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In accordance with the IAEA transport regulations, the design of special form radioactive material (SFRM) shall resist a severe transport accident without undue loss or dispersal of radioactive material. The safety assessment for design approval includes besides the program for physical tests (impact, percussion, bending and heat test) also the evaluation of the management system for design, manufacture, testing, documentation, use, maintenance, and inspection.
SFRM source design plus management system shall ensure, that every specimen of the approved design is able to survive the severe mechanical and thermal tests at any time of its SFRM-working life.
Due to the long-term use of SFRM designs in most cases, the assessment of the source ageing behavior is an important aspect in the approval procedure. Different fields of application imply a wide range of environmental conditions, from clean room atmosphere to highly aggressive industrial conditions. Besides of radioactive content, corrosion is a main factor for possible SFRM design degradation.
Although the IAEA Advisory Material SSG-26 already implies an indication of the need for considering ageing mechanisms, suitable amendments in the regulatory requirements of SSR-6 should be introduced to make the approval procedure more transparent and help to reduce rounds of questions by the authority. A supplementary requirement for considering of ageing mechanisms could be a helpful contribution to an international harmonization of the approval procedure.
This paper will describe major influencing factors to be considered to assess the ageing behavior of a SFRM design and will identify the need for a regulatory specification of a SFRM-working life as basis for the assessment of the SFRM design regarding time-dependent weakening. A proposal for an explicit requirement for consideration of ageing mechanisms in safety assessment of SFRM, which should be considered in the ongoing SSR-6 revision cycle, will be explained.
Most transports of radioactive materials are carried out with packages not requiring competent authority approval of design. These encompass – in accordance with the IAEA SSR-6 regulations – packages of the classification excepted, Industrial packages Type 1, 2 and 3 and Type A packages. Currently an upsurge in number and variation of these package designs can be seen in Germany, resulting from the phase out of nuclear energy in Germany as well as e. g. increased use of radioactive material for medical purposes.
A design assessment regarding the package safety is required in the international IAEA SSR-6 regulations. BAM operates facilities for the performance of all regulatory tests required such as drop towers for a wide range of package masses and dimensions, fire test, leak tightness measurements and pressure test facilities. Experiences with several package types are shown.
Additionally, IAEA SSR-6 requires the establishment of a management system for design, manufacture, maintenance, and repair of the packaging as well as for the preparation, consigning, loading, carriage, unloading and receipt of the package. Relevant for Germany, BAM has published guidance material on the process of management system acceptance in the technical guide BAM-GGR 016. The requirements encompass quality management plans for the manufacturing of packages including independent manufacturing surveillance and specific instructions for operation, maintenance, and repair of packagings. Examples for management system specifics and requirements are given.
Since the latest edition of the IAEA SSR-6 regulations an ageing evaluation including systematic ageing management measures are required for all kind of package types. BAM is going to update the guidance material BAM-GGR 016 to support the stakeholders with relevant information to fulfil the ageing aspect for packages not requiring competent authority approval. The paper explains how the ageing aspect may be included in the safety evaluation process and the management system measures and will give an outlook for the future guidance material.
In accordance with IAEA SSR-6 para 306 a management system shall be established and implemented to ensure compliance with the relevant provisions of the IAEA regulations. BAM has issued an update of the guideline: the BAM-GGR 011. The new revision describes necessary quality assurance measures for design, manufacture, testing, documentation, use, maintenance and inspection of packagings for package designs requiring competent authority approval for the transport of radioactive material.
The measures can be categorised as system-related and design-related. They are independently approved and monitored by the German competent authority BAM and its authorised expert (BAM/T). The qualification of the organisation applying for the design approval certificate is reviewed in the context of the design approval procedure. The quality assurance measures for manufacture consist of three main steps. Pre-assessment of manufacturing documents such as quality plans, specifications etc., Manufacturing inspections according the pre-assessed documents and inspection before commissioning including documentation review. Periodic inspections during operation as well as relevant specifications for use and maintenance ensure that the properties specified in the approval certificate are preserved over the package life time. Special provisions for the return on
experience regarding operational feedback for design, manufacture, use, maintenance and inspection are given. Special focus shall be given here to the rearranged and meanwhile established system of manufacturing inspections. This includes more transparent roles for a) the Producers authorised inspection 11282 representative, b) the independent inspection expert (S), acting on behalf of the manufacturer with acceptance of BAM, and c) BAM or its authorised expert (BAM/T). Additional attention shall be drawn to the management of deviations during manufacturing and provisions for maintenance and periodic inspections.
Specific attention should be paid on safety demonstrations transmitted by applicants in the case of approval request for the package designs containing enriched UF6. Concerning the shipment of enriched UF6, the package designs consist in general of a filled 30B cylinder surrounded by an overpack.
The description of the content, considering the UF6 origin, i.e. natural or reprocessed, shall be clearly justified especially when the UF6 isotopic composition exceeds the limits specified in ASTM standards.
Concerning the containment of the UF6, the applicant shall demonstrate in all conditions of Transport the leak-tightness of the valve and plug of the cylinders filled with enriched UF6. In this regard, when justifications are based on numerical calculations, the absence of contact between These components of the cylinder and the internal surfaces of the overpack after the regulatory drop tests shall be shown. In particular, absence of contact between the valve and any other component of the packaging shall be confirmed to respect the current IAEA regulations [3]. If complementary calculations show a contact between the plug and the internal surfaces of the overpack, additional tests are required to confirm that the strength resulting from this contact will not affect the plug leak-tightness. It can be noticed that the future revision of the IAEA regulations will include additional provision in case of contact of the plug with any other component of the packaging. In addition, the applicant shall demonstrate that the melting temperature of the valve, including the tinned joint, will not be exceeded during the regulatory fire test.
