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At least 19 records

Recertification of the DOE 9978 Type B Package: Lessons L

The history and limited use of the 9978 Type B package history represents a complex case story. Unprecedented delays (from Covid-19) caused the annual maintenance of nine loaded 9978 packages to expire before the actual shipments were initiated. Additionally, with the delays, the content amendment authorizing the Pu and Am standards as authorized content expired, hence additionally requiring a full SARP revision prior to making the shipments

Ketusky, Edward T. [Savannah River National Labora↗

Complete Documentation of Applicable Regulations and Regulatory Authority for Transportation

This report fulfills the M4 milestone M4MR-20PN0303023, “Complete Documentation of Applicable Regulations and Regulatory Authority for Transportation. Microreactors are very small nuclear reactors with a power output of 20MWe or less and are designed to be factory-built, modular in nature, and highly portable. The objective of this report is to identify and document applicable regulations, the appropriate regulatory authority, and the associated framework for microreactor transport. Sections 2 and 3 of this report summarize U.S. Department of Transportation (DOT) and NRC regulations related to the transportation of Class 7 (radioactive) materials. These sections concentrate on the transport of fissile material packages and Type B packages, which would be most applicable to the transport of a microreactor before and after irradiation. Section 4 summarizes DOE hazardous and radioactive material transportation regulations. Section 5 summarizes U.S. Coast Guard regulations related to the transport of radioactive material. Section 6 discusses state requirements for the permitting of oversize and/or overweight truck shipments. Section 7 presents detailed schedules of requirements for transporting fissile material packages and Type B packages based on NRC and DOT regulations. The schedules are presented in a two-column format, the right column is the regulatory requirement and the left column is the citation of the regulation in which the requirement is found.

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REGULATORY TESTING AND 3D SCANNING METHODOLOGY OF THE DPP-1 TYPE SHIPPING CONTAINER FOR NCT AND HAC TESTS

The safe transportation of radioactive material using appropriately designed and certified transportation packages is important to protect the public and environment. In the United States of America all transportation of radioactive material is regulated by the Department of Transportation (DOT) along with input by the Nuclear Regulatory Commission (NRC). All packages that contain radioactive material requires that it be transported and regulated by the requirements set by the DOT Class 7 hazardous material transportation. Federal regulations place strict administrative controls on the transport of radioactive materials. The two main goals for transporting radioactive materials are 1. Safety should be the primarily focused on the package because it is the first line of defense. 2. Package integrity should be directly related to the degree of the hazard of the radioactive material contents. The two-part goal ensures that the right package is used. Type B packages are designed to transport radioactive materials with the highest level of radioactivity. Examples of material transported in Type B packagings include spent nuclear fuel, high-level radioactive waste, and high concentrations of other radioactive materials. The purpose of this test protocol is to determine the effects of drop and thermal testing on package performance in a Type B shipping package (DPP-1). Required physical tests for the DPP-1 package include free drop, crush, puncture, penetration, compression, vibration, water spray, water immersion, and thermal. The preparation, regulatory testing, and post-test evaluation of a Type B shipping package tested to the 10 CFR 71.71 and 10 CFR 71.73 requirements will be presented. Six packages were tested and the responses when subjected to the HAC sequence of free drop, puncture, and thermal tests according to 10 CFR 71.73(c)(1), (c)(2), (c)(3) and (c)(4) were measured. The Free Drop, Crush and Puncture tests were performed at the NTRC in Knoxville, TN, and the Thermal tests were performed Southwest Research Institute in San Antonio, TX. The test units were subjected to a pre-operational leak testing before the NCT and HAC tests and a post-operational leak test and a helium leak test once regulatory testing was complete. Finally, all test units were scanned with a handheld blue light scanner to capture a 3D CAD geometry of the test units in the deformed shape. The handheld scanner provided the most effective and reliable way to acquire accurate 3D measurements of the test unit. The scanned geometry was sectioned in areas with deformation and the cross-section profile was measured to determine accurate and repeatable results of the deformed shape of the test units.

