequent to the NCT tests specified in 10 CFR §71.71, is shown to meet the performance requirements specified in Subpart E of 10 CFR 71. As indicated in the introduction to Chapter 2. 0, Structural Evaluation, the primary proof of performance for the HAC tests is via the use of full­scale testing. In particular, free drop, puncture, and thermal testing of OP-100 CTUs confirms that the packaging will retain its shielding integrity following a worst case HAC sequence.

2.12.1.2 Summary

As seen in the figures presented in Section 2.12.1.7, Test Results, successful testing of the CTUs indicates that the various OP-100 packaging design features are adequately designed to withstand the HAC tests specified in 10 CFR §71.73. The most important result of the testing program was the demonstrated ability of the OP-100 packaging to maintain the shielding integrity of the IR-100 or IR-50 payloads.

Significant results of the free drop tests are as follows:

• No failure of the drum closure lid/closure ring bolt occurred which would have permitted the potential separation of the payload from the protective overpack.

• No evidence of excessive distortion of the lock box occurred that would have significantly displaced the special form source from its desired shielded position.

• There was no evidence of rupturing of the stainless steel housing that could have resulted in thermal degradation of the DU gamma shield by excessive oxidation in a subsequent fire event.

Significant results of the puncture drop testing are as follows:

• No failure of the drum closure lid/closure ring bolt occurred which would have permitted the potential separation of the payload from the protective overpack.

• No evidence of excessive distortion of the lock box occurred that would have significantly displaced the special form source from its desired shielded position.

• There was no evidence of rupturing of the stainless steel housing that could have resulted in thermal degradation of the DU gamma shield by excessive oxidation in a subsequent fire event.

Significant results of the thermal testing are as follows:

6 Title 10, Code of Federal Regulations, Part 71 (10 CFR 71) Packaging and Transportation of Radioactive Material, 1-1-18 Edition.

7 Packaging Technology, Inc., PacTec Document TR-002, Certification Test Report for the OP-JOO Package, Revision 1, August 1998.

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• No evidence of excessive oxidation of the DU gamma shield and subsequent loss of shielding.

• Gases formed by thermal degradation of the polyurethane foam were safely vented out of the stainless steel housing and steel drum.

• The plywood support structure was completely consumed in the test without any effect on the payload.

• The polyurethane foam was completely consumed in the test without any effect on the DU shield material.

• None of the components that are important to safety (i.e., stainless steel housing, lock box, DU gamma shield) sustained any degradation due to excessive temperatures.

2.12.1.3 Test Facilities

The drop testing is being performed using a horizontal concrete slab, which is approximately 20 inches x 4 feet x 8 feet. A 2 inch x 46 inch x 60 inch steel plate is placed on top of the concrete slab and welded to two 8-inch wide steel channels that are embedded in the concrete. The estimated mass of the drop pad is 9,295 lbsm, which is more than 125 times the mass of the OP-100 CTU. Based on these characteristics, the drop pad satisfies the requirement of 10 CFR § 71. 71 and 10 CFR §71.73 for an essentially unyielding, horizontal surface.

The puncture bar for the puncture tests is a 6 inch diameter x 13 inch long solid bar which is orthogonally socket welded through a 1 inch x 18 inch x 18 inch steel plate. The top circumferential edge of the bar has a 1/4-inch radius. The free length of the bar is 12 inches (i.e., 13 inches minus the 1 inch thick plate), thus ensuring an adequate length to potentially cause maximum damage to the CTU as required by 10 CFR §71.73(c)(3). Following the thirty foot free drop tests, the 1-inch thick plate of the puncture bar assembly will then be welded to the 2-inch thick plate on the drop pad to ensure that the puncture bar is restrained for the puncture drop tests.

The oven that was utilized for the OP-100 package thermal testing is located at Manufacturing Sciences Corporation's Oak Ridge, TN facility. The MSC oven is a General Electric, 60 Kw resistance heated box furnace with interior dimensions of 87 inch (L) x 42 inch (W) x 25 inch (H). The oven is capable of temperatures up to 2,000 °F, controlled within ±10 °F.

2.12.1.4 Certification Test Unit Description

The OP-100 package consists of a 10-gallon steel drum that houses a plywood support structure, and either a Model IR-100 Exposure Device or a Model IR-50 Source Changer. The drum was certified to comply with DOT/UN Standard No. 1A2/X150/S (steel drum w/ removable head, satisfies Packaging Groups I, II, & III Tests, intended for solids [Gross Weight= 150 kg] or inner packagings). The plywood support structure centrally locates the Model IR-100 or the Model IR-50 within the steel drum overpack. The steel drum lid is secured by a 12-gauge, ASTM A366 carbon steel closure ring that is secured with a 5/8-inch diameter x 4 inch long carbon steel hex bolt. Although the bolt threads into the closure ring lug, a hex jam nut is added for additional security. The drum lid and body are fabricated using 20-gauge, ASTM A366 carbon steel. The maximum gross weight of the OP-100 package is 77 pounds.

The IR-100 Exposure Device consists of a zircaloy or titanium source tube surrounded by a painted depleted uranium (DU) shield. The DU shield assembly is encased within a welded, Type 304 stainless steel housing. Stainless steel support brackets, welded to the inner housing

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surface, capture the DU gamma shield between the support bracket and the inner surface of the stainless steel housing. Copper shim stock is installed between the DU-stainless steel interfaces to preclude a reaction between the two dissimilar metals. The void space between the DU shield assembly and the inner stainless steel housing is filled with approximately 2 pounds of rigid polyurethane foam that prevents moisture from contacting the DU material.

Prior to free drop, puncture, and thermal testing, two OP-100/IR-100 CTUs and two OP-100/IR-50 CTUs were loaded with a dummy source capsule assembly to simulate the Ir-192 special form capsule. The actual weight was 71 pounds for the OP-100/IR-100 CTUs. The OP-100/IR-50 CTUs weighed 74 pounds (CTU-1) and 73 pounds (CTU-4). Aside from the dummy source capsule assembly, the CTUs were identical to the OP-100 packaging design depicted in Appendix 1. 3 .1 , General Arrangement Drawings.

2.12.1.5 Technical Basis for Tests

For the confinement system to fail, the IR-100 or IR-50 payloads would need to move or separate the radioactive source from the central location within the DU shield assembly. This potential failure mode may only occur if either or both of the following conditions occur:

1. The lock box of the IR-1 OO/IR-50 payloads is broken free of the stainless steel housing or damaged such that the source is significantly moved from its stored position.

2. The DU shield assembly translates away from the lock box/pigtail assembly and the source is significantly moved from its stored position.

For either of these potential conditions to be initiated, the OP-100 package would need to sustain significant damage due to the normal and hypothetical accident condition free drops and then sustain further damage due to the I-meter (40-inch) drop onto a 6-inch diameter vertical steel bar. Therefore, the primary objective of the 1.2-meter (4-foot) normal condition and 9-meter (30-foot) hypothetical accident condition (HAC) free drops is to attempt to separate the IR-100 or IR-50 payload from the drum and cause damage to the lock box or cause significant movement of the special form source within the DU gamma shield. A secondary objective of the 9-meter (30-foot) HAC free drops is to attempt to damage the safety plug fitting such that a potential air pathway into the interior would form. Such a pathway could potential result in a self-sustaining oxidation reaction of the DU and hence, result in a loss of shielding.

The following sections provide the technical basis for the chosen test orientations and sequences for the OP-100 CTUs as presented in Appendix 2.12.1.6, Test Sequence for Selected Free Drop, Puncture Drop, and Thermal Tests.

2.12.1.5.1 Temperature

Certification testing the OP-100 package was performed at temperatures below -20 °F and as high as 125 °F. The results of the OP-100 package testing demonstrated that extreme temperatures had no effect on the shielding integrity of the IR-100 or IR-50 payloads. In addition, the austenitic stainless steel and DU materials are not susceptible to brittle fracture, as delineated in Section 2.1.2.2.1, Brittle Fracture.

2.12.1.5.2 Free Drop Tests

The OP-100 package is qualified primarily by full scale testing, with acceptance criterion being the ability to demonstrate shield integrity. Per 10 CPR §71.73(c)(l), the package is required to

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"strike an essentially unyielding surface in a position for which maximum damage is expected." Therefore, for determining the drop orientations that satisfy the regulatory "maximum damage" requirement, attention is focused predominately on the issue of shield integrity.

To maximize the damage to the Model OP-100 package and potentially opening the drum lid or damaging the IR-100 or IR-50 payload, four orientations have been selected for the free drop testing:

1. Bottom Drop on Drum: This orientation will result in the maximum inertia loading of the drum with the IR-50 Source Changer as the payload. The intent ofthis drop orientation is to develop maximum g forces in the packaging to attempt to separate the Source Changer from the drum/plywood support structure. The bottom drop orientation was also selected for the normal condition drop since this orientation is the most probable to occur in actual use in the field.

2. Side Drop on Drum Closure Ring Bolt (0° Circumferential Orientation): This orientation targets the 5/8-inch diameter drum closure ring bolt that secures the steel closure ring and the drum longitudinal weld seam. The closure ring in tum secures the steel lid to the drum body. Failure of the closure ring bolt could result in a failure of the closure ring and hence, allow the steel drum lid to open or separate from the drum body. Failure of the drum weld seam could also fully expose the payload. This orientation furthers targets the lock box of either the IR-100 Exposure Device or the IR-50 Source Changer.

3. Side Drop on Opposite Side of Drum Closure Ring Bolt (180° Circumferential Orientation): This orientation targets the Safety Plug of the IR-100 Exposure Device due to its minimal distance between the drum side wall and the plug. Failure of the Safety Plug could potentially result in movement of the DU shield assembly and/or cause a radiation streaming problem which would exceed the maximum allowable dose rate permitted by 10 CFR 71.

4. CG Over Drum Closure Ring Bolt: This orientation again targets the 5/8-inch diameter drum closure bolt, but results in maximum deformation of the closure bolt/ring assembly. Should this deformation be sufficiently severe, the steel closure ring potentially may be dislodged and/or broken and allow the steel drum lid to separate from the drum body. This orientation will be applied only to the IR-50 Source Changer.

Separate orientations were identified for the OP-100 package with the IR-100 Exposure Device and the IR-50 Source Changer for the puncture bar tests. For the OP-100 package with the Model IR-100 Exposure Device, the two orientations selected are:

1. Side Drop on Drum at 0° Circumferential Orientation: This side orientation compounds the damage sustained by the 30-foot free drop and continues to attack the welded lock box of the IR-100 Exposure Device. Should this result in a failure of the lock box or significant relative deformation between the lock box and the DU shield assembly, then the radiation dose rate might exceed the maximum allowable dose rate 1,000 mrem/hr at I-meter permitted by 10 CFR 71.

2. Side Drop on Drum at 180° Circumferential Orientation: This side orientation compounds the damage sustained by the 30-foot free drop and continues to attack the Safety Plug of the IR-100 Exposure Device. Should this result in a failure of the Safety Plug or significant relative deformation between the Safety Plug and the DU shield assembly, then the radiation dose rate might exceed the maximum allowable dose rate 1,000 mrem/hr at I-meter permitted by 10 CFR 71.

For the OP-100 package with the IR-50 Source Changer, the two orientations selected are:

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1. Side Drop on Drum at 180° Circumferential Orientation: This side orientation compounds the damage sustained by the 3 0-foot free drop and continues to attack the bolted lock box of the IR-50 Source Changer. Should this result in a failure of the lock box or significant relative deformation between the lock box and the DU shield assembly, then the radiation dose rate might exceed the maximum allowable dose rate of 1,000 mrem/hr at 1-meter permitted by 10 CFR 71.

2. CG Over Drum Closure Ring Bolt This orientation compounds the damage sustained by the 30-foot free drop and continues to attack the 5/8-inch diameter drum closure bolt of the OP-100 package with the IR-50 Source Changer. Should this deformation be sufficiently severe, the steel closure ring potentially may be dislodged and/or broken and allow the steel drum lid to separate from the drum body.

