ML19232A159
| ML19232A159 | |
| Person / Time | |
|---|---|
| Site: | 07103092 |
| Issue date: | 08/12/2019 |
| From: | Vescovi P TN Americas LLC |
| To: | Conroy M, Garcia-Santos N Spent Fuel Licensing Branch, US Dept of Transportation, Pipeline & Hazardous Materials Safety Admin |
| Garcia-Santos N | |
| Shared Package | |
| ML19232A156 | List: |
| References | |
| Download: ML19232A159 (9) | |
Text
From:
VESCOVI Peter (ORANO)
To:
Garcia Santos, Norma; Conroy, Michael (PHMSA)
Subject:
[External_Sender] RE: Fwd: RE: Need Clarification on redactions-TNF-XI--Due Today Date:
Monday, August 12, 2019 10:39:46 AM
- Norma, Just issue the SER with the editorial corrections. TNI agrees to this.
Peter Sent from Workspace ONE Boxer On Aug 12, 2019 10:18 AM, "Garcia Santos, Norma" <Norma.GarciaSantos@nrc.gov> wrote:
Security Notice: Please be aware that this email was sent by an external sender.
Good morning, I just want to clarify that there were a few items that I could not identify as publicly available. I just need to confirm that you do not want to redact anything from the document that I sent you.
Thanks in advance, Norma From: VESCOVI Peter (ORANO) <peter.vescovi@orano.group>
Sent: Monday, August 12, 2019 9:38 AM To: Garcia Santos, Norma <Norma.GarciaSantos@nrc.gov>; Conroy, Michael (PHMSA)
<Michael.Conroy@dot.gov>
Subject:
[External_Sender] Fwd: RE: Need Clarification on redactions-TNF-XI--Due Today
- Norma, Please ignore redactions and just make editorial corrections. In future, it seems we will need to provide more clearly the proprietary information in the French approval certificates Peter Sent from Workspace ONE Boxer
Forwarded message ----------
From: "MATEO Emmanuelle (ORN-NPS)" <emmanuelle.mateo@areva.com>
Date: Aug 12, 2019 9:20 AM
Subject:
RE: Need Clarification on redactions-TNF-XI--Due Today To: "VESCOVI Peter (ORN-NPS)" <peter.vescovi@areva.com>,"LABBE Laurence (ORN-NPS)"
<laurence.labbe@areva.com>,"LATOUR Brigitte (ORN-NPS)" <brigitte.latour@areva.com>
Cc:
Hello Peter, I propose to forget our comments on redacting information given that all this information is already publicly available.
INTERNAL PURPOSE ONLY:
Next time, I think that TNA and TNI should clarify which info is proprietary before the NRC concurrence process. In France only the first page of the French Certificate is public. Technical appendices, safety report, technical clarifications etc. are proprietary information.
- Regards, Emmanuelle De: VESCOVI Peter (ORN-NPS)
Envoyé: vendredi 9 août 2019 21:17
- LABBE Laurence (ORN-NPS) <laurence.labbe@areva.com>; MATEO Emmanuelle (ORN-NPS)
<emmanuelle.mateo@areva.com>; LATOUR Brigitte (ORN-NPS) <brigitte.latour@areva.com>
Objet: Fwd: Need Clarification on redactions-TNF-XI--Due Today
- Emmanuel, Please see question about redacting information that is already av as liable to public in French approval certificate.
Peter Sent from Workspace ONE Boxer
Forwarded message ----------
From: "Garcia Santos, Norma" <Norma.GarciaSantos@nrc.gov>
Date: Aug 9, 2019 1:38 PM
Subject:
Need Clarification on redactions-TNF-XI--Due Today To: "VESCOVI Peter (ORN-NPS)" <peter.vescovi@areva.com>,"Conroy, Michael (PHMSA)"
<Michael.Conroy@dot.gov>,"LABBE Laurence (ORN-NPS)" <laurence.labbe@areva.com>
Cc: "McKirgan, John" <John.McKirgan@nrc.gov>
Security Notice: Please be aware that this email was sent by an external sender.
