ML18264A231
| ML18264A231 | |
| Person / Time | |
|---|---|
| Site: | 07109235 |
| Issue date: | 09/19/2018 |
| From: | Fowler W NAC International |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML18264A245 | List: |
| References | |
| ED20180086 | |
| Download: ML18264A231 (6) | |
Text
A NAC INTERNATIONAL Atlanta Corporate Headquarters 3930 East Jones Bridge Road, Suite 200 Norcross, GA 30092 Phone 770-447-1144 Fax 770-447-1797 www.nacintl.com September 19, 2018 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Attn:
Document Control Desk
Subject:
Submission of Replacement Pages for NAC-STC Submittal 18B, Responses to the NRC Request for Additional Information for NAC's Request for a Revision to Certificate of Compliance (CoC) No. 9235
References:
Docket No. 71-9235
- 1. Model No. NAC-STC Package, U.S. Nuclear Regulatory Commission (NRC)
Certificate of Compliance (CoC) No. 9235, Revision 17, April 6, 2017
Revision 17, NAC International, April 2011
- 3. NUREG-1617, Standard Review Plan for Transportation Packages for Spent Nuclear Fuel, March 2000
- 4. NUREG/CR-3854, Fabrication Criteria for Shipping Containers, March 1985
- 5. ED20170024, Request for a Revision to Certificate of Compliance (CoC) No. 9235 for the NAC-STC Cask Gamma Scanning Requirements, March 16, 2017
- 6. NRC Letter, Application for the Model No. NAC-STC - First Request for Additional Information, June 16, 2017
- 7. ED20170026, Submission of Responses to the NRC Request for Additional Information for NAC's Request for a Revision to Certificate of Compliance (CoC)
No. 9235 for the NAC-STC (Submittal 17B), July 17, 2017
- 8. ED20170092, NA C's Request for a Revision to Certificate of Compliance (CoC) No.
9235 for the NAC-STC (Submittal 17C), September 20, 2017
- 9. NRC Letter, Application for the Model No. NAC-STC-Request for Additional Information, February 8, 2018
9235 for the NAC-STC (Submittal 18A), March 6, 2018
- 11. ED20180063, Submission of Responses to the NRC Request for Additional Information for NAC's Request for a Revision to Certificate of Compliance (CoC)
No. 9235 for the NAC-STC (Submittal 18B), July 18, 2018 NAC International (NAC) hereby submits replacement pages for the response to the Request for Additional Information (RAI) provided to the NRC on July 18, 2018 (Reference 11). Editorial errors affect page 11 of the RAI response and SAR changed page 8.2-5 (backing page included). These editorial errors affect both the proprietary and non-proprietary versions of the submittal. The replacement pages for the proprietary submittal are provided in Attachment I and the replacement pages for the non-proprietary submittal are provided in Attachment 2 to this letter.
ED20180086
ANAC rffrl INTERNATIONAL U.S. Nuclear Regulatory Commission September 19, 2018 Page 2 of2 This submittal package contains one hard copy of both the proprietary and non-proprietary versions, which includes the STC-18B replacement pages to Reference 11. The replacement pages to proprietary version of this submittal do not contain proprietary information therefore an Affidavit pursuant to 10 CFR 2.390 is not needed for this submittal.
Consistent with NAC administrative practice, this proposed SAR revision is numbered to uniquely identify the applicable changed pages. Revision bars mark the SAR text changes on the Revision STC-18B pages. In accordance with NAC's administrative practices, upon final acceptance of this application, the STC-18B changed pages will be reformatted and incorporated into the next revision of the NAC-STC SAR. If you have any comments or questions, please contact me on my direct line at 678-328-1236.