2.12.1.5.3 Puncture Drop Tests

10 CFR § 71. 73( c )(3) requires a free drop of the specimen through a distance of 40 inches onto a puncture bar "in a position for which maximum damage is expected." As in Section 2.12.1.5.2, Free Drop Tests, the "maximum damage" criterion is evaluated primarily in terms ofloss of shielding integrity. Loss of shielding integrity could occur directly by dislodging the lock box body and/or broken and allow the special form source to separate from the IR-100 body.

All puncture orientations were per the orientations identified above in Section 2.12.1.5.2, Free Drop Tests. Should a condition surface during the certification testing that results in unanticipated damage, then a new evaluation and assessment to determine most-damaging orientation(s) for the puncture drop test will be performed.

2.12.1.5.4 Thermal Test

A OP-100 packaging will be subjected to a 30-rninute, 1,475 °F thermal test in accordance with 10 CFR §71.73(c)(4). Because CTU-3 experienced the most damage during the free drop testing, a thermal test of that unit was performed in the thermal test facility described in Section 2.12.1.3, Test Facilities. The OP-100 CTU was oriented such that the through-wall piercing in the carbon steel drum shell and the gap in the closure lid would result in the possible formation of a chimney. Thus, complete combustion of the interior plywood, and possibly the foam and the DU material, would result.

2.12.1.6 Test Sequence for Selected Free Drop, Puncture Drop and Thermal Tests

The following sections establish the selected free drop, puncture drop, and thermal test sequence for the OP-100 CTUs based on the discussions provided in Section 2.12.1.5, Technical Basis for Tests . The tests sequences are summarized in Table 2.12.1-1 and illustrated in Figure 2.12.1-1 and Figure 2.12.1-2.

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2.12.1.6.1 Certification Test Unit No. 1 (CTU-1)

Free Drop No. 1 is a NCT free drop from a height of four feet, impacting the bottom of the drum. The four foot drop height is based on the requirements of 10 CFR §71.71(c)(7) for a package weight not exceeding 11,000 pounds. The purpose ofthis test was to cause maximum damage to the most vulnerable feature (lock box) on the packaging.

Free Drop No. 2 is a HAC free drop from a height of 30 feet, impacting the bottom of the drum, which is the same impact point as the NCT Free Drop No. 1. In this way, NCT and HAC free drop damage is cumulative. The 30 foot drop height is based on the requirements of 10 CFR §71.73(c)(l). The purpose of this test is to cause maximum inertia loading of the packaging.

Free Drop No. 5 is a HAC free drop from a height of 30 feet, impacting the side of the drum on the drum closure ring bolt. The 30 foot drop height is based on the requirements of 10 CFR §71.73(c)(l). The purpose of this test was intended to cause maximum load on the closure bolt/drum seam in an attempt to separate the IR-50 payload from the drum.

Puncture Drop No. 9 impacts directly onto the damage created by Free Drop Test No. 5, directly on the lock box. The puncture drop height is based on the requirements of 10 CFR §71.73(c)(3). The purpose of Puncture Drop No. 9 is to attempt to increase the damage due to Free Drop No. 5, and potential damage the lock box and displace the source capsule.

36

1 4'-o"

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2.12.1.6.2 Certification Test Unit No. 2 (CTU-2)

Free Drop No. 3 is a RAC free drop from a height of 30 feet, impacting the drum side on the closure ring bolt and weld seam. The test is performed with the CTU between -20 °F and 0 °F. The 30 foot drop height is based on the requirements of 10 CFR §71.73(c)(l). The purpose of this test is to cause maximum inertia loading of the closure ring bolt.

30' - 0"

Puncture Drop No. 7 impacts directly onto the damage created by Free Drop Test No. 3, directly on the lock box. The puncture drop height is based on the requirements of 10 CFR §71.73(c)(3). The purpose of Puncture Drop No. 7 is to attempt to increase the damage due to Free Drop No. 3, and potential damage the lock box and displace the source capsule.

2.12.1.6.3 Certification Test Unit No. 3 (CTU-3)

Free Drop No. 4 is a RAC free drop from a height of 30 feet, impacting the drum side opposite the closure ring bolt and weld seam with the IR-100. The test is performed with the CTU between -20 °F and 0 °F. The 30 foot drop height is based on the requirements of 10 CFR §71.73(c)(l). The purpose of this test is to cause maximum damage to the Safety Plug.

Puncture Drop No. 8 impacts directly onto the damage created by Free Drop Test No. 4, directly on the lock box. The puncture drop height is based on the requirements of 10 CFR §71.73(c)(3). The purpose of Puncture Drop No. 7 is to attempt to increase the damage due to Free Drop No. 3, and potentially damage the lock box and displace the source capsule.

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2.12.1.6.4 Certification Test Unit No. 4 (CTU-4)

Free Drop No. 6 is a HAC free drop from a height of 30 feet, impacting the closure ring bolt. The test is performed with the CTU at ambient temperature. The 30 foot drop height is based on the requirements of 10 CFR §71.73(c)(l). The purpose of this test is to cause maximum deformation to the closure ring/closure bolt.

Puncture Drop No. 8 impacts directly onto the damage created by Free Drop Test No. 6, directly on the closure ring bolt. The puncture drop height is based on the requirements of 10 CFR §71.73(c)(3). The purpose of Puncture Drop No. 8 is to attempt to increase the damage due to Free Drop No. 6, and potentially damage the closure ring/closure ring bolt, and separate the drum lid from the drum body.

2.12.1.7 Test Results

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40"

ll The following sections report the results of free drop, puncture drop, and thermal tests following the sequence provided in Section 2.12.1.6, Test Sequence for Selected Free Drop, Puncture Drop, and Thermal Tests. Results are summarized in Table 2.12.1-2 (refer also to Figure 2.12.1-1 and Figure 2.12.1-2).

Figure 2.12.1-3 through Figure 2.12.1-38 sequentially photo-document the certification testing process for the OP-100 CTUs.

2.12.1.7.1 Certification Test Unit No. 1 (CTU-1)

2.12.1.7.1.1 CTU-1 Free Drop Test No. 1

Free Drop No. 1 is a NCT free drop from a height of four feet, impacting the bottom of the OP-100 package. The following list summarizes the test parameters:

• verified longitudinal angle as 0° ±1°

• verified drop height as 4 feet, +3/-0 inches (actual drop height 4 feet)

• measured ambient and package temperatures as 79 °F and 93 - 97 °F respectively

• conducted test at 10:20 a.m. on Tuesday, 7 /28/98

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The packaging rebounded upon impact. There was no visible damage other than oil canning of the drum bottom by the internal plywood support structure. The impact damage is shown in Figure 2.12.1-3 .

2.12.1.7.1.2 CTU-1 Free Drop Test No. 2

Free Drop No. 2 is a HAC free drop from a height of 30 feet, impacting the bottom of the OP-100 package. The following list summarizes the test parameters:

• verified longitudinal angle as 0° ±1°

• verified drop height as 30 feet, +3/-0 inches (actual drop height 30 feet)

• measured ambient and package temperatures as 83 °F and 93 - 106 °F respectively

• conducted test at 10:33 a.m. on Tuesday, 7 /28/98

The packaging rebounded upon impact. There was no visible damage other than the continued oil canning of the drum bottom by the internal plywood support structure (deformation measured at approximately 112-inch. The impact damage is shown in Figure 2.12.1-4.

2.12.1.7.1.3 CTU-1 Free Drop Test No. 5

Free Drop No. 5 impacted directly onto the closure ring bolt/drum seam. As shown in Figure 2.12.1-5, the CTU was oriented 90° with respect to the horizontal impact surface (longitudinal angle 90°, circumferential angle 0°). The following list summarizes the test parameters:

• verified longitudinal angle as 90° ±1°

• verified circumferential angle as 0° ±1°

• verified drop height as 30 feet, +3/-0 inches (actual drop height 30 feet)

• measured ambient and package temperatures as 89 °F and 99 - 125 °F respectively

• conducted test at 11 :35 a.m. on Tuesday, 7 /28/98

The packaging rebounded upon impact. A 6-inch wide x 1/2-inch deep flat developed over the full length of the drum. No other damage was visible. The impact damage is shown in Figure 2.12.1-6.

2.12.1.7.1.4 CTU-1 Puncture Drop Test No. 9

Puncture Drop No. 7 impacted directly onto the damage created by Free Drop Test 5, directly on the lock box of the IR-100. As shown in Figure 2.12.1-7, the CTU was oriented 90° with respect to the horizontal impact surface (longitudinal angle 90°, circumferential angle 0°). The following list summarizes the test parameters:

• verified longitudinal angle as 90° ±1°

• verified circumferential angle as 0° ±1°

• verified drop height as 40inches,+1/-0 inches (actual drop height 40 inches)

• measured ambient and package temperatures as 93 °F and 105 - 115 °F respectively

• conducted test at 2:20 p.m. on Tuesday, 7/28/98

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The packaging rebounded upon impact. The lock box pierced through the outer steel shell of the drum. The impact damage is shown in Figure 2.12.1-8.

2.12.1.7.1.5 CTU-1 Post-Test Radiation Survey

Post-test radiation survey of the OP-100 CTU-1 (IR-50 payload) was performed on Tuesday, 8/19/98. The post-test radiation survey was performed using an Ir-192 special form source. Prior to removing the dummy pigtail source assembly, the position of the dummy source was measured relative to the portal outlet end. With this known position, the dummy source pigtail assembly was removed and the active radioactive source was re-installed. The strength of the source on the day of the survey was 83 Ci. To account for the maximum allowable payload of 144 Ci oflr-192, the measured values were adjusted upward by the ratio of 144/83 or 1.7349. The results of the adjusted post-test radiation survey are follows:

Source Maximum Dose Rate [Top/Bottom/Side/End] (mrem/hr) Position (in)* Surface 1-meter 2-meter

6-3/4 (6-7/8)** 85 I 86 I 115 I 61 o.5 I 0.1 I o.8 I o.5 0.1 I 0.1 I o.4 I o.4

* Measured from the source portal exit end

** Position of dummy source could not be duplicated with an active source due to the dummy pigtail/ball being jammed into the trap of the lock from the drop impact.

As indicated above, the radiation dose levels were well below the requirements of 10 CFR §71.47(a) for NCT and 10 CFR §71.51(a)(2) for RAC for a non-exclusive use shipment.

2.12.1.7.1.6 CTU-1 Post-Test Disassembly

Post-test disassembly of CTU-1 was performed on Tuesday, 8/19/98. The plywood support structure and the lower lock box were damaged. No other damage was visible. The post-test disassembly is shown in Figure 2.12.1-9 and 2.12.1-10.

2.12.1.7.2 Certification Test Unit No. 2 (CTU-2)

2.12.1.7.2.1 CTU-2 Free Drop Test No. 3

Free Drop No. 3 is a RAC free drop from a height of 30 feet, impacting the closure ring bolt. As shown in Figure 2.12.1-11 the CTU was oriented 90° with respect to the horizontal impact surface (longitudinal angle 90°, circumferential angle 0°). The following list summarizes the test parameters:

• verified longitudinal angle as 90° ± 1°

• verified circumferential angle as 0° ±1°

• verified drop height as 30 feet, +3/-0 inches (actual drop height 30 feet, 1 inch)

• measured ambient and package temperatures as 88 °F and -30/-39 °F (interior), 73 - 110 °F (surface) respectively

• conducted test at 11 :45 a.m. on Tuesday, 7 /28/98

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The packaging rebounded upon impact. The brass dust cover on the lock box pierced through the steel wall of the drum. The closure ring bolt/ring deformed approximately 1 inch. The impact damage is shown in Figure 2.12.1-12.

