ML18270A093
| ML18270A093 | |
| Person / Time | |
|---|---|
| Site: | 07109342 |
| Issue date: | 09/26/2018 |
| From: | Nishka Devaser Spent Fuel Licensing Branch |
| To: | Sewell P Daher-TLI |
| Devaser N | |
| References | |
| EPID L-2018-LLA-0100 | |
| Download: ML18270A093 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 26, 2018 Mr. Philip Sewell Senior Engineer 8161 Maple Lawn Boulevard Suite 450 Fulton, MD 20759
SUBJECT:
APPLICATION FOR AMENDMENT REQUEST OF CERTIFICATE OF COMPLIANCE NO. 9342 FOR THE MODEL NO. VERSA-PAC - REQUEST FOR ADDITIONAL INFORMATION
Dear Mr. Sewell:
By letter dated March 16, 2018 (Agencywide Documents Access and Management System Accession No. ML18087A451), Daher-TLI submitted an application in accordance with Title 10 of the Code of Federal Regulations Part 71 to amend Certificate of Compliance No. 9342 for the Model No. Versa-Pac package per the details of the submitted revision of the safety analysis report, Revision 10. In connection with the U.S. Nuclear Regulatory Commission staff review, we need the information identified in the enclosure to this letter. Additional information requested by this letter should be submitted in the form of revised pages. Please provide your response within two months from the date of this letter.
Please reference Docket No. 71-9342 and Enterprise Project Identifier No. L-2018-LLA-0100 in future correspondence related to this request. The staff is available to meet to discuss your proposed responses. If you have any questions, I may be contacted at (301) 415-5196.
Sincerely,
/RA/
Nishka Devaser, Project Manager Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-9342 EPID No. L-2018-LLA-0100
Enclosure:
Request for Additional Information
P. Sewell APPLICATION FOR AMENDMENT REQUEST OF CERTIFICATE OF COMPLIANCE NO. 9342 FOR THE MODEL NO. VERSA-PAC - REQUEST FOR ADDITIONAL INFORMATION, DOCUMENT DATE: September 26, 2018 DISTRIBUTION: DSFM r/f, G:\SFST\Devaser\Casework\Daher-TLI Versa-Pac Review - RAI 1 Letter.docx ADAMS Package No.: ML18270A093 *via e-mail OFC DSFM DSFM DSFM DSFM DSFM DSFM NAME NDevaser SFigueroa JIreland JSmith CKenny DTarantino DATE 08/09/18 08/09/18 08/14/18 08/16/18 08/14/18 08/14/18 OFC DSFM DSFM DSFM DSFM DSFM NAME ARigato TTate YDiaz-Sanabria MRahimi JMcKirgan DATE 08/15/18 08/16/18 09/23/18 08/22/18 09/26/18 OFFICIAL RECORD COPY
Request for Additional Information Daher-TLI Docket No. 71-9342 Certificate of Compliance No. 9342 Versa-Pac Transportation Package By letter dated March 16, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18087A451), Daher-TLI submitted an application in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 71 to amend Certificate of Compliance No. 9342 for the Model No. Versa-Pac package. This request for additional information identifies information needed by the U.S. Nuclear Regulatory Commission staff (the staff) in connection with its review of the application. The staff used guidance provided in NUREG-1609, "Standard Review Plan for Transportation Packages for Radioactive Material, in its review of the application.
Each question describes information needed by the staff for it to complete its review of the application and to determine whether the applicant has demonstrated compliance with regulatory requirements.
Containment Evaluation C1-1. Address how the contents are a Type A quantity considering the enrichment weight percent (wt.%) of U-235 in Tables 1-1, U-235 Loading Table for VP-55 and VP-110 Standard Configuration, 1-1A, U-235 Loading Table for the VP-55 with 5-inch Pipe, 1-1B, 1S/2S Cylinder Limits for the VP-55 (up to 20wt.% U-235), and 1-1C, 1S/2S Cylinder Limits for the VP-55 with 5-inch Pipe (up to 100wt.% U-235), of the application.
The high enrichment weight percent of U-235 in Tables 1-1, 1-1A, 1-1B, and 1-1C of the application may result in additional radionuclides or impurities that could exceed a Type A quantity. Therefore, while the A2 value for U-235 is unlimited, it has not been shown in the application that the contents are a Type A quantity.
This information is needed to determine compliance with 10 CFR 71.33(b).
