ML19241A566

Letter to R. Boyle Request for Revalidation of French Certificate of Approval F/41 O/B(U)-96 Revision AD - First Request for Additional Information (W/Enclosure)

ML19241A566
Person / Time
Site:	07103094
Issue date:	08/29/2019
From:	Bernie White Spent Fuel Licensing Branch
To:	Boyle R US Dept of Transportation (DOT)
White B
References
EPID L-2018-NEW-0010
Download: ML19241A566 (12)

Text

August 29, 2019 Mr. Richard W. Boyle Radioactive Materials Branch U.S. Department of Transportation 1200 New Jersey Avenue SE Washington, D.C. 20590

SUBJECT:

REQUEST FOR REVALIDATION OF FRENCH CERTIFICATE OF APPROVAL F/41 O/B(U)-96 REVISION AD - FIRST REQUEST FOR ADDITIONAL INFORMATION

Dear Mr. Boyle:

By letter dated November 1, 2018 (Agencywide Documents Access and Management System

[ADAMS] Accession No. ML19220A444), as supplemented on May 9, 2019 (ADAMS Accession No. ML19135A160), the U.S. Department of Transportation (DOT) requested that the U.S.

Nuclear Regulatory Commission (NRC) staff perform a review of the French Certificate of Approval F/41 O/B(U)-96 Revision Ad, for the Model No. MANON transport package and make a recommendation concerning the revalidation of the package for import and export use.

Specifically, you requested that the NRC only review the content in Appendix 3 to the French certificate.

In connection with our review, we need the information identified in the enclosure to this letter.

To assist us in scheduling the staffs review of your response, we request that you provide this information 1 month from the date of issuance of this request. Inform us at your earliest convenience, but no later than 3 weeks after issuance of this request, if you are not able to provide the information by that timeframe. If you are unable to provide a response 1 month after issuance of this request, our review may be delayed.

R. Boyle Please reference Docket No. 71-3094 and Enterprise Project Identifier No. L-2018-NEW-0010 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) 415-6577.

Sincerely,

/RA/

Bernard White, Senior Project Manager Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-3094 EPID L-2018-NEW-0010

Enclosure:

Request for Additional Information

ML19241A566 OFFICE: DSFM DSFM DSFM DSFM DSFM SFigueroa YKim JBorowsky VWilson NAME: BWhite Via email Via email Via email Via email DATE: 8/7/19 8/8/19 8/12/19 8/15/19 8/9/19 OFFICE: DSFM DSFM DSFM DSFM DSFM DForsyth for JWise MRahimi YDiaz-Sanabria NAME: TTate JMcKirgan Via email Via email Via email Via email DATE: 8/9/19 8/15/19 8/19/19 8/19/19 8/29/19 Request for Additional Information Docket No. 71-3052 Model No. TN-MTR French Certificate of Approval No. F/357 /B(U)F-96 Revision Eaf By letter dated November 5, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19220A444), as supplemented on May 9, 2019 (ADAMS Accession No. ML19135A160), the U.S. Department of Transportation (DOT) requested that the U.S.

Nuclear Regulatory Commission (NRC) staff perform a review of the French Certificate of Approval F/41 O/B(U)-96 Revision Ad, for the Model No. MANON transport package and make a recommendation concerning the revalidation of the package for import and export use.

Specifically, you requested that the NRC only review the content in Appendix 3 to the French certificate.

This request for additional information (RAI) identifies information needed by the U.S. Nuclear Regulatory Commission staff (the staff) in connection with its review of the application. The staff used the International Atomic Energy Agency (IAEA) Specific Safety Requirements No. 6 (SSR 6), Regulations for the Safe Transport of Radioactive Material," 2012 Edition, in its review of the application.

Structural Evaluation

1. Explain the use of smaller masses of the components in the LS-DYNA finite element (FE) analysis.

In Chapter 4-3 of the Package Design Safety Report (PDSR), Analytical Study of the Behaviour of the Package During Drop Tests Under NCT [normal conditions of transport]

& ACT [accident conditions of transport], the applicant presented masses of the components used in the LS-DYNA analysis to investigate the performance of the package under the normal condition of transport and accident condition of transport.

Table 5 of Section 5.3 shows the actual masses of the components and the masses of the components used in the analysis. For example, the mass of 4742 kg was used in the analysis for the casing component where the actual mass of the casing component is 5440 kg.