Martinez, Oscar↗

Development and Demonstration of a Risk Assessment Approach for Approval of a Transportation Package of a Transportable Nuclear Power Plant for Domestic Highway Shipment

The U.S. Department of Defense (DoD) Strategic Capabilities Office (SCO) has tasked PNNL to address the regulatory challenges associated with confirming the safe transport of Transportable Nuclear Power Plants (TNPPs) containing irradiated nuclear fuel. A previous report—Proposed Risk-Informed Regulatory Framework for Approval of Microreactor Transportation Packages (PNNL-31867)—determined that the expected radioactive inventory in the irradiated fuel of a TNPP would likely require shipment in an NRC-approved Type B package (or spent nuclear fuel cask) but that a TNPP “package” is unlikely to meet the entire suite of NRC requirements set forth in Part 71 of Title 10 of the Code of Federal Regulations (CFR) for a Type B package. It was therefore concluded that shipment of this initial TNPP transportation package, as well as possibly others, under existing regulations would likely require NRC approval using the 10 CFR 71.12 (“Specific exemptions”) process that relies on risk-informed decision making supported by quantitative risk assessment (i.e., Probabilistic Risk Assessment).

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Technology Development of a High-Capacity High-Assay Low Enriched Uranium Transportation Concept

This paper discusses the technology development (TD) efforts that led to the development of a High-Capacity High-Assay Low Enriched Uranium Transportation (HALEU) transportation concept. In 2018, the Department of Energy (DOE) Office of Nuclear Technology and Research Development tasked Idaho National Laboratory (INL) to investigate strategies to transport large quantities of HALEU. To complete this task, INL collaborated with Pacific Northwest National Laboratory and Oak Ridge National Laboratory. The project was completed in 2020, and one of the project outcomes was a transportation concept that consisting of five individual Type B packages transported on a single legal-weight truck (LWT). The total payload capacity of this concept is 1,881 kg (4,149 lb) of HALEU in the form of uranium dioxide (UO2) powder. The concept utilizes an existing Type B packaging design carrying a novel fuel basket design with an incorporated flux trap. The basket can be loaded with 18 individual fuel canisters. The research collaboration investigated the U.S. certification potential of this concept. This part of the project included evaluations of criticality safety, radiological safety, thermal safety, structural integrity, and confinement under hypothetical accident scenarios of transport. The results of these evaluations demonstrated a promising potential for U.S. certification of this concept. Eventually, the described efforts led to the pursuance and issuance of a U.S. patent, thus, protecting the associated intellectual property (IP). Current short-term goals include making this IP available to private industry partners for licensing, directly supporting DOE’s objectives of accelerating commercialization of national laboratory-generated IP. If additional funding becomes available, long-term research goals could include exploring the feasibility of transporting other uranium chemical forms (e.g., UF4) with this concept, or refining operational procedures to load or unload the packagings.

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Cask RT-100 Type B(U) Self-Certification for DOT 7A, Type A Nuclear Waste Transportation - 20098

The purpose of this Type A certification is to diversify the use of the RT-100 cask by allowing the end user to transport either Type A or Type B radioactive waste in accordance with the handling procedures for each waste category. The project's scope included the development of a matrix that contains all applicable requirements for a Type A package from the Code of Federal Regulations (CFR), Title 49 for the Department of Transportation (DOT) with a justification for each requirement. Moreover, the scope included the writing of conditions and restrictions list for the transportation of Type A nuclear waste, the writing of a compliance statement, and the design and fabrication of a Type A placard to be permanently placed on the RT-100 cask. Type A packages are self-certified by the end user using one of three methods as permitted by 49 CFR 173.461, either by performance of tests with prototypes or samples of the specimens representing the packaging, or reference to a previous satisfactory demonstration of compliance of a sufficiently similar nature, or calculations or reasoned evaluation using reliable and conservative procedures and parameters. Since the RT-100 cask was licensed by the Nuclear Regulatory Commission (NRC) as a Type B cask, Robatel relied on the method of reference to a previous satisfactory demonstration of compliance of a sufficiently similar nature for Type A certification. This method was determined to be acceptable, since Type B packages are evaluated for more demanding transport conditions than those required for Type A packages. This paper presents Robatel's process for certifying the RT-100 cask for Type A shipments, an overview of the DOT regulations related to Type A packages, and the documents that were generated for the end user. This paper is concluded with a discussion on the advantages of having the option to transport both Type A and Type B nuclear waste, and possible future projects to further improve the operation of the cask when making Type A shipments. (authors)

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Combined Effort to De-Inventory the New Brunswick Laboratory of Plutonium Certified Reference Materials - 20504

