Technical Review Report for the Mound 1KW Package Safety Analysis Report for Packaging Waiver for the Use of Modified Primary Containment Vessel (PCV)

Abstract

This Technical Review Report (TRR) documents the review, performed by the Lawrence Livermore National Laboratory (LLNL) staff, at the request of the U.S. Department of Energy (DOE), on the Waiver for the Use of Modified Primary Containment Vessels (PCV). The waiver is to be used to support a limited number of shipments of fuel for the Multi-Mission Radioisotope Thermoelectric Generator (MMRTG) Project in support of the National Aeronautics and Space Administration's (NASA's) Mars Science Laboratory (MSL) mission. Under the waiver, an inventory of existing national security PCVs will be converted to standard PCVs. Both types of PCVs are currently approved for use by the Office of Nuclear Energy. LLNL has previously reviewed the national security PCVs under Mound 1KW Package Safety Analysis Report for Packaging, Addendum No. 1, Revision c, dated June 2007 (Addendum 1). The safety analysis of the package is documented in the Safety Analysis Report for Packaging (SARP) for the Mound 1KW Package (i.e., the Mound 1KW SARP, or the SARP) where the standard PCVs have been reviewed by LLNL. The Mound 1KW Package is certified by DOE Certificate of Compliance (CoC) number USA/9516/B(U)F-85 for the transportation of Type B quantities of plutonium heat source material. The waiver requests an exemption, claiming safety equivalent to the requirements specified in 10 CFR 71.12, Specific Exemptions, and will lead to a letter amendment to the CoC. Under the waiver, the Office of Radioisotope Power Systems, NE-34, is seeking an exemption from 10 CFR 71.19(d)(1), Previously Approved Package,[5] which states: '(d) NRC will approve modifications to the design and authorized contents of a Type B package, or a fissile material package, previously approved by NRC, provided--(1) The modifications of a Type B package are not significant with respect to the design, operating characteristics, or safe performance of the containment system, when the package is subjected to the tests specified in {section}71.71 and 71.73.' The LLNL staff had previously reviewed a request from Idaho National Laboratory (INL) to reconfigure national security PCVs to standard PCVs. With a nominal 50% reduction in both the height and the volume, the LLNL staff initially deemed the modifications to be significant, which would not be allowed under the provisions of 10 CFR 71.19(d)(1)--see above. As a follow-up, the DOE requested additional clarification from the Nuclear Regulatory Commission (NRC). The NRC concluded that the reconfiguration would be a new fabrication, and that an exemption to the regulations would be required to allow its use, as per the requirements specified in 10 CFR 71.19(c)(1), Previously Approved Package: '(c) A Type B(U) package, a Type B(M) package, or a fissile material package previously approved by the NRC with the designation '-85' in the identification number of the NRC CoC, may be used under the general license of {section}71.17 with the following additional conditions: (1) Fabrication of the package must be satisfactorily completed by December 31, 2006, as demonstrated by application of its model number in accordance with 71.85(c).' Although the preferred approach toward the resolution of this issue would be for the applicant to submit an updated SARP, the applicant has stated that the process of updating the Model Mound 1KW Package SARP is a work that is in progress, but that the updated SARP is not yet ready for submittal. The applicant has to provide a submittal, proving that the package meets the '-96' requirements of International Atomic Energy Agency (IAEA) Safety Standards Series No. TS-R-1, in order to fabricate approved packagings after December 31, 2006. The applicant has further stated that all other packaging features, as described in the currently approved Model Mound 1KW Package SARP, remain unchanged. This report documents the LLNL review of the waiver request. The specific review for each SARP Chapter is documented.