2.12.1.7.2.2 CTU-2 Puncture Drop Test No. 7

Puncture Drop No. 7 was intended to impact directly onto the damage created by Free Drop Test 3, directly impacting the lock box. As shown in Figure 2.12.1-13, the CTU was oriented 90° with respect to the horizontal impact surface (longitudinal angle 90°, circumferential angle 0°) . The following list summarizes the test parameters:

• verified longitudinal angle as 90° ±1°

• verified circumferential angle as 0° ±1°

• verified drop height as 40inches, +1 /-0 inches (actual drop height 40 inches)

• measured ambient and package temperatures as 96 °P and -27 °F (interior), 72 - 88 °P (surface) respectively

• conducted test at 3:08 p.m. on Tuesday, 7/28/98

The packaging rebounded upon impact. The brass dust cover on the lock box pierced through the steel wall of the drum. The impact damage is shown in Figure 2.12.1-14 and Figure 2.12.1-15.

2.12.1.7.2.3 CTU-2 Post-Test Radiation Survey

Due to the severe damage to the lock box, a radioactive special form capsule assembly could not be installed into CTU-2 to perform a post-test radiation survey (refer to Figure 2.12.1-16).

2.12.1.7.2.4 CTU-2 Post-Test Disassembly

Post-test disassembly ofIR-100 CTU-2 was performed on Tuesday, 8/19/98. The plywood support structure and the brass dust cap on the lock box were damaged. The damage is shown in Figure 2.12.1-17 and Figure 2.12.1-18.

2.12.1.7.3 Certification Test Unit No. 3 {CTU-3)

2.12.1.7.3.1 CTU-3 Free Drop Test No. 4

Free Drop No. 4 is a HAC free drop from a height of 30 feet, impacting the side of the drum opposite the closure ring bolt/weld seam. The CTU was tested at a temperature between -20 °F and 0 °F. As shown in Figure 2.12.1-19, the CTU was oriented 25° with respect to the horizontal impact surface (longitudinal angle 90°, circumferential angle 180°). The following list summarizes the test parameters:

• verified longitudinal angle as 90° ± 1°

• verified circumferential angle as 180° ± 1°

• verified drop height as 30 feet, +3/-0 inches (actual drop height 30 feet)

• measured ambient and package temperatures as 95 °F and -45/-49 °F (interior), 30 °F (surface) respectively

• conducted test at 1 :35 p.m. on Tuesday, 7/28/98

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The packaging rebounded upon impact. The lid separated from the drum body approximately 100 degrees around the circumference (radial distance approximately 15 inches). The impact produced a flat approximately 1 inch deep x 8 inches wide. The Safety Plug was loose, with a crack observed in the knurled section. The impact damage is shown in Figure 2.12.1-20 and Figure 2.12.1-21.

2.12.1.7.3.2 CTU-3 Puncture Drop Test No. 8

Puncture Drop No. 8 was intended to impact directly onto the damage created by Free Drop Test 4, directly impacting side of the drum opposite the closure ring bolt/weld seam. The CTU was tested at a temperature between -20 °F and 0 °F. As shown in Figure 2.12.1-22, the CTU was oriented 68° with respect to the horizontal impact surface (longitudinal angle 90°, circumferential angle 180°). The following list summarizes the test parameters:

• verified longitudinal angle as 90° ± 1°

• verified circumferential angle as 180°±1°

• verified drop height as 40 inches, + 1/-0 inches (actual drop height 40 inches)

• measured ambient and package temperatures as 95 °F and-23/-25 °F (interior), 74 - 91 °F (surface) respectively

• conducted test at 3:40 p.m. on Tuesday, 7/28/98

The packaging rebounded upon impact. The impact resulted in a slight increase of the opening in the drum lid at approximately 90° from impact point. The Safety Plug produced a through­wall puncture of approximately 1 Y2 inches in diameter. The impact also further compressed the drum shell/closure ring. The impact damage is shown in Figure 2.12.1-23.

2.12.1.7.3.3 CTU-3 Thermal Test

Since CTU-3 was the most damaged test unit, it was selected for the thermal test. The following list summarizes the test parameters:

• The OP-100 CTU-3 was orientated in the upright position, with the closure lid facing downward (longitudinal angle 180°, circumferential angle NA). The CTU was placed on fire bricks to provide as much surface area as possible for heat transfer during the test (refer to Figure 2.12.1-24).

• A Type K thermocouple was installed on each side of the packaging to monitor the temperature of the package throughout the test.

• Consistent with discussions with the NRC Storage and Transportation Package Section, pressurized air was introduced into the oven near the test article once the minimum package temperature reached 1,475 °F. After re-establishing a minimum of 1,475 °F, the test was started.

• Commenced thermal testing (minimum 1,475 °F package temperature after air introduction) at 10:36 a.m. on Tuesday, 8/11/98.

• Completion of thermal test at 11:06 a.m. on Tuesday, 8/11/98 (refer to Figure 2.12.1-25).

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2.12.1.7.3.4 CTU-3 Post-Test Radiation Survey

Post-test radiation survey of the OP-100 CTU-3 was performed on Tuesday, 8/19/98. The post­test radiation survey was performed using an Ir-192 special form source. Prior to removing the dummy pigtail source assembly, the position of the dummy source was measured relative to the portal outlet end. With this known position, the dummy source pigtail assembly was removed and the active radioactive source was re-installed. The strength of the source on the day of the survey was 83 Ci. To account for the maximum allowable payload of 144 Ci of Ir-192, the measured values were adjusted upward by the ratio of 144/83 or 1.7349. The results of the adjusted post-test radiation survey are follows:

Source Maximum Dose Rate [Top/Bottom/Side/End] (mrem/hr) Position (in)* Surface 1-meter 2-meter

6-9/16 121 I 92 I 1s2 I 73 0.1 I 0.1 I o.s I u 0.1 I 0.1 I 0.1 I 0.1

* Measured from the source portal exit end

As indicated above, the radiation dose levels were well below the requirements of 10 CFR §71.47(a) for NCT and 10 CFR §71.51(a)(2) for HAC for a non-exclusive use shipment.

2.12.1.7.3.5 CTU-3 Post-Test Disassembly

Post-test disassembly of OP-100 CTU-3 was performed on Tuesday, 8/19/98. Upon removal of the drum lid, the plywood support structure was found to be totally consumed by the test. Both the lock box dust cap and the Safety Plug were found to be damaged due to the free drop tests. No other damage of the IR-100 payload was visible (refer to Figures 2.12.1-26 and 2.12.1-27.

An abrasive cutting wheel was utilized to cut and remove one side of the stainless steel housing sheet of the IR-100 payload. Upon removal of the stainless steel sheet, the presence of foam char demonstrated the intumescent behavior of the polyurethane foam, as shown in Figure 2.12.1-28. Following removal of the foam char, visual examination of the DU gamma shield and the DU support brackets was performed. As shown in Figures 2.12.1-29, 2.12.1-30, and 2.12.1-31, there was no indication of any weld/structural failure or deterioration of the DU shield material or the DU support brackets.

2.12.1.7.4 Certification Test Unit No. 4 (CTU-4)

2.12.1.7.4.1 CTU-4 Free Drop Test No. 6

Free Drop No. 6 is a HAC free drop from a height of 30 feet, impacting the closure ring bolt. As shown in Figure 2.12.1-32, the CTU was oriented 140° with respect to the horizontal impact surface (longitudinal angle 140°, circumferential angle 0°). The following list summarizes the test parameters:

• verified longitudinal angle as 140° ±1°

• verified circumferential angle as 0° ± 1°

• verified drop height as 30 feet, +3/-0 inches (actual drop height 30 feet)

• measured ambient and package temperatures as 96 °F and 107 - 118 °F respectively

• conducted test at 12:03 p.m. on Tuesday, 7/28/98

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The packaging rebounded upon impact. The closure ring deformed inward, with both the handle edge and the lock box piercing the shell of the drum. In addition, the pigtail plug end and lock were damaged. The impact damage is shown in Figure 2.12.1-33.

2.12.1.7.4.2 CTU-4 Puncture Drop Test No. 10

Puncture Drop No. 10 was intended to impact directly onto the damage created by Free Drop Test 6, directly impacting the closure ring bolt. As shown in Figure 2.12.1-34, the CTU was oriented 140° with respect to the horizontal impact surface (longitudinal angle 140°, circumferential angle 0°). The following list summarizes the test parameters:

• verified longitudinal angle as 140° ± 1°

• verified circumferential angle as 0° ±1°

• verified drop height as 40inches,+1/-0 inches (actual drop height 40 inches)

• measured ambient and package temperatures as 98 °F and 103 - 110 °F respectively

• conducted test at 1 :02 p.m. on Tuesday, 7 /28/98

The packaging rebounded upon impact. The impact continued driving the closure ring bolt/closure ring inward, resulting in further tearing of the outer steel shell. The impact event and damage are shown in Figure 2.12.1-35 and Figure 2.12.1-36 respectively.

2.12.1.7.4.3 CTU-4 Post-Test Radiation Survey

Post-test radiation survey of the OP-100 CTU-4 was performed on Tuesday, 8/19/98. The post­test radiation survey was performed using an Ir-192 special form source. Prior to removing the dummy pigtail source assembly, the position of the dummy source was measured relative to the portal outlet end. The dummy source was found to have moved approximately 114 inch from its pre-test position (later attributable to the free movement of the DU gamma shield during disassembly). With this known position, the dummy source pigtail assembly was removed and the active radioactive source was re-installed. The strength of the source on the day of the survey was 83 Ci. To account for the maximum allowable payload of 144 Ci oflr-192, the measured values were adjusted upward by the ratio of 144/83 or 1.7349. The results of the adjusted post-test radiation survey are follows:

Source Maximum Dose Rate [Top/Bottom/Side/End] (mrem/hr) Position (in)* Surface 1-meter 2-meter

6-15116 108 I 61 I 152 I 13 0.1 I o.8 I u I 2.3 0.1 I 0.1 I 0.1 I o.4

* Measured from the source portal exit end

As indicated above, the radiation dose levels were well below the requirements of 10 CFR §71.47(a) for NCT and 10 CFR §71.51(a)(2) for HAC for a non-exclusive use shipment.

2.12.1.7.4.4 CTU-4 Post-Test Disassembly

Post-test disassembly of OP-100 CTU-4 was performed on Tuesday, 8/19/98. The plywood support structure and the handle were damaged. The damage is shown in Figure 2.12.1-37 and Figure 2.12.1-38.

In conclusion, the OP-100 packaging design has been demonstrated to satisfy the requirements of Subpart F, 10 CFR 71 for the transportation of special form radioactive material.

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Table 2.12.1-1 - Summary of OP-100 Certification Tests in Sequential Order1

Test Test Description Temperature Test Unit Angular Orientation

No. (Certification Test Unit No.) (as measured) 92 ~3

1 4 foot bottom drop w/ IR-50 (CTU-1) 93 - 97 °P oo NA

2 30 foot bottom drop w/ IR-50 (CTU-1) 93-106°P oo NA

30 foot side drop on drum closure ring -22/-32 op (interior) 3 bolt, weld seam w/ IR-100 (CTU-2) 73 - 110+ 0P 90° oo

(surface)

30 foot side drop on side opposite drum -22/-32 °P (interior)

4 73 - 110+ 0 P 90° 180° closure ring bolt w/ IR-100 (CTU-3)

(surface)

5 30 foot side drop on drum closure ring bolt

99 - 125 °P 90° oo w/ IR-50 (CTU-1)

6 30 foot, CG over drum closure ring bolt w/

107 - 118 °P 131° oo IR-50 (CTU-4)

7 Puncture drop on drum side w/ IR-100 -24/-25 °P (interior)

90° oo (CTU-2) 72 - 88 °F (surface)

8 Puncture drop on drum side w/ IR-100 -23/-25 op (interior)

90° 180° (CTU-3) 74 - 91 op (surface)

9 Puncture drop on drum side w/ IR-50

105 - 115 °P 90° 180° (CTU-1)

10 Puncture drop, CG over drum closure ring

103 - 110 °P 131° oo bolt w/ IR-50 (CTU-4)

11 Thermal Test (CTU-3) Ave. 1,553 °P oo NA

Notes:

1. Tested 7/28/98 and 8/11/98 .

2. Longitudinal angle, 9 , is relative to long axis of packaging (i.e., 0° is vertical).

Remarks

Docket No. 71-9185 Revision 6, 10/2018

NCT impact on most probable orientation in field to cause damage.