To de-inventory plutonium Certified Reference Materials standards (CRMs) from the New Brunswick National Laboratory (NBL), the Argonne National Laboratory (ANL) and Savannah River National Laboratory (SRNL) formed a unique team. This teaming arrangement leveraged the different capabilities and expertise of both laboratories, helping to ensure the effort would be performed both safely and cost-effectively. With the NBL then physically housed on the ANL site, ANL served as the host-site, providing the necessary facilities and support services (e.g., supplying everything from hoods, loading equipment, and scales to Health Physics supports). From a packaging perspective, ANL's responsibilities focused mainly on characterizing and preparing the contents for shipment, followed by performing the Shipper of Record activities. With SRNL being the Package Design Authority of the 9978, the Type B packaging used for this effort, SRNL's scope included developing a Safety Analysis Report in Packaging (SARP) Letter Amendment to add the CRMs as authorized contents to the 9978. Recognizing competency, ANL prodigiously tasked SRNL to perform the actual loading of the CRMs into the 9978s, while physically on the ANL site. This paper details five different aspects of this effort. They are: 1. Characterization/validation of the CRM contents. 2. Development of the 9978 SARP Letter Amendment for the content change. 3. Development of the nitrogen inerting method to address SARP identified potential flammability concerns. 4. Renewal of the SRNL 9978 loading procedure. 5. Performance of the actual work execution activities. In 2017, the first nine packages were successfully loaded and shipped from NBL, while in 2019, the last ten were successfully loaded and planned for shipment. Without ANL leveraging SRNL's strengths, the de-inventorying of NBL of its plutonium CRMs would have likely taken many years longer. (authors)

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ADDITIVE MANUFACTURING AND REGULATORY TESTING OF CANISTERS FOR SPENT NUCLEAR FUEL MANAGEMENT

The back end of the fuel cycle focuses on the interim storage, transportation, and final disposition of the spent nuclear fuel from nuclear reactors. Commercial light water nuclear power stations across the United States operate with fuel assemblies being irradiated for up to 6 years (planned) in the reactor pressure vessel. After their planned irradiation, the fuel assemblies are moved to a spent fuel pool within the facility complex. After the spent nuclear fuel is removed from the fuel pool, it is typically inserted into a welded metal canister that can be transferred between overpacks for storage, transportation and possibly disposal. Most dry storage systems being used by industry today use dual purpose canisters (DPCs), designed for use in storage and transportation overpacks, but not specifically designed for disposal. Triple purpose-canisters, designed for disposal in addition to storage and transportation, have also been researched. Traditional manufacturing methods for spent fuel canisters involve fusion welding along the length or circumference of the canister which results in high tensile residual stresses in the joint weld zone (WZ) and heat affected zone (HAZ). In this paper, spent fuel canister designs were printed by wire arc additive manufacturing (AM) using the 316L SS welding wire to demonstrate: 1. Feasibility of spent nuclear fuel canister fabrication using this advanced manufacturing method, 2. Dynamic response of the additive manufacture canister design when subjected to the federally mandated Normal Conditions of Transport (NCT) and Hypothetical Accident Conditions (HAC) physical tests for Type B packages. This paper will focus on the canister printing design and structural tests. The AM 3D printed design, regulatory testing, and post-test evaluation of the canister tested to the 10 CFR 71.71 and 10 CFR 71.73 requirements will be presented. One AM canister design was subjected to the penetration, free drop, and puncture test. Before and after the dynamic structural tests, the AM canister design was scanned with a handheld scanner to capture a 3D CAD geometry to compare to the 3D printed canister design in the deformed shape. The scanned geometry was sectioned in areas with deformation and the cross-section profile was measured to determine accurate and repeated results of the deformed shape of the AM canister design.

Martinez, Oscar↗

Development of a Helical Closure for Radioactive Material Shipping Packages

The Savannah River National Laboratory (SRNL) Packaging Technology group proposed a closure design for the outer packaging of a prototype Type B shipping package being developed for the Department of Energy (DOE). The closure design provides an efficient means of securing the containment vessel (CV) within the radioactive material packaging. This design has a simplified operation, requires less components, and less maintenance when compared to current radioactive material package closure methods. This paper will review and discuss the materials, designs, processes, and testing activities that were considered and pursued in the development of the novel closure for the outer packaging of new radioactive material shipping packages.

