ML19098A931
| ML19098A931 | |
| Person / Time | |
|---|---|
| Site: | 07109297 |
| Issue date: | 03/26/2019 |
| From: | Sloma-Delosier T Westinghouse |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML19098A930 | List: |
| References | |
| LTR-LCPT-19-01 | |
| Download: ML19098A931 (10) | |
Text
Westinghouse Non-Proprietary Class 3
© 2019 Westinghouse Electric Company LLC All Rights Reserved ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Direct tel: +1.301.931.5301 Direct fax: +1.803.695.4164 e-mail: sloma1t@westinghouse.com Your ref: Docket No. 71-9297 Our ref: LTR-LCPT-19-01 March 26, 2019
Subject:
Application Request for Renewal of Certificate of Compliance USA/9297/AF-96 for Model No.
Traveller STD, XL, and VVER
References:
(1) Docket 71-9297 (2) Certificate of Compliance USA/9297/AF-96, Rev. 10
Dear Director,
In accordance with 10 CFR 71.38, Westinghouse Electric Company LLC hereby requests renewal of the Nuclear Regulatory Commissions (NRC) Certificate of Compliance (CoC) USA/9297/AF-96, Revision 10, which expires 31 March 2020 (Reference 2).
Request Westinghouse requests a five-year renewal of the license USA/9297/AF-96 for Model No. Traveller STD, XL, and VVER, as soon as reasonably achievable. We request this submission take priority over our other ongoing application request for approval of USA/9380/B(U)F-96. The timing of this renewal request is to allow competent authorities greater than six months to review the renewal license prior to the March 2020 expiration. If possible, Westinghouse requests a one-year extension of validity for CoC Rev.
10 from the issuance of the new certificate revision.
This renewal request includes all revisions consolidated into the Safety Analysis Report (SAR) Revision
- 14. The SAR Revision 14 changes provide clarifications and editorial corrections. However, these revisions did not result in a change of the packaging design or contents as described in the CoC, Rev. 10 (Reference 2) and there are no changes to any technical analysis.
Finally, it is requested that this application be reviewed for the Joint United States - Canada process for package approval and validation, in accordance with NUREG 1886. The current Canadian endorsement for the Traveller packagings is CDN/E216/-96.
=
Background===
Based on requests for additional information (RAI) from competent authorities and clarifications of existing analyses and operating procedures, SAR Revision 14 was revised as necessary. Revisions were made in Sections 1, 6, 7, and 8 of the SAR Revision 14. The revisions in Sections 1, 7, and 8 were minor Westinghouse Electric Company Nuclear Fuel Columbia Fuel Fabrication Facility 5801 Bluff Road Hopkins, South Carolina 29061 USA
Page 2 of 10 Our ref: LTR-LCPT-19-01 March 26, 2019 in nature, consisting of clarifications to the existing text. To assist in a timely review, each change page for SAR Revision 14 is detailed in Appendix A of this letter and summarized below.
Additionally, some information relating to the BORAL poison plates that had been previously redacted in the submittal of the SAR Revision 13 was missed and therefore is now redacted throughout Revision 14 of the SAR. Westinghouse seeks to keep the details of the BORAL material proprietary for commercial concerns moving forward with SAR Revision 14, as documented in LTR-LCPT-19-02 and affidavit AW-19-4868 (Enclosure 3). Note the SAR page revision number is not updated for the new redaction marking. Redaction page additions are detailed in Appendix A of this letter.
SAR Revision All previous requests are consolidated into the SAR Revision 14. The page changes for the renewal are marked as Revision 14, dated February 2019 with the revised portion of pages marked using a change bar consisting of a vertical line drawn in the right margin. General changes are noted in the SARs Record of Revisions and List of Affected Pages. The revised SAR Revision 14 is provided as Proprietary and Non-Proprietary Enclosure 2. To assist in a timely review, detailed SAR Revision 14 page changes are identified in Appendix A of this letter.
Non-technical changes addressed in Chapters 1, 6, 7, and 8 of the SAR Revision 14 are either added for clarification of existing analyses or simple text revisions, including nomenclature of components and identifying the Westinghouse QA program. Additional grammatical changes are made in Chapter 1. The revisions in Sections 1, 7, and 8 are minor in nature, consisting of clarifications to the existing text.
In Revision 13 of the SAR Section 6, the PWR fuel assembly HAC single package criticality analyses credited higher masses of polyethylene packing materials than the 2 kg polyethylene packing material limit of CoC Sections 5.(b)(1)(vi), 5.(b)(2)(vi), and 5.(b)(3)(vi) (Reference 2) for all three PWR Groups.