HAC impact on region to cause maximum inertia loading.

HAC impact producing maximum load on closure bolt/drum seam.

HAC impact to attack the Safety Plug opposite the lock box.

HAC impact producing maximum load on closure bolt/drum seam.

HAC impact to cause maximum deformation of drum closure ring.

Puncture in area expected to increase damage of drum/IR- I 00 resulting from free drop.

Puncture in area expected to increase damage of drum/IR-100 resulting from free drop.

Puncture in area expected to increase damage of drum/IR-50 resulting from free drop.

Puncture in area expected to increase damage of drum/IR-50 resulting from free drop.

Thermal testing of most damaged CTU.

3 . Circumferential angle, <j>, is relative to rotation of package around longitudinal axis (i.e., 0° is closure bolt).

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Figure 2.12.1-1 - Schematic Summary of CTU Testing with I R-100 Device

L __ ~ _ __p

Figure 2.12.1-2 - Schematic Summary of CTU Testing with IR-50 Device

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Figure 2.12.1-3 - CTU-1 Free Drop Test No. 1: View of Drum Bottom Following Impact

INC OP- lOC

C TU-I

TE~r NO.Z Figure 2.12.1-4- CTU-1 Free Drop Test No. 2: Measured Bottom Deformation (-1/2 inch)

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Figure 2.12.1-5- CTU-1 Free Drop Test No. 5: Side Drop on Closure Bolt

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Figure 2.12.1-6 - CTU-1 Free Drop Test No.5: Flattening of Drum Side Following Impact

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cru - 1

T£sr NC. 9

Figure 2.12.1-7 - CTU-1 Puncture Drop Test No. 9 Just Prior to Impact

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Figure 2.12.1-8- CTU-1 Puncture Drop Test No. 9: Damage to Drum Side

Figure 2.12.1-9- CTU-1 Post-Test Disassembly: Condition of Plywood Support Structure

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· CAlUTION R DIOACT

MATERA

Figure 2.12.1-10- CTU-1 Post-Test Disassembly: Condition of Lock Box/Dust Cap

TN C OP-!00

CTU-2

IE.ST NO. s

Figure 2.12.1-11 - CTU-2 Free Drop Test No. 3 Side Drop on Closure Bolt

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Figure 2.12.1-12- CTU-2 Free Drop Test No. 3: Damage to Drum Shell/Closure Bolt

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J. /v l O~ ~ lOO

cru-2

1esr Ne. 7

I ! I

Docket No. 71-9185 Revision 6, 10/2018

: II'

Figure 2.12.1-13 - CTU-2 Puncture Drop Test No. 7 Immediately Prior to Impact

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· _ .. ; . _-

Figure 2.12.1-14- CTU-2 Puncture Drop Test No. 7: Damage to Drum Side (Side View)

Figure 2.12.1-15 - CTU-2 Puncture Drop Test No. 7: Damage to Drum Side (Front View)

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Figure 2.12.1-16- CTU-2 Post-Test Disassembly: Jammed Ball into Trap

Figure 2.12.1-17 - CTU-2 Post-Test Disassembly: Condition of Plywood Support Structure

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Figure 2.12.1-18-CTU-2 Post-Test Disassembly: Jammed Lock Box Dust Cap & Indicator

CTU-3

TJJ'Sr NO. l.fi

Figure 2.12.1-19-CTU-3 Free Drop Test No. 4: Side Drop on Side Opposite Closure Bolt

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Figure 2.12.1-20- CTU-3 Free Drop Test No. 4: Damage to Closure Lid

~

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Figure 2.12.1-21 - CTU-3 Free Drop Test No. 4: Damage to Drum Shell by Safety Plug

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Figure 2.12.1-22 - CTU-3 Puncture Drop Test No. 8 Just Prior to Impact

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Figure 2.12.1-23- CTU-3 Puncture Drop Test No. 8: Damage to Drum Shell

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Figure 2.12.1-24- CTU-3 Thermal Test No. 11 Just Prior to Insertion Into Oven

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- :, .. ·-

... · .... J

, \ ... · .......

., . .. .. .. .

Docket No. 71-9185 Revision 6, 10/2018

Figure 2.12.1-25-CTU-3 Thermal Test No. 11 Immediately Upon Removal from Oven

Figure 2.12.1-26 - CTU-3 Post-Test Disassembly: Damaged Lock Box Dust Cap

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Figure 2.12.1-27 - CTU-3 Post-Test Disassembly: Damaged Safety Plug

Docket No. 71-9185 Revision 6, 10/2018

Figure 2.12.1-28- CTU-3 Post-Test Disassembly: Illustrating Polyurethane Foam Char

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Figure 2.12.1-29 - CTU-3 Post-Test Disassembly: Interior Cavity with Foam Debris Removed

Figure 2.12.1-30 - CTU-3 Post-Test Disassembly: DU Support Bracket M/elds and Copper Shims

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Figure 2.12.1-31 - CTU-3 Post-Test Disassembly: DU Support Bracket M/elds and Copper Shims

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~ J C OP '00 C TU - If

Docket No. 71-9185 Revision 6, 10/2018

Figure 2.12.1-32 - CTU-4 Free Drop Test No. 6: CG Over Closure Bolt

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C TU -If

!€Sr Nl . JO

Figure 2.12.1-34-CTU-4 Puncture Drop Test No. 10 Setup

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Figure 2.12.1-35 - CTU-4 Puncture Drop Test No. 10 Immediately Prior to Impact

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Figure 2.12.1-36-CTU-4 Puncture Drop Test No. 10: Damage to Drum Shell Due to Lock Box

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CAUTION RADIOACTIVE

MATERIAL

•• SPECIAL FORM N.O.S. UN2974

Figure 2.12.1-38-CTU-4 Post-Test Disassembly: Condition of Handle

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2.12.2 Supplementary Certification Tests

Docket No. 71-9185 Revision 6, 10/2018

Presented herein are the results of supplementary hypothetical accident condition (RAC) tests that address free drop performance of the polyurethane foam support structure per the requirements of 10 CFR 71 8

. The Supplementary Certification Tests are fully documented in the certification test report9

. Note that the CTU identifications in the test report were CTU-1 and CTU-2, which correspond to CTU-5 and CTU-6, respectively, are utilized in this appendix.

2.12.2.1 Introduction

The OP-100 packaging with the optional polyurethane foam support structure, when subjected to the RAC free drop tests specified in 10 CFR §71.73, is shown to meet the performance requirements specified in Subpart E of 10 CFR 71. As indicated in the introduction to Chapter 2. 0, Structural Evaluation, the primary proof of performance for the RAC tests is via the use offull­scale testing.

2.12.2.2 Summary

As seen in the figures presented in Section 2.12.2.7, Test Results, successful testing of the CTUs indicates that the various OP-100 packaging design features are adequately designed to withstand the RAC free drop tests specified in 10 CFR § 71. 73. The most important result of the supplementary testing program was the demonstrated ability of the OP-100 packaging with the polyurethane foam support structure to maintain the shielding integrity of the IR-100 or IR-50 payloads.

Significant results of the supplementary free drop tests are as follows:

• No failure of the drum closure lid/closure ring bolt occurred that would have permitted the potential separation of the payload from the protective overpack.

• No evidence of excessive distortion of the lock box occurred that would have significantly displaced the special form source from its desired shielded position.

• There was no evidence of rupturing of the stainless steel housing that could have resulted in thermal degradation of the DU gamma shield by excessive oxidation in a subsequent fire event.

2.12.2.3 Test Facilities

The drop testing was performed utilizing a horizontal concrete slab, which is approximately 9-12 inches x 10 feet x 15 feet. A 2 inch x 48 inch x 48 inch steel plate was placed on top of the concrete slab, grouted, and secured to the concrete pad by four (4) 5/8-inch anchor bolts. Utilizing only the concrete directly underneath the steel plate as being effective and a minimum thickness of 4 inches, the estimated mass of the drop pad is 2, 100 lbm, which is more than 27 times the mass of the OP-100 CTU. Based on these characteristics, the drop pad conservatively satisfies the requirement of 10 CFR § 71. 73 for an essentially unyielding, horizontal surface.

8 Title 10, Code of Federal Regulations, Part 71 (10 CFR 71) Packaging and Transportation of Radioactive Material, 1-1-18 Edition.

9 Orano Federal Services LLC, OFS Document TR-3021513-000, Test Report f or Supplementary Tests of the OP-JOO Package, Revision 0, October 2018.

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2.12.2.4 Certification Test Unit Description

Docket No. 71-9185 Revision 6, 10/2018

The OP-100 package consists of a 10-gallon steel drum that houses a plywood or polyurethane foam support structure, and either a Model IR-100 Exposure Device or a Model IR-50 Source Changer. For the supplementary certification tests, only the polyurethane foam support structure was tested to demonstrate that the package response is bounded by free drop testing with the plywood support structure. The drum for the polyurethane foam support structure is certified to comply with DOT/UN Standard No. 1A2/X120/S (steel drum w/ removable head, satisfies Packaging Groups I, II, & III Tests, intended for solids [Gross Weight 120 kg] or inner packagings). The polyurethane support structure centrally locates the Model IR-100 or the Model IR-50 payload within the steel drum overpack. The maximum gross weight of the OP-100 package is 77 pounds.

The IR-50 Source Changer consists of a zircaloy or titanium source tube surrounded by a painted depleted uranium (DU) shield. The DU shield assembly is encased within a welded stainless steel housing. Stainless steel support brackets, welded to the inner housing surface, capture the DU gamma shield between the support bracket and the inner surface of the stainless steel housing. Copper shim stock is installed in the DU-stainless steel interfaces to preclude a reaction between the two dissimilar metals. The void space between the DU shield assembly and the inner stainless steel housing is filled with approximately 2 pounds of rigid polyurethane foam, which prevents moisture from contacting the DU material.

Prior to free drop testing, two OP-1 OO/IR-50 CTUs were loaded with a dummy source capsule assembly to simulate an Ir-192/Se-75 special form capsule. The actual weight was 72.0 pounds (CTU-5) and 72.5 pounds (CTU-6) for the OP-100/IR-50 CTUs. Aside from the dummy source capsule assembly, the CTUs were identical to the OP-100 packaging design depicted in Appendix 1.3.1, General Arrangement Drawings.

2.12.2.5 Technical Basis for Tests

For the confinement system to fail, both the OP-100 and the IR-50 Source Changer would need to fail in order to reduce the effectiveness of the DU gamma shielding. This potential failure mode may only occur if either of the following conditions occurs:

1. The lock box of the Model IR-50 Source Changer is broken free of the stainless steel housing or damaged such that the source capsule is significantly moved from its stored position in the DU gamma shield.

2. The DU shield assembly translates away from the lock box/pigtail assembly and the source is significantly moved from its stored position.

For either of these potential conditions to be initiated, the IR-50 Source Changer would either need to be ejected out of the OP-100 package or sustained significant damage within the 10-gallon drum due to the hypothetical accident condition free drops. Therefore, the primary objective of the 9-meter (30-foot) hypothetical accident condition (RAC) free drops is to damage the OP-100 package that results in subsequent damage to the payload package.

The following sections provide the technical basis for the chosen test orientations and sequences for the OP-100 CTUs as presented in Appendix 2.12.3 .6, Test Sequence for Selected Free Drop, Puncture Drop, and Thermal Tests .

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2.12.2.5.1 Temperature

Docket No. 71-9185 Revision 6, 10/2018

Certification testing the OP-100 package with the polyurethane foam structure was performed at temperatures at-37.5 °F (-39 °C) and as high as 101 °F (38 °C). The results of the OP-100 package supplementary testing demonstrated that extreme temperatures had no effect on the shielding integrity of the IR-50 payload. In addition, the austenitic stainless steel and DU materials are not susceptible to brittle fracture, as delineated in Section 2.1.2.2.1 , Brittle Fracture.