Housley, William M. [Savannah River National Labor↗

REGULATORY TESTING AND POSTTEST ANALYSIS OF THE DPP-3 TYPE B SHIPPING CONTAINER FOR NCT AND HAC TESTS

The safe transportation of radioactive material using appropriately designed and certified transportation packages is important to protect the public and environment. Therefore, a comprehensive and rigorous system of packaging requirements are required. The purpose of this test protocol is to determine the effects of drop testing on package performance in a Type B shipping package (DPP-3). Required physical tests for the DPP-3 package include normal conditions of transport and hypothetical accident conditions test requirements. The preparation, regulatory testing, and post-test evaluation of a Type B shipping package tested to the 10 CFR 71.71 and 10 CFR 71.73 requirements will be presented. Six packages were tested and the responses when subjected to the HAC sequence of free drop, puncture, and thermal tests according to 10 CFR 71.73 were measured. The posttest helium leak test showed a leak rate less than 1 × 10-7 He-cc/sec which means that the containment boundary was maintained after the regulatory testing, therefore maintaining a leak tight environment. To determine the amount of change in the package performance measurements, statistical analyses were conducted using SPSS version 26. The null hypothesis of the testing was that there would not be a change in the measurements from pre to post-testing large enough to find statistical significance. Therefore, a finding of statistical significance indicated too much variability in the package design and was deemed an unfavorable finding. A repeated measures t-test was used to analyze the drum lids and CV torques. A one-way ANOVA was used to analyze height and diameter packages. Results of the repeated measures t-test indicated that all six containment vessel lid torques were statistically significant. However only three out of the six drum lid torques were statistically significant. Therefore, design of the lids caused more variability than necessary when subjected to the following drop tests: 1.) horizontal and cold; 2.) vertical lid down; and 3.) corner with lid up. Results of the one-way ANOVA analysis on height indicated that four out of the six CTUs were statistically significant. Thus, design of the CTUs caused more variability then necessary when subjected to the following drop tests: 1.) horizontal hot; 2.) horizontal cold; 3.) corner lid up; and 4.) corner lid down. Results of the one-way ANOVA analysis on diameter indicated that all six CTUs were statistically significant. Thus, design of the CTUs caused more variability then necessary when subjected to all of the tests. The DPP-3 design has been shown to be an acceptable design for the transport of radioactive materials. However, results of the statistical analysis reveal a possible improvement in package and test design to reduce variability in package performance measurement before and after testing.

Martinez, Oscar↗

OPTIMUS{sup TM} Packaging for Intermediate Level Wastes and Spent Fuel - 20129

NAC's OPTIMUS{sup TM} packaging is a family of Type B(U)F transportation packages designed for maximum flexibility and cost-efficiency to support shipment of a wide range of challenging wastes and materials. They are small, modular packaging designs meeting DOT weight limits for road transport. OPTIMUS{sup TM} contents include low level waste, mixed low-level waste, irradiated fuel waste and intermediate level waste. Contents can also include aerosol cans with compressed gas and liquefied gas propellants and standard DOT 3E lecture bottles for shipment to treatment facilities. OPTIMUS{sup TM} packaging provides a cost-effective solution for challenging and unique waste contents combined with design simplicity and operational flexibility meeting the requirements of both SSR-6 and 10 CFR 71 for Type B(U)F packaging. The modular design of the packaging components combined with the flexibility to add modified internals for enhanced packaging performance makes OPTIMUS{sup TM} the preferred solution for many radioactive material transportation needs. The OPTIMUS{sup TM} product line currently includes two packaging designs; OPTIMUS{sup TM}-L and OPTIMUS{sup TM}-H. OPTIMUS{sup TM}-L is a lightweight transportation packaging intended for low-activity wastes, whereas OPTIMUS{sup TM}-H is a larger, heavier package intended for high-activities wastes. Due to its small size and weight, six (6) to ten (10) OPTIMUS{sup TM}-L packages can be accommodated on a single legal-weight truck shipment, depending on the weight of the contents. For typical payloads, two (2) OPTIMUS{sup TM}-H packages can be accommodated on a single legal-weight truck shipment. The OPTIMUS{sup TM} packaging share the same cask containment vessel (CCV) in the OPTIMUS{sup TM}-H and OPTIMUS{sup TM}-L. The large cavity size of the CCV, which can accommodate a 416-liter (110-gallon) drum, combined with the small size, low weight and modularity of the OPTIMUS{sup TM} packaging provides unmatched flexibility. In this paper, NAC provides a technical overview of the OPTIMUS{sup TM} packaging and identifies the design features and technology advancements making the OPTIMUS{sup TM} a readily adaptable and flexible solution for packaging processing facilities, reactor and decommissioning wastes. Optimized shielding performance through the addition of internal shielding components and alternative shipping configurations are discussed. In addition, an overview of the first major deployment of the OPTIMUS{sup TM} packaging for the Whiteshell Laboratories Closure Project (WLCP) is discussed. (authors)