C4-1. Clarify Chapter 4, Containment, of the application to be consistent with Section 1.4.6.1, VP-55 with 5-inch Pipe Packaging Description, of the application. In addition, describe how the 5-inch pipe provides positive closure, summarize how it meets the containment requirements for normal conditions of transport and hypothetical accident conditions, and address any pressure rise within the 5-inch pipe during normal conditions of transport and hypothetical accident conditions. Also, ensure the analysis results in Chapter 3, Thermal Evaluation, are consistent with the description of the containment boundary.
Section 1.4.6.1 of the application describes, When using the 5-inch pipe in the VP-55 the containment boundary is defined as the 5-inch pipe, as all radioactive material is confined inside the pipe during transport conditions. Chapter 4 of the application does not describe the 5-inch pipe as the containment boundary, therefore it is not clear if the conclusions in that chapter continue to apply for that containment boundary. Chapter 4 of the application should describe the positive closure of the 5-inch pipe. Chapter 4 of the application should summarize that there is no loss or dispersal of radioactive material under normal conditions of transport for the 5-inch pipe by referencing specific sections of the application where this is demonstrated. Chapter 4 of the application Enclosure
should also summarize that the package must contain the contents to ensure subcriticality under both normal conditions of transport and hypothetical accident conditions by referencing specific sections of that application where this is demonstrated. In addition, Chapter 4 of the application should address any pressure rise within the 5-inch pipe during normal conditions of transport and hypothetical accident conditions. Also, the analysis results provided in Chapter 3 of the application that refer to the containment boundary should be consistent with the 5-inch pipe containment boundary description, when the 5-inch pipe is used in the VP-55 (e.g., Figures 3-27 through 3-30).
This information is needed to determine compliance with 10 CFR 71.43(c), 71.43(f),
71.55(d)(1), 71.55(e), 71.71(c)(1), and 71.73(c)(4).
Criticality Evaluation C6-1. Clarify the maximum uranium mass limits for air transportation of 1S and 2S cylinders within the VP-55 transport container.
The uranium mass limits for transport of fissile material that is provided in Section 6.7.2 of the application appear to be inconsistent with the quantities that are indicated to be allowed in 1S and 2S cylinders. The maximum quantity of 100 wt% U-235 as shown in Table 6.1-3 of the application indicates that the total quantities of U-235 per VP-55 allowed for air transport are well above the minimum spherical critical masses for 100 wt% U-235 reported in LA-10860-MS, Critical Dimensions of Systems Containing U-235, Pu-239, and U-233, as well as the limits reported for optimally moderated H/X UO2F2 systems in ORNL/TM-12292, Estimated Critical Conditions for UO2F2-H2O Systems in Fully Water-Reflected Spherical Geometry. The discussion in Section 6.7 of the application has a much lower mass limit (i.e., 395 grams U-235 at 100 wt%) than either of the 1S and 2S configurations, and appear to exceed the 5-inch pipe U-235 mass limits for air transportation that is specified in Section 6.7.2.
This information is needed to determine compliance with 10 CFR 71.55(f).
Structural Evaluation S2-1. Describe the yield strength and ductility (grade) of carbon steel used to construct the 55-gallon drum, drum lid, 5/8-inch-11 hex head bolt, backing bar, and the drum ring, and the drum lid reinforcing ring.
The licensing drawings (VP-55-LD) specify that the drum (BOM 9), the drum ring (BOM 11), 5/8-inch-11 hex head bolt, and drum lid (BOM 26) are only identified as being made from carbon steel, while the drum reinforcing ring (BOM 11) and backing bar (BOM 6) are made of an unspecified grade of ASTM A1011. While the 55-gallon Versa-Pac was drop tested, it is unclear what the yield strength and ductility of the steel used to construct these components was made of. Without specified yield strength & ductility (material grade), it is unclear how another package will perform during HAC drop test conditions due to the ambiguity of the materials yield strength and ductility. The aforementioned components used in the construction of the new 55-gallon Versa-Pac drum package would have to meet or exceed the yield strength and/or ductility of those components used during drop testing.
Staff is concerned that components made from material with unspecified yield strength and ductility (parameters that determine energy absorption) may fail during the 9 meter drop test and expose the contents such as the inner container and the 5-inch pipe that carries 1S or 2S cylinders directly to subsequent thermal test (a scenario that appears to not have been considered in Chapter 3 of the application) if left unspecified. Specify the minimum yield strength and ductility (grade) of the carbon steel used to construct these components and place this information in the safety analysis report and licensing drawings.
This information is needed to determine compliance with 10 CFR 71.33(a)(5) and 10 CFR 71.73(c)(1), 10 CFR 71.73(c)(3), and 10 CFR 71.73(c)(4).
S2-2. Clarify the performance of the 55-gallon Versa-Pac package with respect to the puncture test and subsequent thermal test when the drum ring is struck directly for HAC conditions.