The SAR Revision 14 has been revised to credit the 2 kg polyethylene packing material limit for the PWR fuel assembly HAC single package analyses. This resulted in a reduction in Maximum keff for all the PWR Groups 1, 2 and 3 HAC single package analyses. The results of the single package analysis in SAR Revision 14 remain acceptable below the upper subcritical limit (USL). These revisions did not result in a change of the any technical analysis or the license, just apply consistency of the penalty assessed for the 2 kg polyethylene packing material limit for all PWR Group safety cases. Further revision discussion and impacted SAR Revision 14 page changes are provided in Appendix A of this letter.
Certificate Revision Section 5 and Section 6 (requirements of Subpart G of 10 CFR Part 71) of the CoC Revision 10 remain applicable to all Traveller family packagings.
Westinghouse has a quality assurance program, approved by the Commission, that satisfies the provisions of Subpart H (Quality Assurance) of Part 71. Further, Westinghouse complies with the terms and conditions of the applicable requirements of Subparts A (General Provisions), G (Operating Controls and Procedures), and H (Quality Assurance) of Part 71.
One copy of the renewal application is submitted electronically via NRC Electronic Information Exchange (EIE) system and emailed to the prior Project Manager, Pierre Saverot. Additional electronic or hard copy submissions are available upon request. Should you have any questions, or require additional information, please contact me either by telephone at (301) 931-5301 or by email at sloma1t@westinghouse.com, or contact the Engineering & Regulatory Compliance Manager, Wes Stilwell, directly at (803) 647-3438 or by email at stilwewe@ westinghouse.com.
Page 3 of 10 Our ref: LTR-LCPT-19-01 March 26, 2019 Best regards,
- electronically approved Tanya Sloma-DeLosier Licensing, Compliance and Package Technology Nuclear Fuel Transport Westinghouse Electric Company LLC
Enclosures:
Proprietary
Enclosures:
- 1. LCPT-19-01-P Attachment Application for Certificate of Compliance for the Traveller PWR Fuel Shipping Package, NRC Certificate of Compliance USA/9297/AF-96, Docket 71-9297, Safety Analysis Report Revision 14, (dated February 2019, Proprietary)
Non-Proprietary
Enclosures:
- 2. LCPT-19-01-NP Attachment Application for Certificate of Compliance for the Traveller PWR Fuel Shipping Package, NRC Certificate of Compliance USA/9297/AF-96, Docket 71-9297, Safety Analysis Report Revision 14, (dated February 2019, Non-Proprietary)
- 3. LTR-LCPT-19-02 / AW-19-4868 Submittal of LTR-LCPT-19-01, Application Request for Renewal of Certificate of Compliance USA/9297/AF-96 for Model No. Traveller STD, XL, and VVER (Proprietary/Non-Proprietary),
March 12, 2019 cc w/o enclosures:
W. Stilwell, Westinghouse-USA T. Grange, Westinghouse-UK P. Lindgren, Westinghouse-Sweden P. Saverot, NRC
- Electronically approved records are authenticated in the Electronic Document Management System.
Page 4 of 10 Our ref: LTR-LCPT-19-01 Appendix A March 26, 2019 Appendix A - List of SAR Revision 14 Changes Revisions to the SAR include the following:
- 1. Section 1 changes:
o Throughout (these changes are not marked by change bars)
Switched order of all Imperial/metric units so that Imperial units are listed first and metric units are in parentheses 10CFR71 changed to 10 CFR 71 Strong back of Clamshell changed to base for consistency For any instances where a numeric digit appears in the text, e.g. 9, the text was changed to read nine (9)
All mentions of fuel Rod Pipe corrected to Rod Pipe o Section 1.1 Added the names of the three Traveller variants to the first paragraph.
2nd para.: clarified groups as PWR groups Added fourth paragraph detailing the Travellers procurement under an approved WEC QA program o Sections 1.2.1.1.1 and 1.2.1.1.2 Clarified fuel as fuel assemblies o Section 1.2.1.2 1st para., 1st sent.: Corrected SSR-6 title to say, Specific Safety Requirements and not Safety Standard Series 1st para., 2nd sent.: clarified that the containment system for the Traveller is the zirconium alloy clad and end plugs of the fuel rods.
