ML17262A045

9/18/2017, Conversation Record with J. Harrison Et Al. Conference Call to Discuss the Status of the Review of the Letter Authorization Request for the Model Number RAJ-II (CAC No. L25239), Non-Proprietary Information. Conversation Held on

ML17262A045
Person / Time
Site:	07109309
Issue date:	09/18/2017
From:	Tae Ahn Renewals and Materials Branch
To:	Harrison J Global Nuclear Fuel
Garcia-Santos N
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ML17262A085	List: ML17262A045
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Download: ML17262A045 (3)

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U.S. NUCLEAR REGULATORY COMMISSION NRC FORM 699

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(03-2013) f

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CONVERSATION RECORD 1/f1(UJJIJ NAME OF PERSON(S) CONTACTED OR IN CONTACT WITH YOU James Harrison. et al.

E-MAIL ADDRESS james.harrison@ge.com ORGANIZATION Global Nuclear Fuel - Americas (GNF-A)

LICENSE NUMBER(S)

NA SUBJECT DOCKET NUMBER(S) 07109309 CONTROL NUMBER(S)

NA DATE OF CONTACT TYPE OF CONVERSATION 08/ 16/2017 TELEPHONE NUMBER (9 10) 620-1826 D

E-MAIL 0 TELEPHONE D

INCOMING 0 OUTGOING NON-PROPRI ETARY INFORMATIO ---8/ 16/2017, 10:00 AM CO FERENCE CALL TO DISCUSS THE STATUS OF THE REV IEW OF THE LETTER AUTHORIZATIO REQUEST FOR THE MODEL UM BER RAJ-II (CAC

0. L25239)

SUMMARY

Attendees:

NRC John McKi rgan Travis Tate Norma Garcia Santos Tae Ahn Andrew Barto Kim Yong Joseph Borowsky Caylee Kenny Daniel Forsyth Continue on Page 2 ACTION REQUIRED (IF ANY)

See ummary.

Continue on Page 3 GNF-A James Harrison Justin Lamy Christopher Kmiec James Fawcett Robert Rand Mine Yi lmaz Brian Eber Russ Fawcett NAME OF PERSON DOCUMENTING CONVERSATION Norma Garcia Santos, et al.

SIGNATURE NRC FORM 699 (03-2013)

Page 1 of 3

NRC FORM 699 (03-2013)

U.S. NUCLEAR REGULATORY COMMISSION CONVERSATION RECORD (continued)

SUMMARY

(Continued from page 1)

I On August 16, 2017, NRC and G F-A participated on a phone call to discuss status of the review of the letter authorization for the Model

o. RAJ-I I for transporting accident tolerant fuel (ATF) lead test assemblies (LT As), gain a common understanding about the licensing action requested, communicate challenges associated with the revieJ, and discuss a possible path forward to continue the review of the application. The fo llowing items summarize the discussion during the August 16 telephone call.

The staff started the meeting by going over the main aspects of the cover letter1submitted with the application to ensure that the staff and the applicant had a common understanding of the licensing actions being requested. The pa11icipants agreed on the fol lowing:

I. The licensing action request consisted of up to 16 ATF lead test rods inside of two G F2 fuel assemblies (a maximum of 8 ATF lead test rods per assembly) per package with a maximum of two packages per shipment.

2. The A TF rods may contain Type A fissile fuel and the G F2 fuel will contai n previously approved Type B quantity fuel.

3. The ATF will be transported in a Type B shipment.

4. The applicant is requesting one shipment per year from 2017 to 2019.

In terms of the number of A TF assemblies to be shipped per year, on the top of page 2 of the cover letter, the applicant mentioned that there would be maximum of 4 A TF lead tests assemblies per shipment. The statement on the top of page 2 of the cover letter seemed to be in agreement with page 3 of the cover letter in which the applicant stated (in proposed condition 4) that "There shall be a maximum of two RAJ-II packages on single truck, each containing a maximum of two LT As." On the propo ed condi tion 5, the applicant mentioned that "RAJ-II packages with G F A TF LT As shall commingle with other RAJ-II packages... " Therefore, it was not clear for the staff the maximum number of A TF FeCrA I rods per package and the number of packages that will be shipped at any given time on a truck, including GNF ATF L TAs. The applicant indicated that the following:

I. The maximum number of ATF rods in a package will be 16.

2. The maximum number of packages per truck (including the packages containing ATF L TAs) will be 13-14 packages.

3. The near term plan is to ship two RAJ-II packages containing ATF L TAs commingling with other packages containing GNF fuel.

4. The applicant requested the flexibility to ship GNF fuel with GNF fuel containing ATF FeCrAI rods.

The wording of the proposed Condition 4 was clear that a maximum of two packages could be loaded per truck. When one member of the applicant's organization mentioned that the condition did not preclude additional packages on a truck. another G F-A member rightly stated that the word ing could be improved to express the application's clear intention.