This information is needed to determine compliance with paragraphs 701, 726 and 727 of IAEA SSR-6, 2012 Edition.

2. Provide the following information:

(a) technical discussions or dimensional analyses that justify the use of the 1:3 scale model for the drop tests, (b) the physical information of the 1:3 scale model for the drop tests (e.g., drop height, mass of each component, dimension of the model, etc.) in a tabular form, Enclosure

2 (c) a comparison study between the measurements of the 1:3 scale model tests and the results of the LS-DYNA FE analyses under the normal conditions of transport and accident conditions of transport, and (d) the LS-DYNA output files (i.e., d3plot files, etc.) for the drop analyses.

The applicant provided information in Chapters 4-3 through 4-6 of the PSDR, Analytical Study of the Behaviour of the Package During Drop Tests Under NCT [normal conditions of transport] & ACT [accident conditions of transport], Definition and Representative Nature of the Test Packaging, Drop Test Programme, and Drop Test Report, respectively. Table 7 of Chapter 4-6 shows the Y component maximum acceleration of 374g for the 1:3 scale model (Model No. S3bisC2), while Table 8 of Chapter 4-6 shows the transposed maximum acceleration of 125g for the full-scale model (Model No.

S3bisC2) after considerations of the model scaling effects.

This information is needed to determine compliance with paragraphs 701, 726, and 727 of IAEA SSR-6, 2012 Edition.

Materials Evaluation 1 Provide the material data sheets or test reports that describe the shock absorber foam chemical composition, thermal properties, and mechanical behavior.

The casing and the external enclosure assembly use NU280 phenolic foam for shock absorption. The foam is also credited in the thermal analysis. The packages safety analysis does not include data on the foam that are necessary for the staff to evaluate the corrosion, thermal, and mechanical characteristics of the package, as follows:

• Corrosion: Phenolic foams with high chloride contents have resulted in significant corrosion of stainless steel in transportation packages (NRC, 1994). The staff requires information on the foam chemistry to verify that the foam is compatible with the packaging materials and service environment.

• Thermal: In the thermal calculations, the thermal conductivity of the foam is not dependent on temperature or the amount of foam crush. The heat capacity of the foam is temperature-dependent, but it does not vary with foam crush. The staff requires data on the effects of temperature and crushing on the thermal behavior of the foam to verify the material properties used in the thermal calculations. (See Questions No. 6 in the Thermal Evaluation, below.)

• Mechanical: The mechanical calculations model the crush behavior of the foam at -40°C and +70°C. The staff requires test data on the foam crush behavior at these temperatures to verify the material properties used in the drop calculations.

To address these concerns, the staff requests a copy of reference QTR STM9665-00 Rev. A and other supporting documentation, as necessary.

This information is required to demonstrate compliance with IAEA SSR-6, 2012 Edition 614, 639, and 658.

3

Reference:

NRC Bulletin 94-02, Corrosion Problems in Certain Stainless Steel Packagings Used to Transport Uranium Hexafluoride, November 14, 1994 (https://www.nrc.gov/reading-rm/doc-collections/gen-comm/bulletins/1994/bl94002.html).

Thermal Evaluation

1. Explain how the content was adequately represented in the model during the thermal analysis, recognizing that the content is the source of the 309 W decay heat and proper modeling is necessary to achieve accurate or bounding results. The Note on Thermal Calculation (Document No. NC LME 50291001-08, Rev. C) page 5/21 appears to indicate that the non-removable equipment (content) was not explicitly modeled, which leads to the following issues:

a. How was the decay heat modeled in the package? If a flux was applied to the inner surface of the EDCE to represent the decay heat, provide details for the flux calculation.

b. Page 7/21 states there is radiative exchange. However, there is no discussion about the exchange surfaces, considering that it appears the non-removable equipment is not modeled (e.g., what surfaces that are modeled undergo a radiation exchange?).

c. What are the temperatures of the critical isotopic generator components (especially the bounding Marguerite 20), including the lead shielding (per Chapter 02, page 8/10)? In addition, provide the allowable temperatures of those critical Marguerite 20 components. For example, there was no confirmation that lead, or other critical components of the isotopic generator, was below the allowable temperature under normal conditions and accident thermal conditions.

This information is needed to determine compliance with paragraphs 653, 659 of IAEA SSR-6, 2012 Edition.

2. Demonstrate how the ANSYS thermal model addresses the natural convection within the package due to the ventilation openings at the ends of the casing.