Added second paragraph describing the assembly and inspection of the fuel rod tubes.
o Section 1.2.1.3 Added a sentence that personnel barriers are not necessary due to insignificant decay heat of the contents o Section 1.2.1.4 Corrected the description of the BORAL plates from each axial side to each lateral side Removed the BORAL minimum areal density from this section o Section 1.2.1.5.1 End of 2nd para.: corrected Travellers to Traveller 4th para., 4th sent.: corrected routine transport to transport 4th para., 5th sent.: changed provides a seal to mitigate rain and water spray to is used to mitigate water and debris o Section 1.2.1.5.2 1st paragraph: Clarified Clamshell main doors o Section 1.2.1.5.3 1st para.: corrected a multi-point cammed latch closure mechanism to multi-point cammed latch closure mechanisms 2nd para.: added Clamshell base 5th para.: deleted the following to clarify the axial restraint may be used for any configuration to ensure a tight axial fit and is not specific to the Traveller XL. The
Page 5 of 10 Our ref: LTR-LCPT-19-01 Appendix A March 26, 2019 Traveller XL Clamshell is both larger in cross-sectional dimension and in length than the Traveller STD Clamshell so that the XL Clamshell can accommodate larger fuel assemblies. The longer length may be adapted for shorter fuel assembly designs that are normally shipped in the Traveller STD. Added Some fuel assemblies require an axial or lateral spacer to ensure proper axial fit into the Clamshell. The Clamshell is adapted axially for shorter fuel assemblies.
o Section 1.2.1.5.4 Corrected latch closure mechanism to plural instead of singular Added lateral to describe the absorber plate locations 4th para., 2nd sent.: Added description of clamping plate locking devices o Section 1.2.1.5.5 1st para., 1st sent.: changed loose rods to loose fuel rods 2nd para., 1st sent.: corrected to positive restraining devices 2nd para., 5th sent.: corrected removal to removable o Section 1.2.2.1 2nd para., 3rd sent.: corrected actual to physical number of fuel rods o Section 1.2.2.1.1 2nd para.: added The rods are pressurized with helium and end plugs are welded to the rod, which effectively seals and contains the radioactive material.
3rd para.: clarified that non-destructive methods are used. Deleted X-ray inspection and added radiographic. Added As the containment boundary is welded closed, it cannot be opened unintentionally.
o Section 1.2.2.1.2 Clarified that grid assemblies are mechanically fastened to the guide thimbles o Section 1.2.2.1.3 2nd para.: clarified that the core component may also function as a flow by-pass 3rd para., 1st and 2nd sent.: added language to clarify the Traveller is not limited to only the neutron poisons listed in this paragraph 3rd para., 4th sent.: added why integral burnable absorbers are not credited in the Section 6 analysis 4th para., 1st sent.: added typically to describe startup neutron sources o Section 1.2.2.2 1st para.: added fuel to describe the UO2 and U3Si2 rods 3rd para.: added reference to Table 1-2 when discussing ASTM C 996 o Section 1.2.3 Clarified that this section is discussing the Traveller Type A package o Section 1.2.4 Clarified that the package must be up-ended for the loading and unloading of contents o Section 1.3.2 Added descriptions for drawing numbers listed
- 2. No changes are made to Sections 2
- 3. No changes are made to Sections 3
- 4. No changes are made to Sections 4
- 5. No changes are made to Sections 5
Page 6 of 10 Our ref: LTR-LCPT-19-01 Appendix A March 26, 2019
- 6. Section 6 changes:
o Section 6.1.2 1st para, 1st sent.: corrected 10CFR71 to 10 CFR 71 1st para., 2nd sent.: changed Type A, fissile packages to Type A, fissile material packages 3rd para., 3rd sent.: clarified when penalties are and are not applied by adding the following text:
Typically, when the total penalty (ku) is less or equal to one-sigma the penalty is not included. In general, when the ku penalty values are insignificant to the total penalty, relative to the effects of the other sensitivity studies analyzed, then the ku is not included. Where the effects from all sensitivity studies are smaller, accounting for very small penalties has a more significant effect on the total penalty, then ku is included.
o Section 6.1.2.1 Updated Maximum keffs in Table 6-2, Summary Table of Criticality Evaluation, for Groups 1 and 2, and Group 3 HAC single package evaluations and referenced tables due to polyethylene packing material penalty discrepancy in Section 6.4.2. In SAR Rev. 13, the penalties taken for polyethylene packing materials for the single package analyses were for masses greater than the 2 kg limit on the package.
For SAR Rev. 14, the penalty taken for polyethylene packing materials is changed to 2 kg for consistency with the limit set on the package, as determined in the HAC package array analyses and for simplicity. Section 6.2.1, Group 1, Section 6.2.2, Group 2, and Section 6.2.3, Group 3, already identify the polyethylene packing material limits to 2.0 kg.
