ML19024A169
| ML19024A169 | |
| Person / Time | |
|---|---|
| Site: | 07109233 |
| Issue date: | 01/23/2019 |
| From: | Edwards W Orano USA, TN Americas LLC |
| To: | William Allen Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML19024A167 | List: |
| References | |
| E-53386 | |
| Download: ML19024A169 (4) | |
Text
Columbia Office 7135 Minstrel Way Columbia, MD 21045 Tel: (410) 910-6900
@Orano_USA Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.
January 23, 2019 E-53386 U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852
Subject:
Supplement to Application for Revision 17 to Certificate of Compliance No. 9233 for the Model No. TN-RAM, Docket No. 71-9233
References:
[1] Document E-53202, Application for Revision 17 to Certificate of Compliance No. 9233 for the Model No. TN-RAM, Docket No. 71-9233.
[2] Wood Handbook, Wood as an Engineering Material. Forest Products Laboratory, Forest Service, U.S. Department of Agriculture, General Technical Report FPL-GTR-190, April 2010.
https://www.fpl.fs.fed.us/documnts/fplgtr/fpl_gtr190.pdf
[3] Von Riessman, W.A. and Guiss, T.R. The Effects of Temperature on the Energy-Absorbing Characteristics of Redwood, Sandia Laboratories SAND77-1589, August 1978.
[4] Knoell, A. C., Environmental and Physical Effects on the Response of Balsa Wood in an Energy Dissipation, Jet Propulsion Laboratory, Technical Report No.32-944, June 15, 1966.
[5] Gerhards, C. C., Effect of Moisture Content and Temperature on the Mechanical Properties of Wood: An Analysis of the Immediate Effects, Forest Products Laboratory, Forest Service, U.S. Department of Agriculture, November 1980.
[6] Document E-10621, Safety Analysis Report for the TN-RAM, Revision 17.
[7] Revision 16 to Certificate of Compliance No. 9233 for the Model No. TN-RAM, 2017.
January 23, 2019 E-53386 Page 2 of 4
Dear Mr. Allen:
In accordance with 10 CFR 71.31(b), TN Americas LLC submits a supplement to an application for revision to Certificate of Compliance (CoC) No. 9233 for the Model No. TN-RAM [1]. These changes are self-identified by the applicant as discussed during a phone call on January 18, 2019.
There are two packaging design changes in this application:
- 1) Material specification change for item 19 on SAR drawing 990-708, FUSIBLE PLUG, This change allows the option to use nylon 6 or 6,6 or RILSAN BMN G8 that is already approved for the impact limiters fusible plugs. This change is being requested to allow more flexibility for the fabrication of the fusible plugs.
This change has no impact on the performance of the TN-RAM cask and its impact limiters.
The purpose of this fusible plug is to melt during a fire event, which prevents pressure build-up within the impact limiter shell. Using a material with a melting temperature below approximately 300 °C meets the intent of this design feature. The melting temperature of RILSAN BMN G8 material is in the 186 °C range. The most common nylon types are Nylon 6 (PA6) and Nylon 6,6 (PA66). Typical melting temperatures for these materials is in the 210-270 °C range, which is slightly higher than RILSAN, but still low enough to fulfill the design intent.
- 2) Moisture content specification change for the impact limiter wood material The crush stress properties (average compressive strength and locking strain) and moisture content are critical characteristics that are measured using standard methods required by the procurement specification. Acceptance tests are done at ambient conditions for temperature on samples taken from wood that has been conditioned for moisture content.
The crush stress properties depend on moisture content of the wood and temperature. The crush stress properties and moisture content (oven dry) must be within the range specified in the licensing documents.
The TN-RAM SAR Appendix 2.10.2 describes a range for compressive strength that covers the expected values for the density, moisture content, and temperature range of interest, -20 °F to 165 °F. The SAR and procurement specification specifies a range for maximum moisture content as 10-12% for balsa wood and 12-15% for redwood. A minimum moisture content of 6% and maximum of 12% for both redwood and balsa wood provides a range that is consistent with the range of moisture expected for conditioned wood as reported in the USDA FPL Wood Handbook [2]. This range of moisture is also consistent with the 6% to 10% moisture content range specified for MP197HB and TN-LC impact limiter wood that has similar ranges specified for compressive strength.
January 23, 2019 E-53386 Page 3 of 4 The TN-RAM method for evaluating the energy absorption in the impact limiters considers the range of compressive strength specified in the SAR as 1560-201 O psi for balsa wood and 5000-6500 psi for redwood. The specified range of compressive strength is generally consistent with USDA FPL Wood Handbook and other source [References 3, 4, and 5]
reports on the effects of moisture and temperature on compressive strength referenced to values of moisture content in the range from 6% to 12% and in the temperature range of interest, -20 °F to 165 °F.
This submittal contains the following enclosures:
- provides a copy of the TN-RAM SAR Revision 18 for the SAR Cover Page, Revision Log (changed pages only), Chapter 1 (changed pages only), Drawing 990-708, Revision 12. This enclosure is proprietary.
- provides a public version of Enclosure 1. This enclosure does not include Drawing 990-708, Revision 12, as it contains security related information. The drawing is being withheld from public disclosure in accordance with RIS 2005-31.
- provides an affidavit, as discussed further below.
The changed areas in the SAR [6] are marked as follows:
New or changed pages show "Revision 18" in the header.
Changed areas are indicated using revision bars in the right-hand margin. Newly inserted or changed text is shown by italics.
Certain portions of this submittal include proprietary information, which may not be used for any purpose other than to support the NRG staff's review of the application. In accordance with 1 O CFR 2.390, TN Americas LLC is providing an affidavit (Enclosure 3) specifically requesting that this proprietary information be withheld from public disclosure. The submittal also includes security-related information.
TN Americas LLC respectfully requests that Revision 17 to the Certificate of Compliance No.
9233 for the Model No. TN-RAM [7] be issued on or about February 15, 2019 to support the use of the impact limiters for TN-RAM Number 2 for shipments planned in March 2019.
Should NRG staff have any questions or require additional information regarding this submittal, please do not hesitate to contact Mr. Peter Vescovi at 336 420-8325.
Sincerely, W. Scott Edwards Director of Transportation
January 23, 2019 E-53386 Page 4 of 4
Enclosures:
- 1. TN-RAM SAR Revision 18 Changed Pages (Proprietary)
- 2. TN-RAM SAR Revision 18 Changed Pages (Public Version)
- 3. Affidavit Pursuant to 10 CFR 2.390 cc: William Allen, U.S. Nuclear Regulatory Commission One copy of this letter and Enclosures 1, 2, and 3