Chapter 03 page 19/46 states that the Manon package includes top and bottom ventilation openings to allow natural convection to occur within the free space between the EDCE and the casing. There was no description about this feature in the thermal model, including the type of turbulence modeling scheme, its justification, and the appropriateness of boundary conditions (e.g., modeling a pressure boundary far removed from vents to allow natural flow behavior). In addition, there was no discussion whether these openings would result in a pathway for fire, such as during the thermal accident test condition.

This information is needed to determine if the Manon package meets the requirements of paragraph 653, 659 of IAEA SSR-6, 2012 Edition.

3. Specify the location of the holes associated with the thermal fuses with respect to the EDCE containment boundary.

4 Chapter 03 Section 7.2.1.4 appears to state that both the Manon casing and the EDCE have thermal fuses and that the fuses include holes in both the casing and the EDCE, but fuse locations were not clearly provided to ensure they would not have an adverse impact on the containment boundary.

This information is needed to determine if the Manon package meets the requirements of paragraph 641 of IAEA SSR-6, 2012 Edition.

4. Provide the specification, or certificate of conformity, for the thermal fuse that is used to maintain acceptable package performance during a fire accident condition.

Chapter 04-11, Classification Plan for Safety-Related Components on the Casing, page 15/19 indicates that the thermal fuses are safety components. However, there was no clear design or detailed description that provided the specifications and required properties (e.g., composition, melting point) of the thermal fuse.

This information is needed to determine if the Manon package meets the requirements of paragraph 641 of IAEA SSR-6, 2012 Edition.

5. Clarify the presence of combustible gases during normal conditions and accident conditions due to the packages phenolic foam and thermal fuses.

Both the thermal fuse and the phenolic foam are hydrocarbon materials. Confirm there is not a significant amount of flammable gases via radiolysis or thermal degradation during normal transport conditions and accident transport conditions. If present, confirm that the concentrations are below flammability limits (e.g., 5% volume).

This information is needed to determine if the Manon package meets the requirements of paragraph 614, 641, 644 of IAEA SSR-6, 2012 Edition.

6. Discuss the performance of the phenolic foam during the fire accident condition to ensure the temperatures will remain below the limit.

a. The allowable temperature of the phenolic foam should be provided to ensure the foam performs its function during the fire test condition. (See Materials Evaluation question, above.)

b. There was no discussion about the phenolic foams behavior (i.e., changes in morphology, properties) and how the changes were adequately modeled (or bounded) in the ANSYS representation.

c. If the foams insulating behavior does adversely change at high temperatures, there was no discussion that would justify the temperatures of the containment boundary gaskets and critical components of the isotopic generator (i.e., lead shielding, see Question No. 1, under Shielding Evaluation, below).

This information is needed to determine if the Manon package meets the requirements of paragraph 614, 644, 659 of IAEA SSR-6, 2012 Edition.

7. Provide details on the heat dissipation test that will be used to confirm thermal performance, including methodology and how the heat dissipation test when loaded with radioactive sources will demonstrate the heat transfer capability of the package.

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a. Chapter 05-01, Use and Maintenance of the Packaging, page 20/37 indicates there is a heat dissipation test in actual conditions when loaded with radioactive sources. There are no details that discuss how the test will demonstrate the heat transfer capability of the package, no discussion on measurements to be taken and their associated acceptance criteria, and no specific component(s) that is (are) tested or its allowable temperature limit.

b. Although Chapter 05:01, page 20/37 mentions that a heat dissipation test is performed under actual conditions when loaded with the radioactive content, this heat test is not mentioned in the loading procedure described in Section 5.6.1 on page 12/37.

This information is needed to determine if the Manon package meets the requirements of paragraph 503 of IAEA SSR-6, 2012 Edition.

Containment Evaluation

1. Clarify the meaning of the following EDCE components, their location (if possible, refer to Figure 1 or Figure 2 on page 25/27 of the Packaging Maintenance Manual), and whether they are considered part of the containment boundary, in order to provide a complete description of the package.

a. Chapter 03 (page 16/46) mentions a self-sealing coupling on the vent of the EDCE; discuss the self-sealing coupling (meaning a quick-disconnect valve?)

b. Chapter 03 (page 23/46) mentions a self-sealing fitting; discuss the self-sealing fitting (meaning a quick-disconnect valve?)

c. Chapter 03 (page 44/46) mentions there is an O-ring for the EDCE self-sealing coupling; discuss the O-ring and the sealing coupling (meaning a quick-disconnect valve?)

d. Packaging Maintenance Manual (page 22/27, Table 5), which mentions an O-ring / sealing of the EDCE self-plugging connector and the Radioactive Release Study Document No. U-8021-NT-02 (page 6/18) mentions a venting self-plugging connector is planned for the enclosure; discuss the O-ring and the self-plugging connector. In addition, clarify if this component is the same as the self-sealing coupling, self-sealing fitting, and the EDCE self-sealing coupling discussed above. Likewise, confirm that these components currently exist as part of the package (Note, the package design should be finalized, not planned).