Change Description Old Value New Value Affected text HAC single package Group 1 and 2 poly packing material penalty 8 kg penalty 0.02068 2 kg penalty 0.00284 Table 6-36 highlight change Table 6-27 penalty assessed updated HAC single package Group 3 poly packing material penalty 6 kg penalty 0.02151 2 kg penalty 0.00261 Table 6-36 highlight change Table 6-27 penalty assessed updated HAC single package Group 1 and 2 Total Penalty ku 0.03177 0.01393 Table 6-27 total recalculated Table 6-26 ku updated HAC single package Group 3 Total Penalty ku 0.03411 0.01521 Table 6-27 total recalculated Table 6-26 ku updated HAC single package Group 1 and 2 Maximum keff 0.93484 0.91700 Table 6-26 Maximum keff recalculated Table 6-2 updated HAC single package Group 3 Maximum keff 0.91702 0.89812 Table 6-26 Maximum keff recalculated Table 6-2 updated
Page 7 of 10 Our ref: LTR-LCPT-19-01 Appendix A March 26, 2019 o Section 6.3.4.2.1.3 Add clarification that the expanded lattice results in a water-to-fuel ratio closer to the optimal value than the nominal fuel region o Section 6.3.4.3 Clarified when penalties are and are not applied (same as Section 6.1.2) o Sections 6.4.2, 6.5.2, and 6.6.2 throughout For Groups 1, 2, and 3: changed package variant in results sections to Group. These changes are not marked.
For Rod Pipe: changed package variant in results sections to content. These changes are not marked.
o Section 6.4.2.1 and Section 6.4.2.2.1 Due to the polyethylene packing material penalty update described above, updated Maximum keffs and total penalty ku in Table 6-26, Single Package - Maximum Reactivity Results Summary, for Groups 1 and 2 and Group 3 HAC single package.
See Section 6.1.2.1 for further details.
See change for Section 6.4.2.2.3.
o Section 6.4.2.2.3 Pages 6-50 and 6-51: added statement clarifying that the poly limit is 2.0 kg. Also revised the highlighted poly penalties to 2 kg polyethylene in Table 6-36, Polyethylene Sensitivity Results - Single Package, HAC, Groups 1, 2, and 3.
o Section 6.4.2.2.4.1 Page 6-58: added statement clarifying that there is no poly limit resulting from the rod pipe NCT single package analysis o Section 6.4.2.2.4.2 Page 6-62: clarified that the Clamshell shift is from the centerline, baseline position Page 6-63: added statement clarifying that there is no poly limit resulting from the rod pipe HAC single package analysis o Section 6.5.2.2.4 Page 6-80: clarified that the Clamshell shift is from the centerline, baseline position Page 6-81: corrected Outer Wrap to Uniform Wrap. Uniform wrap is when each rod is encapsulated in polyethylene as described in text.
Table 6 Corrected label Outer Wrap to Uniform Wrap.
o Section 6.6.2.2.2 Page 6-92: clarified that a limit of 2 kg of poly is imposed on Groups 1, 2, and 3 o Section 6.9.3.1.2 Added wording clarifying the modeling of centering the fuel assemblies axially to promote axial reflection and explaining that the variation in axial positioning was statistical in nature.
Page 8 of 10 Our ref: LTR-LCPT-19-01 Appendix A March 26, 2019
- 7. Section 7 changes:
o Throughout (these changes not marked)
Corrected package to package(s) where applicable Corrected axial restraint and axial spacers to axial restraint(s) and axial spacer (as needed) o Section 7.1 Clarified that the package loading operations cover a range of activities o Section 7.1.1 Added reference to applicable information in Section 1 o Section 7.1.1.a Corrected unirradiated definition to unirradiated uranium definition Corrected assembly or fuel to contents or fuel contents, respectively o Section 7.1.1.b Corrected unirradiated definition to unirradiated uranium definition Added reference to applicable information in Section 1 Corrected assembly or fuel to contents or fuel contents, respectively Added U3Si2 in example of uranium isotopes, as it is an approved content Clarified that plutonium and fission products are not allowed in the Traveller Type A packages.