Good afternoon, Thanks for the quick response. About the editorial corrections:
- a. The units marked in green should be ft. and not m.
- b. In terms of Document No. DOE-06-00370218-004, please provide the editorial correction. Is the correct Document No. DOS-06-00037028-004? Please confirm. I am not able to see the comments in the document.
I review the document that you provided with the mark ups. There are multiple occasions in which the applicant suggests redacting information that was submitted without an affidavit and it is currently publicly available [In order to facilitate the review process, I am attaching the documents (as in our documents management system) that I am referencing in the clarification questions below]. Therefore, I need clarification about the following proposed redactions to the document:
- 1. Clarify why the enrichment percent of the content needs to be redacted, since it is in the French Certificate, which is a publicly available document. No affidavit was submitted to withhold the French Certificate from public disclosure.
- 2. Section 1.1.2 of the SER - Clarify why the items listed from (1) to (4) in Section 1.1.2 of the SER need to be redacted, since this information is in the French Certificate, which is a publicly available document. No affidavit was submitted to withhold the French Certificate from public disclosure.
- 3. Section 1.1.2 of the SER - Clarify why the items listed from (1) to (2) in Section 1.1.2 of the SER need to be redacted, since it is and response for supplemental information (ADAMS Accession No. ML19071A147, dated February 21, 2019), which is a publicly available document. No affidavit was submitted to withhold this response from public disclosure.
- 4. Section 2.3.1 of the SER-Clarify why the acceleration rate assumed in the LS-DYNA model need to be redacted, since it is in a response to staffs questions (ADAMS Accession No. ML19211B871, dated July 1st), which is a publicly available document.
No affidavit was submitted to withhold this part of the response from public disclosure.
- 5. Section 3.1 of the SER -The temperature range for normal conditions and accident conditions can be redacted, since I was not able to locate these values in the response that the applicant provided. However, clarify why the temperature limit related to Content No. 8 in the French Certificate needs to be redacted. The French Certificate is a publicly available document. No affidavit was submitted to withhold the French
Certificate from public disclosure.
- 6. Section 3.2.1 of the SER - Clarify why the temperature limit related to Content No. 8 in the French Certificate needs to be redacted. The French Certificate is a publicly available document. No affidavit was submitted to withhold the French Certificate from public disclosure.
- 7. Section 3.2.1 of the SER - Clarify why the maximum percent of water in the foam needs to be redacted. The response to staffs questions is a publicly available document (ADAMS Accession No. ML19211B871, dated July 1st). No affidavit was submitted to withhold this part of the response from public disclosure.
- 8. Section 3.2.2.3 of the SER - Clarify why the temperature range for the BORA resin needs to be redacted. The information was provided in a response to staffs questions and is a publicly available document (ADAMS Accession No. ML19211B871, dated July 1st). No affidavit was submitted to withhold this part of the response from public disclosure.
- 9. Section 3.2.2.4 of the SER - Clarify why the upper temperature range for the EPDM needs to be redacted. The information was provided in a response to staffs questions and is a publicly available document (ADAMS Accession No. ML19211B871, dated July 1st). No affidavit was submitted to withhold this part of the response from public disclosure.
- 10. Section 3.2.2.5 of the SER - Clarify why the temperature limit related to Content No. 8 in the French Certificate needs to be redacted. The French Certificate is a publicly available document. No affidavit was submitted to withhold the French Certificate from public disclosure.
- 11. Transmittal letter, Section 3.2.3 of the SER, and Conditions section -
Clarify why the information related to the thermal conductivity and the material need to be redacted. The information was provided in a response to staffs questions and is a publicly available document (ADAMS Accession No. ML19211B871, dated July 1st). No affidavit was submitted to withhold this part of the response from public disclosure.