This information is needed to determine if the Manon package meets the requirements of paragraph 641 of IAEA SSR-6, 2012 Edition.

2. Explain the role of the gasket washer associated with the EDCE coupling and whether it is part of the containment boundary.

Page 16/27 of the Packaging Maintenance Manual states that a gasket washer has an EDCE containment role. However, (a) there is no clear designation or specified location

6 of this component in the Figure 1/Figure 2, (b) no indication that this is part of the containment boundary and, if so, (c) no mention of leak test acceptance criterion.

This information is needed to determine if the Manon package meets the requirements of paragraph 641, 659 of IAEA SSR-6, 2012 Edition.

3. Explain the closure plate leakage rate test procedure after content loading and clarify the leakage rate test acceptance criterion, or confirm that the procedure and acceptance criterion is provided in Appendix 1.

Section 5.6.1 of Chapter 05:01 (page 13/37) indicated that the acceptance criterion for the leakage rate test of the closure plate O-ring is found in a Specific procedure, but did not specify any details. Although Appendix 1 (page 27/37 and 28/37) discusses a closure plate O-rings leakage rate test with an acceptance criterion of 1E-5 Pa m3/sec Standard Leakage Rate (SLR), it was not clear if this procedure and acceptance criterion is applicable to page 13/37 or if there is a different specific procedure.

This information is needed to determine if the Manon package meets the requirements of paragraph 659 of IAEA SSR-6, 2012 Edition.

4. Clarify the methods associated with the leakage rate tests as well as the leakage rate test acceptance criteria associated with the fabrication, minor maintenance and major maintenance for the welds, lid/flange gaskets, and vent cover plates gaskets.

a. Page 9/27 of the Packaging Maintenance Manual indicates that only the containment (lid and cavity) is proposed to undergo Minor maintenance leakage (air) tests. Clarify:

i. the acceptance criterion is 1E-5 Pa m3/sec SLR and that the test is based on Appendix 1.

ii. the components (lid/flange gaskets, cover plate gaskets) that undergo leakage rate tests and iii. what is meant by leak testing the cavity.

b. Page 8/27 indicates that the EDCE (and Manon casing) welds undergo a helium leak test as part of the Major maintenance. Clarify that the acceptance criterion is 1E-8 Pa m3/sec SLR and that the test is based on Appendix 1.

c. Page 9/27 indicates that the EDCE containment (lid and cavity) undergoes a helium sealing test as part of Major maintenance. Clarify the extent of this test (e.g., lid/flange gasket, cover plate gaskets), provide the acceptance criterion (SLR), and clarify the test is based on Appendix 1.

This information is needed to determine if the Manon package meets the requirements of paragraph 659 of IAEA SSR-6, 2012 Edition.

5. Specify the suitable surface condition of the EDCE gasket contact surface and the surface roughness acceptance criterion to ensure that the seals have appropriate performance.

Although Chapter 03 (page 28/46) states the groove surface in contact with the gaskets must have a suitable surface condition to ensure sealing performance, no surface condition information was provided. In addition, it is noted that no surface roughness

7 acceptance criterion was provided in the Packaging Maintenance Manual (page 8/27) that described the gasket contact surface roughness test as part of major maintenance.

These conditions should be stated to ensure that appropriate performance is maintained.

This information is needed to determine if the Manon package meets the requirements of paragraph 659 of IAEA SSR-6, 2012 Edition.

6. Confirm that the EDCE welds undergo helium leakage rate tests after weld repair, irrespective of the year.

Repairs of EDCE welds, which are part of the containment boundary, may need to occur throughout the packages operational period. Therefore, the helium leakage rate test of the weld, with an acceptance criterion of 1E-8 Pa m3/sec SLR according to the Packaging Maintenance Manual (page 8/27 and 9/27), would occur after the repair even if it occurs in years other than the 3rd year or 6th year time frames.