Furthermore, the representativeness of the ballast used to simulate the behaviour of the UF6 loaded within the cylinder shall be justified if drop tests are performed.
Finally, specific provisions relative to the use of plugs and the maintenance of cylinders should be included in the safety analysis reports.
Assessment of quality management for transport packages not requiring authority design approval
(2018)
The majority of transports of radioactive materials are carried out in packages which don’t need a package design approval of a competent authority. Low active radioactive materials are transported in such kind of packages e.g. in the medical and pharmaceutical industry and in the nuclear industry as well.
In Germany the decision to phase out nuclear energy leads to a strong demand for packages to transport low and middle active radioactive waste due to the dismantling and decommissioning of nuclear power plants. According to IAEA regulations the “non-competent authority approved package types” are the excepted packages and the industrial packages of Type IP-1, IP-2 and IP-3 and of Type A.
For the packages of Type IP-2, IP-3 and Type A an assessment by the German competent authority is required for the quality management for the design, manufacture, testing, documentation, use, maintenance and inspection. In general a compliance audit of the manufacturer of the packaging is required during this assessment procedure.
Packages for intermediate level waste (ILW) often contain residual water besides the actual waste. The water either exists as obvious free water or it may be bound physically or chemically, e.g. as pore water. A water driven gas generation could occur by vaporisation and by radiolysis. Steam as the result of vaporisation causes an increasing pressure inside a package and can affect corrosion. Vaporisation and condensation processes itself change the thermal behavior of the content especially during strongly unsteady thermal situations like accident fire situations. Radiolysis changes the chemical composition of the content which could cause an unexpected interaction, e.g. hydrogen embrittlement. Besides the pressure build-up the radiolysis of water generates hydrogen and oxygen, which can be highly flammable respectively explosive. The gas generation caused by vaporisation and radiolysis must be taken into account during the design and the safety assessment of a package. Pressure build-up, a changed thermal behavior and content chemistry, and especially the risk of accumulation of combustible gases exceeding the limiting concentration for flammability has to be considered in the safety assessment. Approaches to ensure the transportability of stored packages due to radiolysis will be discussed.
BAM as competent authority regarding assessment of mechanical and thermal design, activity release and quality assurance aspects of SNF and HLW transport packages developed a thesaurus of experience feedback topics from recent approval procedures. The list is structured according to the European PDSR guide. It involves issues, which from BAM point of view, needed clarification during last package design assessment procedures. The list contains issues from operation (e.g. deactivation of handling lugs not intended for package handling), maintenance (e.g. leak tightness of impact limiting devices) to technical assessment (e.g. formation of hydrogen by radiolysis and its impact on pressure and ignitability, consideration of ageing mechanisms, thermo-mechanical assessment, impact of gaps between content and flask, spent fuel behaviour) as well as to general and specific safety analysis report requirements (e.g. report structure and required data).
Storage of spent nuclear fuel and high-level waste in dual purpose casks (DPC) is related with the challenge of maintaining safety for transportation over several decades of storage. Beside consideration of aging mechanisms by appropriate design, material selection and operational controls to assure technical reliability by aging management measures, an essential issue is the continuous control and update of the DPC safety case. Not only the technical objects are subject of aging but also the safety demonstration basis is subject of “aging” due to possible changes of regulations, standards and scientific/technical knowledge. The basic document, defining the transport safety conditions, is the package design safety report (PDSR) for the transport version of the DPC. To ensure a safe transport in future to a destination which is not known yet (because of not yet existing repository sites) periodical reviews of the PDSR, in connection with periodic renewals of package design approval certificates, have to be carried out. The main reviewing tool is a gap analysis. A gap analysis for a PDSR is the assessment of the state of technical knowledge, standards and regulations regarding safety functions of structures, systems and components.
BAM as competent authority regarding assessment of mechanical and thermal design, activity release and quality assurance measures of Type-B(U) transport packages developed a thesaurus of experience feedback topics from recent assessment procedures. The list is structured according to the European PDSR guide. It involves issues, which from BAM's point of view, needed clarification during the last package design assessment procedures. The list contains issues from Operation (e.g. deactivation of handling lugs not intended for package handling), maintenance (e.g. leak tightness of impact limiting devices) to technical assessment (e.g. formation of hydrogen by radiolysis and its impact on pressure and ignitability, consideration of ageing mechanisms, thermo-mechanical assessment, impact of gaps between content and flask) as well as to general and specific safety analysis report requirements (e.g. report structure and required data).
Type B(U) packages for the transport of radioactive material have to withstand accident conditions of transport defined in the regulations of the International Atomic Energy Agency in form of different mechanical (drop) tests with a subsequent thermal test. According to the regulatory requirements the orientation of the package in drop tests shall be such to cause the most damaged state in the components performing the safety functions.
For the package Iid system a 9 m drop onto the unyielding target with Iid side downwards is often the most damaging orientation. The impact Ioads acting on the Iid in this orientation result mainly from interaction between Iid and internal content. In case of a movable content its impact onto the inner side of the Iid can cause additional Ioad peaks on the Iid and the Iid bolts. The intensity of the internal collision depends on the position of content relating to Iid at the time of package first contact with target. Due to physical limitations an axial gap, which could be set in "pre-drop" configuration of package or which could spontaneously appear during the drop test, usually does not cover the maximum size possible in specific package design. In this context, the combination of drop tests with post-test analysis can be helpful to better estimate the effect of internal impact. The paper summarizes some aspects of this issue based on the BAM experience in the design assessment of Type B(U) transport packages. Additionally the paper shall support applicants in German approval procedures to reduce rounds of questions and ensure delivery of reliable safety case documents to the authorities.