2.12.2.5.2 Free Drop Tests

The OP-100 package is qualified primarily by full scale testing, with acceptance criterion being the ability to demonstrate shield integrity. Per 10 CFR §71.73(c)(l), the package is required to "strike an essentially unyielding surface in a position for which maximum damage is expected." Therefore, for determining the drop orientations that satisfy the regulatory "maximum damage" requirement, attention is focused predominately on the issue of shield integrity.

To maximize the damage to the Model OP-100 package and potentially opening the drum lid or damaging the IR-50 payload, four orientations have been selected for the free drop testing:

1. Bottom Drop on Drum (Hot): This orientation targets the lock box of the IR-50 payload. The hot test condition also maximizes the deformation of the drum body. Should this impact be sufficiently severe, the IR-50 lock box may be damaged, which could result in significant movement of the source.

2. Top Down, CG-Over-Closure Ring (Hot): This orientation targets the lock box assembly of the IR-50 payload. The hot condition also maximizes the deformation to the drum and closure ring. The intent ohhis orientation is to attempt to damage the IR-50 lock box, and the steel drum lid of the OP-100 package. Should this impact be sufficiently severe, the steel closure ring may be dislodged and/or broken and allow the steel drum lid to separate from the drum body.

3. Top Down Drop (Cold): This orientation targets the steel drum lid and the lock box of the IR-50 payload. The cold test condition (-20 °F) maximizes the impact forces on the IR-50 payload. Should this impact be sufficiently severe, the IR-50 lock box may be damaged, which could result in significant movement of the source.

4. CG Over Drum Bottom (Cold): This orientation targets the lock box assembly of the IR-50 payload and the steel drum body. The cold test condition (-20 °F) maximizes the impact forces on the steel drum and the IR-50 payload. The intent ohhis orientation is to attempt to damage the IR-50 lock box, and possibly ovalize the drum body to attempt to separate the steel drum lid from the drum body. Should this impact be sufficiently severe, the deformation may dislodge the steel drum lid from the drum body and possibly cause the IR-50 payload to separate from the drum body.

2.12.2.6 Test Sequence for Selected Free Drop Tests

The following sections establish the selected free drop test sequence for the OP-100 CTUs based on the discussions provided in Section 2.12.2.5, Technical Basis for Tests. The tests sequences are summarized in Table 2.12.2-1 and illustrated in Figure 2.12.2-1 and Figure 2.12.2-2.

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2.12.2.6.1 Certification Test Unit No. 5 (CTU-5)

Free Drop No. 12 is a RAC free drop from a height of 30 feet, impacting the bottom of the drum. The 30 foot drop height is based on the requirements of 10 CFR §71.73(c)(l). The test is performed with the CTU at hot temperature. The purpose of this test is to cause maximum inertia loading of the packaging.

Free Drop No. 13 is a RAC free drop from a height of 30 feet, impacting the closure ring bolt. The test is performed with the CTU at ambient temperature. The 30-foot drop height is based on the requirements of 10 CFR §71.73(c)(l). The test is performed with the CTU at hot temperature. The purpose of this test is to cause maximum deformation to the closure ring/closure bolt.

2.12.2.6.2 Certification Test Unit No. 6 (CTU-6)

Free Drop No. 14 is a RAC free drop from a height of 30 feet, impacting the top of the drum. The 30-foot drop height is based on the requirements of 10 CFR §71.73(c)(l). The test is performed with the CTU at cold temperature. The purpose of this test is to cause maximum inertia loading of the packaging.

Free Drop No. 15 is a RAC free drop from a height of 30 feet, impacting the bottom comer of the drum. The test is performed with the CTU at cold temperature. The 30-foot drop height is based on the requirements of 10 CFR §71.73(c)(l). The purpose of this test is to cause maximum deformation to the drum body, and dislodge the lid.

2.12.2.7 Test Results

Docket No. 71-9185 Revision 6, 10/2018

I ~ 1 11

-

The following sections report the results of free drop, puncture drop, and thermal tests following the sequence provided in Section 2.12.2.6, Test Sequence for Selected Free Drop Tests. Results are summarized in Table 2.12.1-2 (refer also to Figure 2.12.2-1 and Figure 2.12.2-2).

Figure 2.12.2-3 through Figure 2.12.2-10 sequentially photo-document the certification testing process for the OP-100 CTUs.

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2.12.2.7.1 Certification Test Unit No. 5 (CTU-5)

2.12.2.7.1.1 CTU-5 Free Drop Test No. 12

Docket No. 71-9185 Revision 6, 10/2018

Free Drop No. 12 is a HAC free drop from a height of 30 feet, impacting the bottom of the OP-100 package. The following list summarizes the test parameters:

• verified longitudinal angle as 0° ±1°

• verified drop height as 30feet,+11-0 inches (actual drop height 30 feet)

• measured ground and package foam temperatures as 7 5-7 6 °F and 101 °F, respectively

• conducted test at 10:20 a.m. on Tuesday, 9/1 1/18

The package slightly rebounded upon impact. There was no visible damage other than some minor buckling of the outer shell, and oil canning of the drum bottom by the internal polyurethane foam support structure. No other damage was observed. The impact damage is shown in Figure 2.12.1-3.

2.12.2.7.1.2 CTU-5 Free Drop Test No. 13

Free Drop No. 13 is a HAC free drop from a height of 30 feet, impacting the closure ring bolt. The following list summarizes the test parameters:

• verified longitudinal angle as 141° ± 1°

• verified drop height as 30 feet, + 11-0 inches (actual drop height 30 feet)

• measured ground and package foam temperatures as 75-77 °F and 95 .9 °F, respectively

• conducted test at 9:48 a.m. on Tuesday, 9/11/18

The package rotated and struck the bottom edge upon impact. The primary impact drove the bolt ring into the top of the drum, which measured approximately 11 inches wide. The impact damage is shown in Figure 2.12.2-4.

2.12.2.7.1.3 CTU-5 Post-Test Disassembly

Post-test disassembly of OP-100 CTU-5 was performed on Wednesday, 9/26/18. As expected, the polyurethane foam support structure was slightly damaged. However, the IR-50 Source Changer payload was not damaged from the free drop impacts. The damage is shown in Figure 2.12.2-5 and Figure 2.12.2-6

2.12.2.7.1.4 CTU-5 Post-Test Radiation Survey

Post-test radiation survey of the OP-100 CTU-5 (IR-50 payload) was performed on Wednesday, 9/26/18. The post-test radiation survey was performed using an Ir-192 special form source. The strength of the source on the day of the survey was 102 Ci. To account for the maximum allowable payload of 144 Ci of Ir-192, the measured values were adjusted upward by the ratio of 144/1 02 or 1.412. The results of the post-test radiation survey are follows:

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Test Unit Maximum Dose Rate [Top/Bottom/End] (mrem/hr) Number

I I (Serial Number) Surface 1-meter 2-meters

CTU-5 (3012) 61 I 165 I 90 I 0.0 I 1.4 I 0.0 I 0.0 I 0.0 I 0.0

As indicated above, the radiation dose levels satisfy the requirements of 10 CFR §71.47(a) for NCT and 10 CFR §71.51(a)(2) for RAC for a non-exclusive use shipment.

2.12.2.7.2 Certification Test Unit No. 6 (CTU-6)

2.12.2.7.2.1 CTU-6 Free Drop Test No. 14

Free Drop No. 14 is a RAC free drop from a height of 30 feet, impacting the top of the OP-100 package. The following list summarizes the test parameters:

• verified longitudinal angle as 180° ± 1.1°

• verified drop height as 30feet,+1/-0 inches (actual drop height 30 feet)

• measured ground and package foam temperatures as 75-77 °F and-37.5 °F, respectively

• conducted test at 10:20 a.m. on Tuesday, 9/11/18

The package slightly rebounded upon impact. There was no visible damage other than oil canning of the drum lid by the internal polyurethane support structure. The impact damage is shown in Figure 2.12.2-7.

2.12.2.7.2.2 CTU-6 Free Drop Test No. 15

Free Drop No. 15 is a RAC free drop from a height of 30 feet, impacting the bottom comer of the drum. The following list summarizes the test parameters:

• verified longitudinal angle as 45° ±1°

• verified drop height as 30feet,+1/-0 inches (actual drop height 30 feet)

• measured ground and package foam temperatures as 81-82 °F and -37.5 °F, respectively

• conducted test at 10:35 a.m. on Tuesday, 9/11/18

The package rotated and struck the top edge upon impact. The primary impact created a deformed area that measured approximately 2Yz" x 9Yz" on bottom comer edge, with minor damage to the bolt ring edge from the secondary impact. No other damage was observed. The impact damage is shown in Figure 2.12.2-8.

2.12.2.7.2.3 CTU-6 Post-Test Disassembly

Post-test disassembly ofOP-100 CTU-6 was performed on Wednesday, 9/26/18. As expected, the polyurethane foam support structure was slightly damaged. However, the IR-50 Source Changer payload was not damaged from the free drop impacts. The damage is shown in Figure 2.12.2-9 and Figure 2.12.2-10.

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2.12.2.7.2.4 CTU-6 Post-Test Radiation Survey

Post-test radiation survey of the OP-100 CTU-6 (IR-50 payload) was performed on Wednesday, 9/26/18. The post-test radiation survey was performed using an Ir-192 special form source. The strength of the source on the day of the survey was 102 Ci. To account for the maximum allowable payload of 144 Ci of Ir-192, the measured values were adjusted upward by the ratio of 144/102 or 1.412. The results of the post-test radiation survey are follows:

Test Unit Maximum Dose Rate [Top/Bottom/End] (mrem/hr) Number

I I (Serial Number) Surface 1-meter 2-meters

CTU-6 (3137) 123 I 85 I 75 I 0.0 I 0.0 I 1.4 I 0.0 I 0.0 I As indicated above, the radiation dose levels were well below the requirements of 10 CFR §71.47(a) for NCT and 10 CFR §71.51(a)(2) for HAC for a non-exclusive use shipment.

0.0

In conclusion, the OP-100 packaging design with the polyurethane foam support structure has been demonstrated to satisfy the requirements of Subpart F, 10 CFR 71 for the transportation of special form radioactive material.

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Table 2.12.2-1 - Summary of OP-100 Supplementary Certification Tests in Sequential Order1

Foam Test Unit Angular Orientation Test Test Description Temperature e2 ~3 No. (Certification Test Unit No.) (as measured) Remarks

12 30 foot, bottom down 101 Of oo NA

RAC impact on most probable orientation in field; hot (CTU-5) condition maximizes deformation.

13 30 foot, top down, 95.9 Of 141 ° NA

HAC impact on lid closure ring and closure ring bolt; hot CG-over-comer (CTU-5) condition maximizes deformation.

14 30 foot, top down -37.5 Of 180° oo HAC impact on lid; cold condition maximizes impact

(CTU-6) deceleration on payload.

15 30 foot, bottom down, CG-over-comer -37.5 Of 45° 180°

HAC impact on bottom comer; cold condition maximizes (CTU-6) deformation and impact deceleration on payload.

Notes:

1. All tests performed on 9/11118.

2. Longitudinal angle, 0, is relative to long axis of packaging (i.e., 0° is vertical).

3. Circumferential angle, ~' is relative to rotation of package around longitudinal axis (i.e., 0° is closure bolt).

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.,.

t~ . 12

Figure 2.12.2-1 - Schematic Summary of CTU-5 Testing

' 14 :

~

, 15

Figure 2.12.2-2 - Schematic Summary of CTU-6 Testing

80

13

. ~ .