- 12. Section 3.5 of the SER - Clarify why the information related to the thermal conductivity and the material need to be redacted. The information was provided in a response to staffs questions and is a publicly available document (ADAMS Accession No. ML19211B871, dated July 1st). No affidavit was submitted to withhold this response from public disclosure. (The same comment applies to the transmittal letter.)
- 13. Sections 7.2 and 7.3 of the SER - Except for the density, clarify why the mass and enrichment percent related to Content No. 8 in the French Certificate needs to be redacted. The French Certificate is a publicly available document. No affidavit was submitted to withhold the French Certificate from public disclosure.
- 14. Section 7.3.1 of the SER - Clarify why the entire section needs to be redacted. For example, the staffs evaluation should not be redacted, unless there is justification of proprietary information. However, here is a suggestion:
The bounding parameter analysis assumes a single package with 5.0 kg (11.02 lb.) of 5 wt. % enriched 235U metal at optimum moderation in a spherical shape with the material centered in the bottom of the package cavity. The use of uranium metal bounds all potential content types identified as Content No. 8. The uranium sphere was modeled within the cavity filled with the bounding BeO (beryllium oxide) reflector, with mirrored reflection outside of the model. The applicant performed a parametric study on potential reflectors that may be present in the TNF-XI package, including BeO, Be steel, graphite, lead, concrete water, and aluminum, and demonstrated that beryllium oxide bounds all potential reflectors that may be present within the TNF-XI package. The maximum calculated multiplication factor for the single package was keff + 3 = 0.881.
The applicant also performed an analysis of a single package with 235U metal enriched to 20 wt.% with a mass of 0.5 kg (1.10 lb.), which yielded a lower maximum keff + 3 of 0.759. The reduction in the amount of fissile material at this higher enrichment resulted in a lower keff of the system consistent with the minimum spherical masses of 235U versus enrichment presented in LA-10860-MS, Critical Dimensions of Systems Containing 235U, 239Pu, and 233U, as expected Since the conditions of the models are the same for the package array evaluation due to the full reflection of the model, the applicants analysis bounds both the single package and an infinite array of packages, since full reflection is a very conservative
assumption. The staff finds this assessment to be acceptable, since the package body, lid, and base are stainless-steel, the keff of the single package with the containment system reflected is bounded by the infinite array of packages.
- 15. Section 7.4 of the SER - Clarify why the keff related to Content No. 8 needs to be redacted. The information was provided in a response to staffs questions and is a publicly available document (ADAMS Accession No. ML19211B871, dated July 1st). No affidavit was submitted to withhold this part of the response from public disclosure.
- 16. Section 7.5 of the SER - Clarify why the range of enrichment percent of the content needs to be redacted, since it is in the French Certificate, which is a publicly available document. No affidavit was submitted to withhold the French Certificate from public disclosure.
I will wait for your response. NOTE: If the information is currently publicly available, that information is not redacted from the SER, unless there is a reason that you can articulate.
- Thanks, Norma From: VESCOVI Peter (ORANO) <peter.vescovi@orano.group>
Sent: Friday, August 09, 2019 11:40 AM To: Garcia Santos, Norma <Norma.GarciaSantos@nrc.gov>; Conroy, Michael (PHMSA)
<Michael.Conroy@dot.gov>; LABBE Laurence (ORANO) <laurence.labbe@orano.group>
Subject:
[External_Sender] Fwd: TR: FW: Due Today
- Norma, There are some redactions requested as shown in yellow highlight. The green highlight identify some editorial corrections.
Peter Vescovi Sent from Workspace ONE Boxer
Forwarded message ----------
From: "MATEO Emmanuelle (ORN-NPS)" <emmanuelle.mateo@areva.com>
Date: Aug 9, 2019 10:05 AM
Subject:
TR: FW: Due Today To: "VESCOVI Peter (ORN-NPS)" <peter.vescovi@areva.com>
Cc: "LABBE Laurence (ORN-NPS)" <laurence.labbe@areva.com>,"LATOUR Brigitte (ORN-NPS)"
<brigitte.latour@areva.com>
- Peter, Here attached the reviewed document.