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Best Practices for Shielding Analyses of Activated Metals and Spent Resins from Reactor Operation

This report investigated best practices for performing shielding evaluations of Type B waste packages, as defined in 10 CFR Part 71 regulations on packaging and transportation of radioactive material, or packages for which the contents are not defined before loading and may include a broad range of nuclides, geometries, and non-fuel materials. The following non-fuel waste streams were analyzed: Activated metals from decommissioned commercial power reactors, including Type 304 stainless steel, reactor vessel steel, and Inconel, Control blades from boiling water reactors, Neutron-activated corrosion products on surfaces of activated metals, and Spent resins from power plant operations. Measured elemental compositions, including major constituents and impurities, for steel and Inconel samples from commercial power reactors were used in activation calculations to determine radionuclide inventories in activated metals. For a simplified cask model, 60 Co contribution to the total external package dose rate at 30 days after shutdown varied from approximately 60% to 95%, depending on the activated metal, initial cobalt impurity concentration in the metal, and the thickness of the overpack gamma shield. Its maximum contribution to the total external package dose rate of approximately 100% was reached within the time interval of 2 to 5 years after shutdown and was maintained for up to 45 to 60 years after shutdown, depending on material, initial cobalt impurity concentration, and shield thickness. Thereafter, the 60 Co contribution to external package dose rate decreased with increasing decay time. Cobalt-60 is primarily produced by neutron reactions with the cobalt impurity in steel and Inconel. Other important radionuclides in activated metals contributing to package external dose rate are radionuclides with relatively short decay times, including 51 Cr, 59 Fe, 58 Co, and 54 Mn. These radionuclides may be represented as an equivalent 60 Co activity/source because 60 Co gamma ray emissions are bounding in terms of source strength and energy to other important radionuclides identified in the analyzed activated metals. Approaches for modeling the neutron-activated corrosion products that may be attached to activated reactor components were analyzed in this report. It was demonstrated that a surface source is more conservative than a uniform volumetric source for the treatment of neutron-activated corrosion products with respect to external package dose rates. An analysis of the maximum radionuclide loadings reported on spent resins identified the radionuclides 137 Cs, 60 Co, 134 Cs, 65 Zn, and 58 Co as the primary contributors to external package dose rate. For a resin cooled for 3.08 years, the external package dose rate was entirely produced by the reported 137 Cs and 60 Co inventory. The neutron sources from actinides found on spent resins or activated metals produced negligible dose rates and may be ignored in dose rate analyses. Effects of idealized waste material, source geometry, and spatial material/source distributions on external package dose rates were determined based on dose rate results for a simplified cask model under normal conditions of transport. Type 304 stainless steel, zirconium, and aluminum with adjusted mass densities based on a maximum content weight were analyzed for material modeling effects on external package dose rate. These materials produced identical external package dose rates within the statistical uncertainties of the dose rate estimates. Among four different source geometry configurations with homogeneous material of different mass densities, uniform volumetric source distribution, and the same source strength, the geometry configuration with lowest mass density (i.e., minimum self-shielding effect among the four cases) was most conservative. Spatial source distributions that better represent localized peak 60 Co activity values were more conservative than a uniform volumetric source distribution, assuming the same weight and total source strength per package. The increase in external dose rate caused by localized source peaks can be as much as the ratio between source peak activity density to average activity density, depending on the location of the activated metal with peak activity density. Therefore, the shielding analysis may be simplified if localized peak activities and the average activity per package can be measured/determined and documented at the time of cask loading. For simplicity, external package dose rates may be determined based on average source activity and a uniform volumetric source distribution. The dose rate results from that calculation model multiplied by the ratio of peak activity density to average activity density will produce maximum dose rate values for conservative estimates.