Based on the evaluation section of the cover letter, the staff asked ifthe applicant was relying on the cladding as the containment boundary or not, since the evaluation section mentions that the structural and thermal evaluations demonstrated that the G F FeCrA I fuel rods would not rupture. The applicant clarified that since the application Ii i1its FeCrA I fuel rods to Type A fissile content, the applicant is not relying on the cladding as the containment boundary, but as a barrier to maintai n the pellets in a safe geometry (i.e..

for criticality safety purposes). The applicant also indicated that it analyzed water entering into the pellet-cladd ing gap. The staff mentioned that a concern was failure of the cladding resulting in pellets getting out of the cladding and radioactive material reconfiguration. The applicant mentioned that ifthe cladding burst, the applicant does not have physical data to indicate that pellet migration outside of the rod is possible. The applicant pointed out that UREG/CR-1 458 and NU REG/CR-5892 document a I

transportation accident involving a shipment ofG F fuel assemblies (including a beyond design basis tire), which caused a breach of the cladding. These NUREGs concluded that there was no fuel or pellet migrati n outside of the fuel rod and that a criticality accident was not possible during the accident or after the tire. The applicant pointed out this was included in Section 6.6.2.2 of the Letter Authorization Request. The applicant pointed out that, currently, the structural and thermal analyses do not support migration of pellets outside of the cladding under hypothetical accident conditions. However, staff had comments/questions with the structural and thermal analyses provided. The discussion below includes the staffs initial comments and questions related to the application.

Materials Evaluation The staff pointed out that the FeCrAI material is a ferritic steel. Therefore, the ta ff indicated that the applicant should use Regulatory Guide 7. I I as mentioned in the pre-application meeting. The staff asked if the ssessment of the cladd ing integrity was based on the 9 meter drop test assuming zirconium material. The applicant responded that was correct. The staff also mentioned that Figure 2-1 of of the appl ication includes a strain curve at -20 F. The applicant tated that testing of the FeCrAI material was performed at a strain rate of[withheld per 10 CFR 2,390 (application)], to which the staff commented that it wa high in comparison of a conventional strain rate. The applicant indicated that the strain rate was based on the fo llowing:

NRC FORM 699 (03-2013)

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NRC FORM 699 (03-2013)

U.S. NUCLEAR REGULA TORY COMMISSION CONVERSATION RECORD (continued)

ACTION REQUIRED (Continued from page 1)

I. the duration of the impact of the RAJ-II package in previous drop tests of zirconium alloy;

2. the strain rate of the claddi ng is "controlled" by the package design (since the package design did not change, the applicant assumed that the strain rate did not change); and

3. the assumption that the design of the zirconium alloy and A TF LT A fuel bundle designs are similar for the limited number of FeCrAI rods in an ATF LTA.

The applicant did not perform physical drop tests with FeCrAI rods and assumed these were bounded by (or equi valent to) the testing performed with zirconium alloy rods. Therefore, the applicant's approach is to use the testing to certi fy the RAJ-II package fo r the ATF application.

The staff indicated that the strain rate may be acceptable, but the staff still needs information to determine whether there may be a localized effect related to the FeCrAI material. The applicant noted that the FeCrAI survi ved from a high strain rate tensile test without a fracture. The staff pointed out that the cladding of the A TF FeCrAI rod is very thin and the staff would need the fo l lowing:

I. confirm (from related literature data or testing) that the slope of stress-strain curve is higher fo r FeCrAI compared to that for zircaloy. (Otherwise, FeCrAI rods among zirconium alloy rods may be bulged out or broken during drop. Provide the stress-stra in curves for FeCrAI and zircaloy claddings so that a comparison can be made.)

2. data related to microhardness testing, fracture testing, Charpy V-notch test, tc.;

3. strain curve at low temperature (to veri fy whether the strain rate is appropriate fo r FeCrAI); and

4. a temperature range to maintain the integrity of the claddi ng.

The application contains a requirement for the Young's Modulus in Attachment 2 Table 2-5 (also repeated in A tt ac hm e nt

~ Table 1-2) which requires a minim um Modu lus of Elasticity for the G F FeCrAI material to be used. The applicant stated that the lower temperature of the HAC is -40°C so that was the temperature that the test was performed to bound the necessary temperature range of operation. A Stress-Strain curve fo r the GNF FeCrAI material at -40°C is provide in Attachment 3 Figure 2-1.

The Regulatory Guide 7. 11 requi rements are based off material that is 0.025 inches and thicker depending on the category classification. The fuel cladding wall thickness is below 0.025 inches for this a pl ication. The applicant stated that the thin claddi ng wall provides an additional margin against brittle fracture in the material relati e to the Regulatory Guide 7. 11 requirements because the stress states would be geometrically forced to be in plane stress loading which has a higher fracture toughness than the plane-strain loading.

Creep Model Evaluation The staff noted that it may have questions related to the fo llowing topics:

I. bases for the allowable hoop stress of 65.2 mega pascals (MPa);

2. reference and j ustification of the generalized creep equation;

3. some inconsistencies with units (e.g., kilo Joule per mol (kJ/mol) versus kilo Joule per Kelvin mol (kJ/K *kmol)] needs to be revised;

4. demonstrate that the I 0% creep strain limit is conservative and provide the PeCrA I stress-strain curve at the high temperatures; and

5. discussion about how the hypothetical accident condition thermal tests and analysis consider the damage from other hypothetical accident condition tests (e.g., drop, impact). The staff asked similar questions in the recent revision to the Model No. RAJ-I I (Ce11ificate of Compliance, Revision 11 ).

At the end of the meeting the applicant expressed interests on having additional phone calls to discuss the staffs questions and a face-to-face meeting. Division of Spent Fuel Management staff and management no 1ted that the applicant can also request a public meeting to have a detailed discussion of the staffs questions. The applicant al o requested that if a meeting were to be scheduled, having RC questions at least a week in advance would enhance the value of the meeting.

NRC FORM 699 (03-2013)

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