o Section 7.1.1.3 Added 5th bullet Check the Clamshell for any mechanical damage or excessive wear o Section 7.1.1.4 Clarified that there may be more than one axial restraint and that the axial spacer is not always needed (change not marked) o Section 7.1.1.5 Clarified that there may be more than one axial restraint and that the axial spacer is not always needed (change not marked)
Added 3rd bullet to inspect the BORAL neutron absorber plates o Section 7.1.2 Corrected swings bolts to swing bolts 25th bullet added metric torque values o Section 7.1.3.1 Added 1st bullet sub-bullets with restrictions to how many stacked packages may be lifted at the same time 5th bullet added metric values to Imperial units o Section 7.1.3.2 Added 2nd bullet with information for how to conduct radiation surveys o Section 7.2 Clarified the unloading operations cover a range of activities o Section 7.2.1 1st bullet specified that the radiation and contamination surveys should be done for the package(s) and transport vehicle 4th bullet added lifting restrictions for stacked packages o Section 7.2.2 1st bullet clarified that the latch is for the powered Upender 10th bullet clarified to install and latch the plant fuel tool to the fuel assembly/component
Page 9 of 10 Our ref: LTR-LCPT-19-01 Appendix A March 26, 2019 11th and 14th bullets added metric values to Imperial units Last bullet clarified that the latch needs to be disengaged if using a powered Upender.
o Section 7.3 Added specific SSR-6 paragraph references
- 8. Section 8 changes:
o Throughout (these changes are not marked)
Corrected +/- to +/-.
o Section 8.1 Added a reference to SSR-6 and added a statement about the Travellers procurement under an NRC-approved QA program meeting 10 CFR 71 Subpart H.
o Section 8.1.1 Moved statement regarding weld requirements from this paragraph to Section 8.1.2.
2nd sent.: Clarified that the process is a manufacturing process o Section 8.1.2 Changed Traveller to Traveller packaging.
Added non-destructive examination procedures and standards from ASME Code,Section III, Subsection NF-5000.
Added second paragraph with information about the weld examination process.
o Section 8.1.3: changed header to Structural and Pressure Tests to align with Reg Guide 7.9 Added hoist ring test criteria Added that the Traveller packaging is not pressurized and pressure testing is not required o Section 8.1.4: changed header to Leakage Tests to align with Reg Guide 7.9 Removed pressure from statement in this section about leak testing and added statement to Section 8.1.3.
o Section 8.1.5.1 Added polyurethane foam reject criterion o Section 8.1.5.1.4 Added reference to Table 8-3 o Section 8.1.5.1.5 Corrected dimension to dimensions o Section 8.1.5.1.6 1st para., 1st sent.: corrected foam will be to foam is 2nd para., 2nd sent.: corrected leachable chloride standards to be an either (1) or (2) applicability o Section 8.1.5.2 2nd para., last sent.: clarified that There are no significant routine loads applied to the BORAL plates o Section 8.1.5.2.1 2nd para., 3rd sent.: corrected Based on the number of neutron count to Based on the neutron count o Section 8.1.5.2.4 Added reference to Table 8-4.
o Table 8-4 Changed NFD Approved Procedure to WEC Approved Procedure
Page 10 of 10 Our ref: LTR-LCPT-19-01 Appendix A March 26, 2019 o Section 8.1.5.2.6 2nd para., 3rd sent.: corrected inspection criteria from with a 5X glass to by visual inspection per approved procedure(s).
o Section 8.1.5.3 Clarified that the UHMW polyethylene must comply with ASTM D4020 and have a specific gravity greater than 0.93 o Section 8.1.6 Clarified that the Traveller packaging contains no purpose-built shielding components and therefore shielding tests are not required.
o Section 8.1.7 Changed (see Section 3.6.5, Certification Tests) served to verify to (see Section 3.6.5) verified to clarify the fire testing confirms material performance o Section 8.2.1: changed header to Structural and Pressure Tests to align with Reg Guide 7.9 Removed There is also no pressure testing requirement. Added The Traveller packaging is not pressurized. Therefore, no pressure testing of the packaging is required.
o Section 8.2.2: changed header to Leakage Tests to align with Reg Guide 7.9 o Section 8.2.3.2 Changed weather seal to weather gasket as the Traveller does not provide a seal or require pressure testing per Section 8.2.1 o Section 8.2.4 Added that degradation of heat transfer capability wont occur under NCT. Therefore, routine thermal tests arent necessary.
o Section 8.2.5 Deleted etc. in last sentence
- 9. Additional BORAL poison plate property redactions are located in:
o Chapter 1 Licensing drawing 10004E58, Sheet 1 Licensing drawing 10037E43, Sheet 1 o Chapter 2 Table 2-2, page 2-6 Section 2.12.8.1, page 2-222 o Chapter 6 Section 6.1.1.2, page 6-1 Table 6-10, page 6-12 Section 6.3.2.11.1, page 6-17 o Chapter 8 Sections 8.1.5.2.1 and 8.1.5.2.3, page 8-6