Onsite Transportation At SRS

Robert W. WatkinsManager Packaging & Transportation Services

Contractors Transportation Management Association 2015

July 6 – 9, 2015

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Savannah River Site

310 sq. milesControlled accessHighways & rail2 public access roadsCSX rail line

Transportation Safety Document

• Defines the SRS onsite packaging and transportation safety program• “Onsite Transfer” via vehicle (including rail) within SRS boundary but external to

facility Documented Safety Analysis (DSA) boundaries– Stay with access controlled outer perimeter of SRS– Don’t cross or travel public access roads

• Covers non-radioactive and radioactive hazardous materials• Demonstrates compliance with:

– DOE Order 460.1C, Packaging and Transportation Safety– DOE Order 461.2, Onsite Packaging and Transfer of Materials of National Security

Interest– 10 CFR 830, Nuclear Safety Management (Subpart B)

• Approved by DOE-SR– Reviewed annually

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Onsite Transfer Methods

• Non-radioactive material:– DOT compliant package (contents & packaging)

• Radioactive material:– DOT compliant package (contents & packaging)– Package/transfer ≥ Hazard Category (HC)-3 as defined in DOE STD-1027

• Via Onsite Safety Assessment (OSA) or Non-Routine Transfer (NRT)– 7 OSAs currently in use– No current NRTs – previously used

– Package/transfer < HC-3• Via Onsite Transportation Report (OTR)

– 2 OTRs currently in use

• All Rad transfers controlled by SRS Radiological Control Manual 5Q which provides 49 CFR equivalent communications

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DOE O 460.1C establishes P&T Requirements

TSD Safety Assessment Methodology

DOE Order460.1C

DOT Compliant

EquivalentSafety

Requirements

49 CFR 171-18049 CFR 350-399

NRC10 CFR 71

Rad Material Quantities

≥ HC-3

Rad Material Quantities

< HC-3

10 CFR 830 Integrated Safety Management

TSD, OSA, NRT, TSQ

TSD, OTR

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Onsite Transportation is from DSA to DSA

Onsite Transportation

Originating FacilityDSA

Receiving

Facility DSA

• Movement – material movement within facility safety basis boundary• Onsite transfer — any material transfer that stays within the fenced in and guarded

boundaries of SRS … and travels outside the area covered by a facility safety basis.

• Transfer: onsite transport of hazardous materials external to the bounds of a facility safety basis … .

Onsite Transfer requires movement through the plane of the originating DSA boundary; at which point a vehicle accident would be under the OSA.

transferMovement Movement

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Regulations, Orders and Program Elements

DOE 460.1C & 461.2 Packaging and

Transportation Safety

10 CFR 830 Nuclear Safety

49 CFR Hazardous Materials

Transportation

SRS Transportation Safety

Document (TSD)

Onsite Equivalence &

5Q Controls

OTR < HC-3

OSA, NRT & DOT/TSQ

≥ HC-3

DOT Package

SRS Manual 11Q

DSA, TSRUSQ

≥ HC-3

SRSManual 19Q

Shipment in

Commerce

Radioactive Packaging Approval Log (RPAL)

10 CFR 830 Subpart B (Safety Basis Requirements) … “The Rule”

Onsite transfer activities containing HC-3 quantities or greater of radioactive materials aresubject to 10 CFR 830 Subpart B, Safety Basis Requirements. The three main requirementsdefined in 10 CFR 830 are:• A DSA that addresses the hazards and the controls necessary to provide adequate

protection to the public, workers, and the environment from these hazards.– Transportation Safety Basis documents: OSAs, NRTs

• Technical Safety Requirements (TSRs) that establish limits, controls, and related actions necessary for safe operations. The exact form and contents of the TSRs will depend on the circumstances as defined in the DSA.– OSA/NRT Controls

• An Unreviewed Safety Question (USQ) process.– Transportation Safety Question (TSQ) Program

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OSA & NRT Methodology

• Two types of documents• Deterministic – Package is credited at its designed performance

– Type B – no release of contents from package during both Routine Conditions of Transport (RCT) & site Credible Abnormal Conditions (CAC)

– Type A or less – no release of contents from package during RCT & no more than 5 rem at site boundary during CAC

• Risk Based – Package is only credited during RCT but not credited during CAC– All contents assumed released during CAC– Utilize SRS-1 design requirements (strong tight/excepted packaging)– Contents limited by dose criteria: < 5 rem at site boundary & < 100 rem at 100 meters– Risk < 5E-2 rem/year (accidents/yr, number of transfers, miles/transfer, content dose)

• Approved by DOE-SR– Reviewed annually

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OTR Methodology

• Establishes DOT equivalence for transfers with < HC-3 Contents– DOE-STD-1027, Hazard Categorization and Accident Analysis Techniques– Lower quantity of radioactive material

• Note HC-3 = ~ 20 A2 Curies on average

• Follow OSA format– Lesser dose criteria: < 5 rem at site boundary & < 5 rem at 100 meters

• Maybe be Deterministic or Risk Based• Not subject to 10 CFR 830 Subpart B (or nuclear safety violations!)

– Complies with applicable DOE Orders & regulations (e.g., 10 CFR 835)• Approved by P&TS Manager

– Not submitted to DOE-SR for approval

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Controls & Programmatic Attributes

• Identified in all OSAs, NRTs, & OTRs• Controls – credited with protecting bounding accident consequences &

frequencies or are considered necessary to ensure contents remain subcritical in CAC– Identified by a “[C]”– Equivalent to a DSA Technical Safety Requirement (TSR)– Violation = ORPS reportable occurrence

• OSA & NRT would be a Group 3 [3A(3)] Nuclear Safety Violation– Potential Inadequacy in the Safety Analysis (PISA) process

• OTR would be a Group 8 Transportation Violation

• Programmatic Attributes – contribute to multiple layers of defense in depth – Identified by a “[P]”– Typically a site program or administrative requirement– Need multiple failures for a reportable occurrence

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Authorization to Transfer Radioactive Material Onsite

• Facility radioactive material transfer procedures and packagings are listed on the Radioactive Packaging Approval Log (RPAL)– Identifies facility, content, procedure(s), TSB/DOT, special restrictions

• Package Review Committee (PRC) reviews facility procedures prior to RPAL listing– DOT (including SARP/SAR), OSA, NRT, OTR– Verifies implementation of all controls & programmatic attributes

• Use Every Time (UET) Procedures (except for OTRs & < Type B)• Initial of steps• Flag P&T steps with trailer

• Update existing RPAL listing via Transportation Safety Question (TSQ) Process– TSQ similar to USQ process but tailored to transportation– Typically used when implementing procedure or TSB is revised

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Summary

• DOT/DOE and 10 CFR 830 Compliant Program– Approved DOT equivalence and 10 CFR 830 methods for transportation– Reviewed annually by DOE-SR

• Graded approach to onsite transportation (OSA/OTR)– Higher Curies / more requirements

• Operational flexibility and cost effective packaging– TSQ program enables facility procedure changes– Lower tier Type A/IP/Excepted packaging used for most transfers

• PRC/RPAL provides consistent review and approvals to all facilities and supports efficient daily operations

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