Sincerely,~
Wren Fowler Director, Licensing Engineering Attachments: - NAC-STC, SAR 18B Replacement Pages (Proprietary Version) - NAC-STC, SAR 18B Replacement Pages (Non-Proprietary Version)
ED20180086
ED20180086 NAC-STC, SAR 18B Replacement Pages (Non-Proprietary Version)
RAI 8-1 Continued NAC-STC Docket No: 71-9235 CoC No: 9235 NAC International Response to Acceptance and Maintenance Tests Evaluation RAJ 8.1:
In understanding the basis for selecting a visual inspection of the neutron shield shell as the approach to determine continuing compliance with the casks thermal heat rejection design, it is impo1tant to understand the mechanical attachment of the thermal fins to the cask body and the neutron shield shell, as well as the nature of the materials used and the extent of cask normal conditions with which cask operations are performed. The robustness of the design would preclude any degradation of the weldments due to normal cask operations. Any issues associated with the adequacy of the fabrication would be discovered on the first article thermal inspection.
The fin is an explosive-bonded, bi-metallic (copper & 304 stainless steel), component which is attached to the cask body outer shell (304 stainless steel) using a full penetration groove weld with 1/8" fillet reinforcement. The weld is PT examined per Section V, Article 6, with acceptance criteria per Section III, NF-5350.
The neutron shield shell is then attached to the fins using one of two approved methods, full penetration groove welds or a single full penetration double-bevel weld. Again, the weld is penetrant examined per Section V, Article 6, with acceptance criteria per Section III, NF-5350.
Thermal cycling would not impose significant stresses at the connections of these members due to their being similar materials. Normal operations will not fail these connections as there is no loading of the connections described. The instance of an impact capable of imposing loads resulting in deformation or weld failure would be clearly visible by means of a general visual inspection of the neutron shield.
Page II of!&
NAC-STC SAR Docket No. 71-9235, Revision 17B June 2018 Revision 18B post-fabrication thermal test shall be performed in accordance with the fabrication thermal acceptance test as described in Section 8.1.6 with approved written procedures including defined acceptance criteria. The packaging shall meet the acceptance criteria of the post-fabrication thermal test prior to a return to radioactive material transport operations.
8.2.7 Miscellaneous The transport impact limiters shall be visually inspected prior to each shipment. The limiters shall be visually inspected for gross damage or cracking to the stainless steel shells in accordance with approved written procedures and established acceptance criteria. Impact limiters not meeting the established acceptance criteria shall be rejected until repairs are performed and the component re-inspected and accepted.
The cask cavity shall be visually inspected prior to each fuel loading. Evidence of gross scoring of the cavity surface, or build-up of other foreign matter in the cask cavity that could block the cavity drainage paths shall be cause for rejection of the cask for use until approved maintenance and/or repair activities have been acceptably completed. The basket assembly for the directly loaded (uncanistered) or canistered configuration (prior to initial loading) shall be visually inspected for deformation of the basket disks or tubes. Evidence of damage shall be cause for rejection of the basket until approved repair activities have been completed, and the basket has been re-inspected and approved for use.
The radial neutron shield shell shall be visually inspected prior to each fuel loading. Any crack, gouge, or gross deformation that could indicate damage of the heat transfer fins shall be cause for rejection of the cask for use until approved maintenance and/or repair activities have been acceptably completed.
The overall condition of the cask, including the fit and function of all removable components, shall be visually inspected and documented during each cask use. Components or cask conditions which are not in compliance with the Certificate of Compliance shall cause the cask to be rejected for transpo11 use until repairs and/or replacement of the cask or component are performed, and the component re-inspected and accepted.
The results of the visual inspections, leakage tests, shielding and radiological contamination surveys; fuel identification information for the package contents; date, time, and location of the 8.2-5
NAC-STC SAR Docket No. 71-9235, Revision 17B June 2018 Revision 18B cask loading operations; and remarks regarding replaced components shall be included in the cask loading report for each loaded cask transport. The requirements of the cask loading report shall be detailed in the NAC-STC Operations Manual.
8.2.8 Maintenance Program Schedule Table 8.2-1 presents the overall maintenance program schedule for the NAC-STC.
8.2-6