The green highlight is for typos and yellow highlight for proprietary information.
The team thinks that we need NFI approval, specially for content description (mass, enrichment, physical element etc)
Have you already reviewed the document by your own, based on the safety report (public version) to check the proprietary info?
- Regards, Emmanuelle.
De: FOREY Emmanuel (ORN-NPS)
Envoyé: vendredi 9 août 2019 16:55
- MATEO Emmanuelle (ORN-NPS) <emmanuelle.mateo@areva.com>
Cc: TIGNAT Aude (ORN-NPS) <aude.tignat@areva.com>
Objet: RE: FW: Due Today Emmanuelle, Jai surligné en vert les coquilles.
En jaune, les infos qui nous semblent confidentielles. Il faudrait mon sens lavis de NFI notamment sur la description du contenu (il y a pas mal de détails: masse, enrichissement, nature physique).
Globalement il y a quand mme pas mal de détails techniques.
Par ailleurs, Peter ne peut-il pas nous détailler comment il fonctionne dhabitude?
A-t-il déj fait une premire passe pour supprimer de linfo?
Emmanuel De: VESCOVI Peter (ORN-NPS)
Envoyé: vendredi 9 août 2019 14:12
- LABBE Laurence (ORN-NPS) <laurence.labbe@areva.com>; MATEO Emmanuelle (ORN-NPS) <emmanuelle.mateo@areva.com>; LATOUR Brigitte (ORN-NPS)
<brigitte.latour@areva.com>
Objet: Fwd: FW: Due Today
- Emmanuel,
Brigitte is not in office. Can you have someone at TNI review and provide concurrence for TNF-XI NRC SER? This is urgent in order to get the US revalidation issued. I am at PATRAM and is there anyone from TNI here also who knows this topic and could review?
Peter Vescovi
Sent from Workspace ONE Boxer
Forwarded message ----------
From: "VESCOVI Peter (ORN-NPS)" <peter.vescovi@areva.com>
Date: Aug 8, 2019 12:17 PM
Subject:
Fwd: FW: Due Today To: "LATOUR Brigitte (ORN-NPS)" <brigitte.latour@areva.com>
Cc:
Can you review and let me know if you have comments? Is anyone at PATRAM that could review?
Sent from Workspace ONE Boxer
Forwarded message ----------
From: "SHAW Donis (ORN-NPS)" <don.shaw@areva.com>
Date: Aug 8, 2019 11:32 AM
Subject:
FW: Due Today To: "VESCOVI Peter (ORN-NPS)" <peter.vescovi@areva.com>
Cc:
Peter, hopefully you can open the attached SER file. Don
From: Garcia Santos, Norma [1]
Sent: Thursday, August 08, 2019 12:28 PM To: SHAW Donis (ORN-NPS)
Cc: VESCOVI Peter (ORN-NPS); Conroy, Michael (PHMSA); McKirgan, John
Subject:
RE: Due Today
Security Notice: Please be aware that this email was sent by an external sender.
- Don,
Please let me know if you were able to open the document. Use the same password that I sent you (see email below).
- Thanks, Norma
From: Garcia Santos, Norma Sent: Thursday, August 08, 2019 11:33 AM To: SHAW Donis (ORANO) <don.shaw@orano.group>
Cc: VESCOVI Peter (ORANO) <peter.vescovi@orano.group>; Conroy, Michael (PHMSA)
<Michael.Conroy@dot.gov>; McKirgan, John <John.McKirgan@nrc.gov>
Subject:
Due 3pm Today
Good morning again,
As previously mentioned, here is the code:
TNFXI2019_Review
Thanks in advance, Norma Garcia Santos STIMS Administrator Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission
Telephone No.: 301-415-6999 Email: Norma.Garcia-Santos@nrc.gov