~

Docket No. 71-9185 Revision 6, 10/2018

BOLT/RING

BOLT/RING

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INC OP-100 Package Safety Analysis Report Docket No. 71-9185 Revision 6, 10/2018

Figure 2.12.2-3 - CTU-5 Free Drop Test No. 12: View of Drum Following Impact

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Figure 2.12.2-4 - CTU-5 Free Drop Test No. 13: Damage to Bolt/Closure Ring

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Figure 2.12.2-5 - CTU-5 Post-Test Disassembly: View of Lower Foam Support Structure

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Figure 2.12.2-6 - CTU-5 Post-Test Disassembly: View of IR-50 Source Changer

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Figure 2.12.2-7 - CTU-6 Free Drop Test No. 14: Damage to Top of Drum

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INC OP-100 Package Safety Analysis Report

Docket No. 71-9185 Revision 6, 10/2018

Figure 2.12.2-8 - CTU-6 Free Drop Test No. 15: Damage to Bottom Edge of Drum

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Figure 2.12.2-9- CTU-6 Post-Test Disassembly: View of Lower Foam Support Structure

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Figure 2.12.2-10 - CTU-6 Post-Test Disassembly: View of IR-50 Source Changer

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INC OP-100 Package Safety Analysis Report

3.0 THERMAL EVALUATION

Docket No. 71-9185 Revision 6, 10/2018

This chapter establishes the compliance of the OP-100 package transporting a payload of up to 144 Ci (5.3 TBq) oflr-192 or Se-75 in special form with the thermal requirements of 10 CFR §71 10

.

3.1 Description of Thermal Design

3.1.1 Design Features

The OP-100 package and the IR-100/IR-50 payloads do not contain any specific thermal design features. The thermal performance of the package is demonstrated by test. Therefore, this section does not apply.

3.1.2 Content's Decay Heat

The OP-100 package may contain up to 144 Ci (5.3 TBq) oflr-192 or Se-75 in special form. The radiolytic decay heat of Ir-192 is 7 .03 x 10-3 W/Ci 11

. The radiolytic decay heat of Se-75 is 2.41 x 10-3 W /Ci9

. Since the radiolytic decay heat of Ir-192 is greater than the radiolytic decay heat of Se-75, the heatload of the lr-192 payload bounds the Se-75 payload. Therefore, the maximum decay heat load for the package is therefore 1.01 W (3.44 Btu/hr), which is negligible.

3.1.3 Summary Tables of Temperatures

The maximum surface temperature of the OP-100 package is 137 °F (58 °C), as documented in Appendix 3.6.1, Determination of Maximum Surface Temperature for OP-100 Package, in full sunlight.

3.1.4 Summary Tables of Maximum Pressures

The containment of the OP-100 package is provided by the special form payload. Gas can freely move from the internal cavity to the environment during all phases of operation. Therefore, there are no internal pressures to be determined, since the OP-100 package does not contain any pressure boundaries.

3.2 Material Properties and Component Specifications

3.2.1 Material Properties

The OP-100 packaging is constructed of a 10-gallon carbon steel drum, with a 20-gauge (0.0359 inch) thick body and lid. The drum lid is attached to the body with a 12-gauge (0.105 inch) thick carbon steel closure ring, which is secured with a 5/8-inch x 4 inch hex bolt and nut. A plywood or polyurethane foam support structure positions the payload in the center of the drum cavity.

10 Title 10, Code of Federal Regulations, Part 71 (10 CFR 71), Packaging and Transportation of Radioactive Material, 1-1-18 Edition. 11 ORIGEN-S Decay Data Library and Half-Life Uncertainties, 0. W. Hermann, P. R. Daniel, and J.C. Ryman, Oak Ridge National Laboratory, ORNL/TM-13624, September 1998.

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The IR-100 Exposure Device and the IR-50 Source Changer are constructed of a 12-gauge (0.105 inch) thick stainless steel outer skin surrounding polyurethane foam and a depleted uranium gamma shield. Since the structural integrity of the package is established by testing, the only pertinent temperature limits on the components is established by their melting temperatures for the fire based Hypothetical Accident Condition (HAC). The melting temperatures for uranium and stainless steel are 2,071 °P (1 ,133 °C) and 2,800 °P (1 ,588 °C), respectively.

The payload was qualified per Qualification of Special Form Radioactive Material, in 10 CPR §71.75(b)(4).

3.2.2 Component Specifications

The OP-100 package does not contain any component or material that is important to the thermal performance of the package. The two primary structural materials are austenitic stainless steel and the DU gamma shield. As noted in Section 2.1.2.2.1, Brittle Fracture, both materials have been tested to temperatures below -20 °P (-29 °C) with no loss of structural or shielding capability.

3.3 Thermal Evaluation under Normal Conditions of Transport

This section presents the thermal evaluation of the OP-100 package under the normal conditions of transport (NCT) per 10 CPR §71.71.

3.3.1 Heat and Cold

Since the total decay heat load of the OP-100 package is approximately 1 W (3.5 Btu/hr), a detailed analysis of the package and internals is unnecessary. The peak internal temperatures will very closely match those on the surface of the package.

Per 10 CPR §71.7l(c)(l), the worst-case high temperature conditions for the package consist of an ambient temperature of 100 °P and maximum insolation. Under those conditions, the worst case surface temperature for the OP-100 package would be 137 °P, as documented in Appendix 3.6.

Given the negligible decay heat, the maximum temperature for all surfaces of the OP-100 package in shade with an ambient temperature of I 00 °P (560 °R) is I 00 °P (560 °R). This temperature is below the maximum acceptable surface temperature of 122 °P for non-exclusive use shipments as stipulated in 10 CPR §71.43(g). Similarly, the package temperature will be equal to ambient under the low temperature conditions of-20 op (-29 °C) and -40 op (-40 °C).

3.3.2 Maximum Normal Operating Pressure

This section does not apply, since the OP-I 00 package does not contain any pressure boundaries. Therefore, there is no maximum normal operating pressure (MNOP) for the OP-100 package.

The containment of the OP-100 package is provided by the special form payload. Gas can freely move from the internal cavity to the environment during all phases of operation. Therefore, determination of internal pressures is not required.

3.3.3 Maximum Thermal Stresses

Due to the small size of the package and the negligible decay heat load, the thermal stresses within the package are negligible.

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3.3.4 Evaluation of Package Performance for Normal Conditions of Transport

As discussed in the previous sections, all of the temperatures that may be experienced by the OP-100 package during normal conditions of transport are within acceptable limits.

3.4 Thermal Evaluation under Hypothetical Accident Conditions

The performance of the OP-100 package under hypothetical accident conditions (HAC) was determined via testing in accordance with 10 CFR §71.73(c)(4). Additional details are provided in the following sections.

3.4.1 Initial Conditions

A previously free and puncture dropped OP-100 certification test unit (CTU) package was placed into an oven and exposed to a forced convective environment that resulted in the average surface temperature of the package to at least 1,475 °F (800 °C).

3.4.2 Fire Test Conditions

Following the introduction of air and indication of the package surface at a minimum of 1,475 °F (800 °C), the package was maintained in the oven for 30 minutes. During the 30-minute test, the surface temperature varied between 1,470 °F (799 °C) and 1,627 °F (886 °C). During heat-up, burning of the combustible materials was observed. Following the 30-minute test, the package was removed from the oven and allowed to cool in air.

A post-test examination of the package indicated that the both the plywood support structure and the polyurethane foam were completely consumed by the fire, adding its combustion energy to that of the forced convection from the oven. The depleted uranium shielding, and the outer skin of the package were not compromised or appreciably oxidized. Additionally, the peak temperatures recorded in the test were well below the melting temperatures of both stainless steel (2,800 °F [1,538 °C]) and uranium (2,071 °F [1,133 °C]).

A post-test radiation survey conducted subsequent to the fire test indicated little, if any, degradation in shielding capability.

The special form qualification of the payload certifies that it could withstand the fire test without degradation.

3.4.3 Maximum Temperatures and Pressures

Based the thermal tests performed on the OP-100 package, none of the components exceeds its temperature limit as described in Section 3.2.1, Material Properties. Specifically, the maximum recorded package temperatures fall more than 500 °F (200 °C) below the melting point of steel and uranium. Additionally, the special form payload does not exceed the temperatures for the special form certification tests.

The containment of the OP-100 package is provided by the special form payload. Gas can freely move from the internal cavity to the environment during all phases of operation, so determination of internal pressures is not required.

This verifies that the OP-100 package satisfies the HAC thermal requirements set forth by 10 CFR §71.73(c)(4).

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3.4.4 Maximum Thermal Stresses

Docket No. 71-9185 Revision 6, 10/2018

The effects ofHAC thermal stresses were addressed by the fire test. No damage due to thermal stresses was found during post-test examination of the OP-100 CTU and its payload.

3.4.5 Accident Conditions for Fissile Material Packages for Air Transport

This section does not apply, since the OP-100 package does not contain fissile material.

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3.5 Appendix

Docket No. 71-9185 Revision 6, 10/2018

3.5.1 Determination of Maximum Surface Temperature for OP-100 Package

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Prepared Paul F. Stevens fl~ Date 0 /?8/99- Revision _Q_

Reviewed Phil W. Noss /J;,{Ju I ,, ""~ ti ~1 Date '-1 1 Page _1_ of_]_

Approved Gary L. Clark Pxau..i Date 6~ Project 98005

Title Surface Temperature Calculation for INC OP-100 Package

TABLE OF CONTENTS

1.0 OBJECTIVE ........................................................................................................ 2

2.0 REFERENCES ........................................................................................ ........ .... 2

3.0 CALCULATION ASSUMPTIONS ............................... ......................................... 2

4.0 MATERIAL PROPERTIES .................................................................................. 3

5.0 THERMAL LOADS ............................ .......................................... ........................ 3

6.0 ANALYTICAL CALCULATIONS .......................................................................... 4

7.0 SUMMARY OF RESULTS .. ...... ......... ............................................................ ..... ?

REVISION LOG

Packaging Technology, Inc., 4507-D Pacific Hwy East, Tacoma WA 98424-2633, fl(253)922-1450 ~(253)922-1445

Page 95: SAFETY ANALYSIS REPORT OP-100 PACKAGE

PacTec Calculation Sheet

Prepared Ps;iul F, Stev~n~ ~tl Date ~l~ ln Revision_Q__

Reviewed PhilW. Noss /Ott/JIJ Date ~lis/7z ' I

Page _ 2_ of _7 _

Approved Ga[J'. L. Qlark ~~ Date t.bet#f. Project 980QQ

Title Surface Temperature Calculation for INC OP-10Q Package

1.0 OBJECTIVE

The purpose of this calculation is to determine the peak surface temperatures on the Industrial Nuclear Company OP-100 Package due to solar radiation per the regulations of 10 CFR 71.71(c)(l).

2.0 REFERENCES

1) Code of Federal Regulations, Title 10, Part 71, Packaging and Transportation of Radioactive Materials, 1/1198.

2) Engineering Heat Transfer, James R. Welty, John Wiley and Sons Publishing, New York, 1974.

3) Industrial Nuclear Company, OP-100 Package, Drawing OP-100-1.

4) Handbook of Heat Transfer, Warren M. Rohsenow and James P. Hartnett, McGraw Hill Book Company, New York, 1973.

5) Principles of Heat Transfer, Frank Kreith, Harper and Row Publishers, New York, 1973.

3.0 CALCULATION ASSUMPTIONS

• Conductance along the carbon steel outer skin of the package is conservatively assumed to be negligible.

• Solar radiation is assumed to be at a constant value that is I/12th of the maximum solar radiation value as prescribed by 10 CFR 71.71(c)(l) (Reference 1).

• Ambient temperature is assumed to be at a constant temperature of 100°F (560 °R) per Reference 1.

• All surfaces, excepting the base, of the OP-100, experience turbulent natural convection.

• Decay heat from OP-100 payload is assumed to be negligible.

