ML18360A572
| ML18360A572 | |
| Person / Time | |
|---|---|
| Site: | 07109379 |
| Issue date: | 12/21/2018 |
| From: | Garcia-Santos N Spent Fuel Licensing Branch |
| To: | Noss P Orano Federal Services |
| Garcia-Santos N | |
| References | |
| EPID L-2018-NEW-0002 | |
| Download: ML18360A572 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 21, 2018 Mr. Philip W. Noss Licensing Manager Orano Federal Services LLC 505 S. 336th St., Suite 400 Federal Way, WA 98003
SUBJECT:
APPLICATION FOR THE MODEL NO. 1105-SD TRANSPORT PACKAGE -
SUPPLEMENTAL INFORMATION NEEDED
Dear Mr. Noss:
By letter dated July 19, 2018 [Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML18215A243], Orano Federal Services LLC (the applicant) submitted an application to the United States (U.S.) Nuclear Regulatory Commission (NRC) for a new certificate of compliance (CoC) corresponding to the Model No. 1105-SD transport package.
The NRC staff performed an acceptance review of your application to determine whether the application contains sufficient technical information in scope and depth to allow the NRC staff to complete a detailed technical review. This letter is to advise you that based on our acceptance review, the application does not contain sufficient technical information. The additional information needed to begin our review is described in the enclosed document containing the request for supplemental information (RSI) and observations. You may or may not choose to respond to the observation at this time. However, an observation may be issued as an RAI later during the review of the application.
In order to start our technical review, this information should be provided within 2 weeks from the date of this letter. Upon receiving the RSI responses, the NRC staff will evaluate the information to determine and inform you whether the supplementary information is sufficient for the NRC staff to proceed with its formal review of the application.
The staff is available for a public meeting if you wish to discuss these issues in more detail prior to deciding on your course of action. Please reference Docket No. 71-9379 and EPID L-2018-NEW-0002 in future correspondence related to this action.
If you have any questions regarding these matters, please contact me at (301) 415-6999.
Sincerely,
/RA/
Norma Garcia Santos, Project Manager Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-9379 EPID L-2018-NEW-0002
Enclosure:
Request for Supplemental Information
SUBJECT:
APPLICATION FOR THE MODEL NO. 1105-SD TRANSPORT PACKAGE -
SUPPLEMENTAL INFORMATION NEEDED, DATE: December 21, 2018 DISTRIBUTION: SFST r/f NMSS r/f http://fusion.nrc.gov/nmss/team/sfst/sfst-licensing/10_cfr_71/1105-SD/Shared Documents/1105-SD_RSI.doc ADAMS P8 Accession No.: ML18360A572 OFFICE:
DSFM DSFM DSFM DSFM DSFM DSFM DSFM NAME:
NGarcía Santos SFigueroa by email JPiotter by email JIreland by email HLindsay In Sharepoint TAhn by email WAllen by email DATE:
11/9/18 11/30/18 11/28/18 11/16/18 11/19/18 11/19/18 11/16/18 OFFICE:
DSFM DSFM DSFM DSFM DSFM DSFM DSFM NAME:
DForsyth by email ELove by email PSilva by email CBajwa by email MRahimi by email DChung for TTate JMcKirgan DATE:
11/28/18 11/16/18 12/19/18 11/20/18 11/30/18 12/20/18 OFFICIAL RECORD COPY
Enclosure Request for Supplemental Information and Observation Orano Federal Services LLC Docket No. 71-9379 Model No. 1105-SD Package Revision 0 REQUEST FOR SUPPLEMENTAL INFORMATION RSI-1 Provide the following information for the Model No. 1105-SD:
- a.
a list of documents that constitute the licensing basis (e.g., structural evaluation and analyses, thermal evaluation, analysis input and output files, etc.) that are available for staffs review. For each document, or group of analysis files, include the following information, as applicable:
- i.
applicable discipline(s),
ii.
identification number, iii.
title (or file name),
iv.
revision number,
- v.
date last modified, vi.
brief description of documents content, and vii.
Agencywide Documents Accession and Management System (ADAMS) Accession numbers (Nos.) (for documents submitted as part of the Docket for the Model No. 435-B and applicable to the Model No. 1105-SD).
- b.
A description of the quality assurance program (QAP) applicable to the Model No. 1105-SD. Include this information in the safety analysis report.
The applicant submitted the Safety Analysis Report (SAR) as the application of the Model No. 1105-SD, Revision 0. In its submittal, the applicant stated the following:
The 1105-SD package is to be understood as the commercial version of the NNSA' s 435-B package. The 1105-SD package is identical to the 435-B package defined by the 435-B SAR, Revision 4.3, NRC Docket 71-9355. Revision 4.3 of the 435-B SAR corresponds to NRC Certificate of Compliance USA/9355/B(U)-96, Revision 2. The 1105-SD SAR, Revision 0 was created by making only the changes to the 435-B SAR, Revision 4.3, which were necessary to change its identity and to update some references.
The applicant noted the differences between the Model No. 1105-SD and Model No. 435-B SARs in attachment A to its submittal. The certificate of compliance (CoC), Revision 2, for the Model No. 435-B was approved by the NRC on January 26, 2018 (ADAMS Package Accession No. ML18026A874).
Based on the applicants submittal, the staff assumed that the documents that would constitute the licensing basis for Revision 0 of the certificate of compliance (CoC) Model No. 1105-SD are the same documents as for Revision 2 of the CoC for the Model No. 435-B, Revision 2. The 10 CFR Part 71 regulation requires that:
- 1.
an application includes a description and evaluation of the package and a description or reference of the applicable QAP, and
- 2.
the applicant establishes design control measures to ensure the adequacy of the design.
The staff is requesting the applicant to provide the information requested in this RSI in order to have reasonable assurance that the future certificate holder has control over the design and quality of the package in order to ensure the adequacy of the design.
This information is needed to determine compliance with the requirements in 10 CFR 71.31(a) and (c) and 71.35(a).
OBSERVATION Containment Evaluation OBS-Co-1 Provide the following descriptions in the Model No. 1105-SD safety analysis report (SAR):
- a.
standards used to certify personnel that develops and approves written leakage rate testing procedures;
- b.
qualifications of personnel that develops and approves written leakage rate testing procedures;
- c.
standards used to certify personnel that performs leakage rate testing; and
- d.
qualifications of personnel that performs leakage rate testing.
Sections 7.4, 8.1.4, and 8.2.2 of the Model No. 1105-SD application includes a description of leakage rate testing procedures. In these sections, the staff noted that the applicant does not mention the following regarding nondestructive testing (NDT) personnel:
- 1.
if only personnel certified as an ASNT Level III examiner for leakage testing shall develop and approve written leakage rate testing procedures, and;
- 2.
if personnel performing leakage rate testing shall be qualified and certified in accordance with Recommended Practice No. SNT-TC-1A, Personnel Qualification and Certification in Nondestructive Testing.
Please specify whether the written leakage rate testing procedures are developed, approved, and performed by qualified and certified NDT personnel for leakage testing in accordance with industry standards to ensure that the package is designed, constructed, and prepared for shipment to comply with the requirements in 10 CFR Part 71.
This information is needed to determine compliance with the requirements in 10 CFR 71.31(c), 71.51(a)(1), and 71.51(a)(2).