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UO 2 HALEU Transportation Package Evaluation and Recommendations

This M3FT-19IN030205042 milestone report presents the current status on investigations related to the development of HALEU transportation capabilities in the U.S. The report initially reviews potential short-term HALEU production options and describes an expected HALEU composition. It then discusses the regulatory bases for HALEU transportation and identifies two compliant packaging designs: (1) the TN Americas TN-LC and (2) the NAC International OPTIMUS™-L. To modify these designs for HALEU transportation, an inner canister concept, and modular metal and foam basket concepts were developed, and this is described in the report. The expected activity, criticality tendency, radiation level, and decay heat of the package content are evaluated considering the specific system characteristics. Based on the results of the investigations, the research team consisting of INL, PNNL, and ORNL staff concluded that, given the anticipated source material composition, the OPTIMUS™-L, or a comparable design, is the preferred candidate. This is due to its larger HALEU payload per LWT, lighter weight, and simpler handling procedures compared to the TN-LC. Thus, ongoing research efforts for the scope of this project will focus on more thorough evaluations of the OPTIMUS™-L packaging for HALEU transportation. A tentative timeline is presented for the remaining work that is planned for FY 2020. The goal is the development of F&Rs that provide guidance to a potential HALEU transportation package vendor on critical specifications by August 2020.

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ORNL Package Testing Program Overview

Radioactive materials are widespread in our everyday activities which are used in many different types of industries: Consumer products, Medicine, Industry, Energy, and Defense. In the United States there is about 3 million shipments of radioactive materials per year. With radioactive material being very widespread the number of new applications to ship these quantities increases daily. As such, ensuring the safe and secure transport of these materials is paramount, necessitating stringent packaging, transportation, and certification requirements. Shipments of radioactive materials have been made from Oak Ridge National Laboratory (ORNL) for the past 65 years. Since the 1940s ORNL has been at the forefront of the early development of regulations pertaining to the transport of radioactive shipments and associated regulatory testing. The early involvement resulted in ORNL being one of the leaders in the development of regulations and testing standards pertaining to the testing and design of packages. Today all package testing activities are conducted under the Package Testing Program (PTP) at ORNL at the Package Evaluation Facility (PEF). The PTP develops and evaluates testing solutions – ensuring that they are safe, efficient, and meet regulatory requirements ORNL PTP has extensive experience in the regulatory testing of radioactive material packages, supporting certification of Type A, Type, B, Type AF, and special form packages. The PEF serves as a one-stop-shop for design, testing, and certification of a wide variety of packages needed for shipment of radioactive materials. The facility provides the space, expertise, and equipment necessary to conduct rigorous performance testing under both normal and accident conditions or transport environments including free drop, dynamic crush, puncture, penetration, compression, vibration, water spray, water immersion, and thermal test. The PTP remains a key contributor to the safety and compliance of radioactive material transportation. This presentation will provide an overview of the program’s history, capabilities, and its ongoing role in advancing regulatory standards and transportation safety.

Martinez, Oscar [ORNL] (ORCID:0000000181814046)↗

Deploying Automation Technology Supporting Packaging and Transportation Operations

Various United States Department of Energy (DOE) sites are investigating the deployment of robotics to provide safer, effective, and more efficient operations. By implementing robotics in packaging and transportation operations, improvements toward production efficiency, worker ergonomics, radiological dose reduction, and security assurance can be realized. Robotic Systems must be designed and implemented in concert with a facility’s safety basis, classification, and security constraints, while improving overall operational effectiveness. The desired robotic implementation should provide a path to potential long-term cost savings, reduce/eliminate hazardous conditions and radiological exposure, while improving quality and reliability of an operation process. The Savannah River Site (SRS), a DOE Site located in Aiken South Carolina, has initiated several large scale projects supporting future nuclear material disposition activities. Incorporation of automation and robotic equipment in system designs will support effective and efficient material handling operations, including container movements and packaging activities. Robotic systems will execute tasks that are precise, procedural and integrated with control systems to verify and record data for material inventory and historical archiving. An overview of the current robotic system development to perform receipt inspection, packaging, storage and shipment preparation activities of designated Type A and B shipping packages will be presented.

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