With reference to drawing (VP-55-LD sheet 1 of 2), describe the performance of the package when the package (lid side up) is dropped at a slight angle relative to the long axis of the package such that the puncture bar strikes (snags) the drum ring (BOM 11) and 5/8-inch-11 hex head bolt (BOM 26) potentially forcing the drum lid (BOM 10) to tear away from the drum portion of the package as depicted below:
Figure 1: Drawing in Reference to VP-55-LD (Appendix 1.4.1: Versa-Pac Shipping Package Licensing Drawings, sheet 1 of 2)
Staff is concerned that the package may be subjected to the free drop test, followed by the puncture test (forcing the lid to come off the package) in which case the contents such as the inner container and the 5-inch pipe that carries 1S or 2S cylinders directly to subsequent thermal test for which it appears that the package has not been examined.
This information is needed to determine compliance with 10 CFR 71.73(c)(1),
10 CFR 71.73(c)(3), and 10 CFR 71.73(c)(4).
S2-3. Clarify the performance of the 55-gallon Versa-Pac package with respect to shallow angle drops for normal conditions of transport (NCT) and hypothetical accident conditions (HAC) conditions and the 1 meter puncture drop.
Appendix 2.13.4 (referenced in Section 2.13 of the application) indicates that the package was drop tested for shallow angles and for the 1 meter puncture tested at a weight of 644.5 lbs. for Revision 9 of the application. However, the package now weighs 750 lbs. and it is unclear how the package will perform at this weigh (Revision 10).
Describe the condition of the package for shallow angle drops for NCT and HAC conditions and the 1 meter puncture drop as described in Appendix 2.13.4 given that the package can now weigh 100 lbs. more than previously tested. Further details regarding shallow angle drops on barrel type packages can be found in NUREG/CR-6818.
This information is needed to determine compliance with 10 CFR 71.71(c)(7),
10 CFR 71.73(c)(1), and 10 CFR 71.73(c)(3).
S2-4. Justify how the champion package is representative of the 55-gallon Versa-Pac package.
In Section 2.7.6 of the application, the applicant states that the champion package was used to bound the 55-gallon Versa-Pac with respect to water immersion. However, it is unclear how the construction of the champion package is similar to the 55-gallon Versa-Pac package. Clarify how the materials, dimensions, configuration etc., is similar enough to that of the 55-gallon Versa-Pac package.
This information is needed to determine compliance with 10 CFR 71.73(c)(6).
Thermal Evaluation T1-1. Address the pressurization of the UF6 cylinders, as well as the ability of the 5-inch pipe and overpack to withstand any release of pressurization of the UF6 cylinders under hypothetical accident conditions, specifically considering air transport where the thermal test in 10 CFR 71.73(c)(4) must be 60 minutes rather than 30 minutes.
The pressurization of the UF6 cylinders, as well as the ability of the overpack and 5-inch pipe to withstand any release of pressurization of the UF6 cylinders considering the potential chemical, galvanic, or other reaction among the packaging components, among package contents, or between the packaging components and the package contents, including possible reaction resulting from inleakage of water has not been addressed.
For example, generation of HF gas during the air transport 60 minute thermal test has not been addressed. Depending on the integrity of the overpack and 5-inch pipe, pressurization may result in release of UF6 vapor and HF gas (in the presence of water),
and high velocity projectiles from the UF6 cylinders, 5-inch pipe, or overpack. It is noted that because of the heat capacity of the UF6, a partially filled cylinder may be more susceptible to hydraulic failure than a full cylinder.
This information is needed to determine compliance with 10 CFR 71.43(d) and 71.55(f)(1)(iv).
T3-1. Confirm whether the package will be shipped by exclusive or non-exclusive use. If the package is shipped by non-exclusive use, clarify Chapter 3 of the application to describe that the maximum accessible surface temperature meets the non-exclusive use temperature limit, and Chapter 7 of the application to describe that the package is shipped by non-exclusive use.
In Chapter 3 (page 3-3) and application Section 3.3.1.1 the applicant states that the NCT evaluation results meet the exclusive use shipment requirement of 10 CFR 71.43(g).
However, the applicant does not indicate the package is being shipped by exclusive use anywhere else in the application, or in the last revision of the Certificate of Compliance.
The applicant should update application Chapter 7 to state that package is being shipped by non-exclusive use. Additionally, if the package is being transported by non-exclusive use, Chapter 3 (page 3-3) and application Section 3.3.1.1 should be clarified to describe that the package meets the non-exclusive use shipment requirements of 10 CFR 71.43(g).
This information is needed to determine compliance with 10 CFR 71.43(g).