Packaging Technology, Inc., 4507-D Pacific Highway East, Tacoma WA 98424-2633, "il(253)922-1450 fj (253)922-1445

Page 96: SAFETY ANALYSIS REPORT OP-100 PACKAGE

PacTec Calculation Sheet

Prepared __ .._P=a=ul'""'"F_... -=S=te~v'"""'e""'n..,_s _____ f_,_f~-'"-'------.:Date C. I?¥ /99 Revision_O_

Reviewed --~P~h~il _,_W~. _,_N~o~s~s ___ Pi_U_!lJ _______ .Oate v/J.s/11 Page ~of _7_

Approved __ G=a=ry.J--.=L.,_,C~la""'"r_,_,_k~~""-~--"-t'4J~'--=-------'oate bh8k9 Project 98005

Title Surface Temperature Calculation for INC OP-100 Package

4.0 MATERIAL PROPERTIES

Since conduction is conservatively neglected for the purposes of this calculation, the only pertinent material properties are the emissivity and solar absorptivity of the paint on the exterior surface of the package.

Per Reference 3, the package may be painted yellow, or the lid and bottom of the package may be painted white, and its walls black. From Reference 4, page 3-22, the emissivity for white, silicone based paint, Ewhite' is 0.75, while its solar absorptivity, awhite' is 0.26. From the same source, the emissivity of black enamel paint, Eblack' is 0.84, and its absorptivity, ablack• is 0.93. From Reference 5, page 237, the radiation properties of yellow paint are commensurate with those of white paint. Therefore, a drum with the white/black paint scheme will be the controlling case, as it will absorb more solar radiation and have higher temperatures than an all yellow drum.

Conductivity and kinematic viscosity of air affect convective heat transfer from the OP-100. These material properties are addressed by using simplified heat transfer equations for air as documented in Section 6.0.

5.0 THERMAL LOADS

Since the decay heat source term of the OP-100 is negligible, the only pertinent thermal load is solar radiation (insolation). Per 10 CFR 71.71(c)(l) (Reference 1), the maximum insolation is as follows:

Surface Orientation Total Insolation for 12 Average Heat Flux Hour Period (gcal/cm2

) (Btu/hr-ft2)

Flat, horizontal (not base) 800 245 .7

Flat, horizontal (base) 0 0.0

Flat, non-horizontal 200 61.4

Curved 400 122.9

Packaging Technology, Inc., 4507-D Pacific Highway East, Tacoma WA 98424-2633, 'il(253)922-1450 ~(253)922-1445

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PacTec Calculation Sheet

__ ........,._,,,_,_,-'-"....,,,_,_,._._,""--___ ......._,~-------'Date (,,ht 199 Revision_JJ_

__ _,_,_,_,_,_,_.._,__,_==-----'---------Date 6/2-~f7 t Page 4 of 7 I I -- --

-~"'-"'-'-'--=-~~-'------------'Date //2&h Project 98005

Title Surface Temperature Calculation for INC OP-100 Package

6.0 ANALYTICAL CALCULATIONS

The simplified dimensions of the OP-100 used in the analytical calculations are shown in the figure below and are derived from Reference 3.

B lo.ck po.int

17 .S"

[::.~.-::=_------------------ :::::::::::::=-] -----------··---

- --.:::::.:::.::::::...-:::::.--:7"-------::=::--::..·::::::::::::-·

~1---14" UD--~

Determining the surface temperature of the OP-100 in the shade with an ambient temperature of 100 °F (560 °R) in accordance with 10 CFR 71.43(g) (Reference 1), which stipulates a maximum accessible surface temperature of 122 °F for non-exclusive use shipments, is a trivial exercise. Without a significant decay heat load, the OP-100 will have a surface temperature of 100 °F (560 °F), and thereby meets the requirements of 10 CFR 71.43(g).

Packaging Technology, Inc. , 4507-D Pacific Highway East, Tacoma WA 98424-2633, fl(253)922-1450 ~(253)922-1445

Page 98: SAFETY ANALYSIS REPORT OP-100 PACKAGE

PacTec Calculation Sheet

--~~~~~~---+-.,_.._, _______ ~Date (,{'l3 (j? Revision_JJ_

__ _,_,_~~-===-------'---'--'-'-=--------Date ZS 'I q Page _L of _7_

--~=+-~=~-~~~--~-----~Date J512t/?t: Project 98005

Title Surface Temperature Calculation for INC OP-100 Package

The temperature for the curved, horizontal and vertical surfaces with maximum insolation can be found by solving the following heat balance equation for each of the three geometries:

Q solar = Q radition + Q co11vectio11

where

Qsolar = Insolation value for the particular geometry · asurface · Area

Qradiation =CJ' €surface' Area· (T' surface - T4 ambient), CJ= 0.1714 X 10-8 Btu/hr-ft2-0 R4

Qconvection = h · Area(Tsurrace - T ambient), h =free convection heat transfer coefficient

From Reference 2, pp. 252-3, the general form ofh at one atmosphere and moderate temperatures is:

h=fw-~T-,..., )' Where a, b and L vary based on surface geometry, orientation and whether the free convection is turbulent or laminar. Since turbulent free convection is less efficient, it is conservatively assumed for this analysis that all surfaces on the OP-I 00 will experience turbulent natural convection. The values for a, b and L for each orientation is presented below:

Simplified Turbulent Free Convection Equation Coefficients

Flat Vertical Flat Horizontal Curved

A 0.19 0.22 0.18

B 113 1/3 1/3

L 1.0 1.0 1.0

h= 0.19~T113 0.22~T113 0.18~T113

Packaging Technology, Inc., 4507-D Pacific Highway East, Tacoma WA 98424-2633, 'il(253)922-1450 ~(253)922-1445

Page 99: SAFETY ANALYSIS REPORT OP-100 PACKAGE

PacTec Calculation Sheet

Title Surface Temperature Calculation for INC OP-100 Package

For a unit area, the energy balance equations for each of the orientation is:

Flat Horizontal (non base)

· Btu Q l, =245.7 ·0.26=63.9-

soa hr

Qradialion =0.1714xl0-8 • 0.75 · (T,,!lface -5604 )=1.29x10-9 ·(T~lface -5604

)

Qco11veclion =0.22. (T,,mface -560)113 ·(T,..,,rface -560)=0.22 • (Trulface -560)413

T surface = 596.9 °R or 136.9 °F

Vertical

· Btu Q.mlar =61.4 · 0.93=57.1 hr

Qradiaiion =0.1714xl0-8 ·0.84·(r,!rfacc -5604 )=1.44xl0-9 ·(T~!rftice -5604)

Qconveclio11 =0.19. cr,111face -560)113 ·(T,...,rface -560) =0.19. (T,...,rfat-e -560)413

Tsurface = 593.3 °R or 133.3 °F

Curved

A 11 curved surfaces of the OP-100 are vertically oriented, and are addressed in the above vertical surface section.

Packaging Technology, Inc., 4507-D Pacific Highway East, Tacoma WA 98424-2633, 'fl(253)922-1450 ~(253)922-1445

Page 100: SAFETY ANALYSIS REPORT OP-100 PACKAGE

PacTec Calculation Sheet

---'--"'""'-'--'-~=:.=.:...:=-------1-~----~Date <e fzi f ?J Revision_O_

/,/; 9 ht'~ --~~~~~-~---------·Date ~age _J__of _7_

--=--=~~-~~~~-~--~Date da:J..& Project 98005

Title Surface Temperature Calculation for INC OP-100 Package

7.0 SUMMARY OF RESULTS

The maximum temperature for all surfaces of the OP-100 in shade and an ambient temperature of 100 °F (560 °R) is 100 °P (560 °R), which satisfies the requirements of 10 CPR 71.43(g). Under peak insolation, the maximum predicted surface temperature of the sides of the OP-100 would be 133.3 °F (593.3 °R), and the maximum predicted temperature of the top of the OP-100 is 136.9 op (596.9 °R).

Packaging Technology, Inc., 4507-D Pacific Highway East, Tacoma WA 98424-2633, fl(253)922-1450 ~(253)922-1445

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INC OP-100 Package Safety Analysis Report

4.0 CONTAINMENT

Docket No. 71-9185 Revision 6, 10/2018

The OP-100 package is designed as a means of confinement for a special form Ir-192 or Se-75 source capsule. Containment of radioactive material is provided by the special form construction of the payload. The source capsules and their respective special form certification are as follows:

Manufacture Model Number Certification Number

A1 USA/0297 /S-96 Industrial Nuclear Co., Inc.

791 1 USA/0393/S-96

Source Production & VSe Source Capsule2 USA/0785/S-96

Equipment Co., Inc.

Notes: 1. Source capsule is limited to a maximum of 144 Ci (5.3 TBq) oflr-192 material 2. Source capsule is limited to a maximum of 144 Ci (5.3 TBq) oflr-192 or Se-75 material.

Since the OP-100 packaging does not provide containment, subsequent sections of this chapter are not applicable.

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5.0 SHIELDING EVALUATION

Docket No. 71-9185 Revision 6, 10/2018

This section demonstrates the shielding capability of the OP-100 package design for the authorized special form contents. The shielding evaluation is demonstrated via prototypic testing in lieu of an analytical evaluation.

5.1 Description of Shielding Design

5.1.1 Design Features

The OP-100 package overpacks the IR-100 or the IR-50 packages. Both the IR-100 and IR-50 packages are a welded structure that contains a depleted uranium (DU) gamma shield, which surrounds a titanium S-tube. A stainless steel special form capsule, which contains either 144 Ci (5 .3 TBq) oflr-192 or Se-75 isotope, is inserted into the S-tube via a pigtail assembly. The radioactive source is positioned at the center of the DU gamma shield to provide the maximum attenuation of the gamma radiation.

5.1.2 Summary Table of Maximum Radiation Levels

Table 5-1 provides the maximum measured external radiation levels for either an IR-100 or IR-50 payload with the maximum payload content (144 Ci (5.3 TBq) Ir-192) for a non-exclusive use shipment. Note that the values were measured for packages removed from the OP-100 package, and did not include any gamma attenuation from the steel 10-gal drum.

Table 5-1 - Maximum Measured External Radiation Levels (Non-Exclusive Use)

Normal Conditions of Transport Hypothetical Accident Conditions

Package Measured1

10 CFR §71.47(a) 10 CFR §71.51(a)(2) Measurement Limit Measured Limit

Location mrem/hr (mSv/hr) mrem/hr (mSv/hr) mrem/hr (mSv/hr) mrem/hr (mSv/hr)

Surface 200 (2) 200 (2) NIA NIA

1 Meter from 1.9 (0.019) 10 (0.1) 2.3 (0.023) 1000 (10) Surface

Note: 1. Normal condition measured values were the highest value from either the pre-test or post-test surveys for a test unit that was subjected to the hypothetical accident conditions tests per 10 CFR §71.73.

5.2 Source Specification

5.2.1 Gamma Source

The radioactive content of the OP-100 package is limited to 144 Ci (5.3 TBq) oflr-192 or Se-75 isotopes. As shown in Table 5-2, Ir-192 results in a higher unit dose than Se-75 per curie of activity. In addition, the photon energies oflr-192 are higher than for Se-75 (0.280 MeV average). Therefore, the Ir-192 payload will bound the Se-75 payload for the 144 Ci (5 .3 TBq) maximum content. Since actual Ir-192 special form capsules are utilized to determine the acceptance of the DU gamma shield, the tabulation of gamma decay source strengths for the special form capsules is not required for the OP-100 package.

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5.2.2 Neutron Source

Docket No. 71-9185 Revision 6, 10/2018

This section does not apply, since the OP-100 package does not contain fissile material.

Table 5-2 - Specific Gamma Ray Constants for Iridium and Selenium Isotopes12

Specific Gamma Ray Constant Radionuclide (R-m2/hr-Ci)

Iridium-192 0.460

Selenium-75 0.203

5.3 Shielding Model

The shielding capability of the OP-100 package design is demonstrated by physical tests of prototypic packages. Therefore, no analytical shielding model of the package is performed.

5.4 Shielding Evaluation

5.4.1 Methods

The method utilized to demonstrate the shielding performance of the OP-100 package is via prototypic testing utilizing an IR-100 or IR-50 payload with a special form capsule containing radioactive Ir-192 material.

5.4.2 Input and Output Data

This section does not apply, since the shielding performance of the OP-100 package is not performed analytically.

5.4.3 Flux-to-Dose-Rate Conversions

This section does not apply, since the shielding performance of the OP-100 package is not performed analytically.

5.4.4 External Radiation Levels

Following the specified tests of a prototypic package with a 144 Ci (5.3 TBq) oflr-192 payload per 2.6, Normal Conditions of Transport, and 2.7, Hypothetical Accident Conditions, the maximum radiation level measured on the surface and at I-meter of the IR-100 or IR-50 package is 200 mrem/hr (2.00 mSv/hr) and 2.2 mrem/hr (0.022 mSv/hr), respectively. As noted in Table 5-1, these levels do not exceed the regulatory limits of 10 CFR §71.47(a) and 10 CFR §71.51(a)(2).

12 "Exposure Rate Constants and Lead Shielding Values for Over 1, 100 Radionuclides", David S. Smith and Michael G. Stabin, Department of Radiology and Radiological Sciences, Vanderbilt University, Nashville, TN, Health Physics Society Journal, March 2012 issue.

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6.0 CRITICALITY EVALUATION

Docket No. 71-9185 Revision 6, 10/2018

The OP-100 package does not transport fissile material; therefore, this section does not apply.

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7.0 PACKAGE OPERATIONS

7.1 Package Loading

Docket No. 71-9185 Revision 6, 10/2018

This section delineates the procedures for loading a payload into the OP-100 packaging. Hereafter, reference to specific OP-100 packaging components may be found in Appendix 1.3.1, General Arrangement Drawings, OP-100 Package.

7 .1.1 Preparation of the OP-100 Package for Loading

1) Visually inspect the OP-100 package for damage and/or missing parts.

2) Visually inspect the payload (i.e., IR-100 or IR-50) to be loaded into the OP-100 package.

3) Loosen and remove the closure ring bolt from the closure ring.

4) Remove the closure ring and the drum lid from the drum body.

5) Preparing the payload cavity:

a) Plywood Dunnage: Remove the two unsecured plywood cross members that allow an IR-100 or an IR-50 payload to be positioned within the plywood support structure.

b) Polyurethane Foam Dunnage: Remove the upper cap that allows access to the cavity for an IR-100 or an IR-5 0 payload to be positioned in the polyurethane foam support structure.

6) Remove the Safety Plug and the dust cover (IR-100) or the dust caps (IR-50). Check the threads for wear or damage.

7) Inspect the lock box for damage or missing set screws. Replace any damaged or missing set screws.

8) Prior to loading an active Ir-192 or Se-75 source into an IR-100 or IR-50, insert a dummy source pigtail and functionally test the automatic locking device to ensure that all components are operating properly. The locking devices on the IR-100 and IR-50 packages shall be checked prior to each use.

9) Pull (retract) the dummy pigtail. The Safety Latch Plate will pop-up and lock the dummy source in the stored position. Rotate the key to the locked position and remove the key.

10) Insert the key into the lock, retract (pull) the dummy source pigtail and rotate the key to the unlocked position. Manually depress the Safety Latch Plate to the operate position and remove the dummy source pigtail.

7.1.2 Loading the Special Form Payload into the IR-100/IR-50

1) Place the special form Ir-192 or Se-75 source pigtail assembly into a source changer.

2) Connect the drive cable housing and the guide tube to the IR-100 Exposure Camera.

3) Crank the drive cable out through the guide tube and connect it to the Ir-192 or Se-75 source pigtail assembly. Connect the guide tube to the IR-50 Source Changer.

4) Unlock the IR-50 Source Changer and retract the Ir-192 or Se-75 source pigtail assembly into the IR-100 Exposure Camera.

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5) Survey the package to ensure that the source is in the stored position. Rotate key to locked position and remove the key.

6) Disconnect drive cable and install the Safety Plug and dust cap (IR-100) or the dust caps (IR-50).

7) Install the Ir-192 or Se-75 source identification plate on the top of the IR-100 Exposure Camera.

8) When transported in an IR-50 Source Changer, attach the Ir-192 or Se-75 source identification plate to the tamper seal wire of the IR-50 for transfer with the Ir-192 or Se-75 source to an IR-100 Exposure Camera.

7 .1.3 Preparation for Transport

1) Install the two tamper-indicating seals (security wire/lead seals). For the IR-100 Exposure Camera, one tamper-indicating seal is located at the lock assembly; and the second is located at the Safety Plug. For the IR-50 Source Changer, the safety seals are located on each lock box and has a lock key attached.

2) Loading the payload cavity:

a) Plywood Dunnage: Load the IR-100 or IR-50 payload into the plywood support structure. Replace the two unsecured plywood cross members in their proper positions.

b) Polyurethane Foam Dunnage: Load the IR-100 or IR-50 payload into the lower polyurethane foam support structure. Replace the upper polyurethane foam cap.

3) Replace drum lid.

4) Replace the closure ring and then the 5/8-inch x 4 inch closure ring hex bolt. As the hex bolt is tightened, ensure that the closure ring is fully seated around the circumference of the drum. Tighten the closure ring bolt to a snug tight condition.

5) Install the hex nut and tighten to a snug tight condition.

6) Install a tamper-indicating seal (security wire/lead seal) through the hex bolt.

7) Monitor external radiation per the guidelines of 49 CFR § 173.441 13•

8) Determine the shielding transport index for the loaded package per the guidelines of 49 CFR §173.403.

9) Load the OP-100 package onto the transport vehicle.

10) Complete all necessary shipping papers in accordance with Subpart C of 49 CFR 17214.

11) OP-100 package marking shall be in accordance with 10 CFR §71.85(c) and Subpart D of 49 CFR 172. Package labeling shall be in accordance with Subpart E of 49 CFR 172. Packaging placarding shall be in accordance with Subpart F of 49 CFR 172.

13 Title 49, Code of Federal Regulations, Part 173 (49 CFR 173), Shippers-General Requirements for Shipments and Packagings, 10-1-17 Edition. 14 Title 49, Code of Federal Regulations, Part 172 (49 CFR 172), Hazardous Materials Tables and Hazardous Communications Regulations, 10-1-17 Edition.

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7.2 Package Unloading

Docket No. 71-9185 Revision 6, 10/2018

This section delineates the procedures for unloading a payload into the OP-100 packaging. Hereafter, reference to specific OP-100 package components may be found in Appendix 1.3 .1, General Arrangement Drawings, OP-100 Package.

7.2.1 Receipt of Package from Carrier

1) Remove the OP-100 package from the transport vehicle.

2) Monitor the external radiation to ensure that the OP-100 package was not damaged during shipment. If Radiation readings or surface radioactive contamination levels exceed allowable limits contact the Radiation Safety Officer for instructions.

7.2.2 Removal of Contents from the OP-100 Package

1) Remove the tamper indicating wire seal. If tamper indicating seal is missing or broken, call Radiation Safety Officer for instructions. The RSO will investigate the incident before proceeding.

2) Remove the hex nut, closure ring hex bolt, the closure ring, and lid.

3) Unloading the payload cavity:

a) Plywood Dunnage: Remove the two unsecured plywood cross members and remove the payload (i.e., IR-100 or IR-50).

b) Polyurethane Foam Dunnage: Remove the upper polyurethane cap and remove the payload (i.e., IR-100 or IR-50 device).

4) Remove the Safety Plug and the dust cap (IR-100) or the dust caps (IR-50).

5) Connect the drive cable housing and the guide tube to the package. Connect the guide tube to a source changer.

6) Unlock the IR-100 and IR-50 devices, and extend the Ir-192 or Se-75 source pigtail assembly into the IR-50 Source Changer.

7) Secure the Ir-192 or Se-75 source pigtail assembly in the IR-50 Source Changer, lock, and remove the key.

8) Disconnect the drive cable from the IR-50 Source Changer and retract it.

9) Disconnect the guide tube from the IR-50 and the IR-100 Exposure Camera. Install the dust caps on the IR-50 Source Changer, and the Safety Plug and dust cap on the IR-100 Exposure Camera. Remove the source identification from the IR-100 Exposure Camera, and install it on the IR-50 Source Changer.

7.2.3 Final Package Preparations for Transport of Unloaded OP-100 Package

1) Complete all required shipping papers in accordance with Subpart C of 49 CFR 172.

2) OP-100 package marking shall be in accordance with 10 CFR §71.85(c) and Subpart D of 49 CFR 172. Package labeling shall be in accordance with Subpart E of 49 CFR 172. Packaging placarding shall be in accordance with Subpart F of 49 CFR 172.

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7 .3 Preparation of an Empty Package for Transport

Previously used and empty 0 P-100 packages shall be prepared and transported per the requirements of 49 CFR § 173 .426, Subpart I.

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8.0 ACCEPTANCE TESTS AND MAINTENANCE PROGRAM

8.1 Acceptance Tests

Per the requirements of 10 CFR §71.85(c)15, this section discusses the inspections and tests to be

performed prior to first use of the OP-100 package.

8.1.1 Visual Inspections and Measurements

All OP-100 package materials of construction and welds shall be examined in accordance with the requirements delineated on the drawings in Appendix 1.3 .1, General Arrangement Drawings, per the requirements of 10 CFR §71.85(a).

8.1.2 Weld Examinations

All welds on the IR-100 and IR-50 packages shall be examined in accordance with the requirements delineated on the drawings in Appendix 1.3 .1, General Arrangement Drawings, per the requirements of 10 CFR §71.85(a).

8.1.3 Structural and Pressure Tests

The OP-100 package does not contain any lifting/tie-down devices or pressure boundaries that require load testing.

8.1.4 Leakage Tests

The OP-100 package does not contain any seals or containment boundaries that require testing.

8.1.5 Component and Material Tests

The OP-100 package does not contain any additional components or materials that require acceptance testing.

8.1.6 Shielding Tests

A radiation profile is performed on each DU gamma shield prior to being used in the fabrication of an IR-100 or IR-50 packages. These measured survey results are ratioed upward to determine the expected radiation levels for the maximum authorized source strength of 144 Ci (5.3 TBq). Any radiation profile of a DU gamma shield that results in a dose rate that exceeds the requirements of 49 CFR §173.441 16 with the maximum authorized payload shall not be utilized in the manufacture of an IR-100 or IR-50 package.

15 Title 10, Code of Federal Regulations, Part 71 ( 10 CFR 71 ), Packaging and Transportation of Radioactive Material, 1-1-18 Edition. 16 Title 49, Code of Federal Regulations, Part 173 (49 CFR 173), Shippers-General Requirements for Shipments and Packagings, 10-1-17 Edition.

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8.1.7 Thermal Tests

Docket No. 71-9185 Revision 6, 10/2018

The OP-100 package does not contain any thermal features or systems that require testing. Therefore, this section does not apply.

8.1.8 Miscellaneous Tests

There are no additional acceptance tests required for the OP-100 packaging.

8.2 Maintenance Program

This section describes the maintenance program used to ensure continued performance of the OP-100 package.

8.2.1 Structural and Pressure Tests

The OP-100 package does not contain any lifting/tie-down devices or pressure boundaries that require load testing.

8.2.2 Leakage Tests

The OP-100 package does not contain any seals or containment boundaries that require testing.

8.2.3 Component and Material Tests

8.2.3.1 Fasteners

All threaded components shall be inspected quarterly for deformed or stripped threads. Damaged components shall be repaired or replaced prior to further use.

8.2.3.2 Lock Assembly

Prior to each use, inspect the lock assembly for restrained motion. Any motion or operational impairing shall be corrected prior to further use.

8.2.3.3 Payload Support Structure

Prior to each use, inspect the plywood or the polyurethane foam support structures for damage. Damaged components shall be replaced prior to further use.

8.2.4 Thermal Tests

No thermal tests are necessary to ensure continued performance of the OP-100 packaging.

8.2.5 Miscellaneous Tests - Shielding

Prior to each shipment, a radiation survey is performed to ensure that the radiation dose levels do not exceed the requirements of 49 CFR § 173 .441. This survey confirms that the DU gamma shield has maintained its shielding function.

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