This information is needed to determine if the Manon package meets the requirements of paragraph 659 of IAEA SSR-6, 2012 Edition.

7. Confirm that the choice of O-ring gaskets associated with the EDCE flange/lid and the EDCE vent cover plate are designed to provide sealing with their respective groove dimensions.

Section 10.6.1 (page 28/46) of Chapter 03 indicates that the acceptance criterion for the O-ring gaskets is that the ratio of the gasket volume to the groove volume must be less than or equal to one. However, confirm that the gaskets are appropriately sized, recognizing that in addition to there being an acceptable volume condition, O-rings also must be in an adequately compressed state to maintain containment.

This information is needed to determine if the Manon package meets the requirements of paragraph 659 of IAEA SSR-6, 2012 Edition.

8. Explain why P2 is not recorded when performing a pressure rise leakage rate test.

Chapter 05:01 of page 28/37 (and Packaging Maintenance Manual, page 24/27) provides the equation for determining the leakage rate of the gasket interspace of the EDCE flange and closure plate; this equation requires pressures P1 and P2. However, it is noted that P2 is not recorded in the procedure.

This information is needed to determine if the Manon package meets the requirements of paragraph 659 of IAEA SSR-6, 2012 Edition.

9. Confirm the location of the containment boundary gasket to ensure the proper containment boundary gasket is installed and maintained.

Figure 2 of the Packaging Maintenance Manual has the containment boundary as the outer gasket. This is different from Figure 4 of Chapter 05:01, which has the containment boundary as the inner gasket. Knowledge of the containment boundary gasket location is important to ensure that the seal area is maintained properly.

8 This information is needed to determine if the Manon package meets the requirements of paragraph 503 of IAEA SSR-6, 2012 Edition.

10. Demonstrate that the lid maintains adequate containment function with adequate screw/bolt torque values.

Provide the correct equation for determining the torque for the package screws/bolts in Section 5.2 (page 11/23) of Chapter 04-11; currently it appears to be an equation for tolerance.

This information is needed to determine if the Manon package meets the requirements of paragraph 503 of IAEA SSR-6, 2012 Edition.

Editorial Note:

1. The paragraphs near the top of Page 23/27 of the Packaging Maintenance Manual assign Figure 5 to the EDCE. However, Figure 5 heading is associated with the SV69 plug and lid sealing.

Shielding Evaluation

1. Justify the amount of lead assumed within the shielding evaluation for the MARGUERITE 20.

The applicant includes the lead within the MARGUERITE 20 as a bremsstrahlung target and as a shield. It states on page 3 of Enclosure 1 to E-53665 that the shield is a 18 cm lead cylinder. In this simulation, target and shield are the same. The description of the MARGUERITE 20 within the table in Section 1.2 of Appendix 3 to the English translation of Certificate Number F/410/B(U)-96 states that the overall base is 1,100 mm in diameter and 1,330 mm in height, however from Figure 3.3 of Appendix 3, and Drawing 1ME50291521 the staff is not able to determine the thicknesses of the lead and whether or not an 18 cm lead cylinder is conservative or representative. The staff requests that the applicant state how it determined that the 18 cm lead cylinder (height 18 cm, radius 18 cm from Table 2 of Enclosure 1 to E-53665) is appropriate.

The staff needs this information to verify that the shielding is adequate for determining compliance with paragraphs 526, 527, 648(b), and 659(b)(1) of IAEA SSR-6, 2012 Edition.

2. Clarify the dimensions of the shielding credited for the Manon package.

The staff requests clarifying information on the dimensions credited within the Manon package with the MARGUERITE 20 source. On Page 3 of Enclosure 1 to E-53665, the applicant states that it modeled the source inside a 18cm lead cylinder surrounded by a 1.5 mm thick stainless steel cask with a radius of 73 cm. In response to Part 4 of RSI 1-1 which asked the applicant to provide the materials and thicknesses of shielding components credited within the shielding evaluation, the applicant states that 20 mm is credited in the axial direction and 8 mm in the radial. The staff requests that the applicant clarify how much of the stainless steel Manon packaging is credited in the shielding evaluation (1.5 mm axially and radially or 20 mm axially and 8 mm radially).

9 The staff needs this information to verify that the shielding is adequate for determining compliance with paragraphs 526, 527, 648(b), and 659(b)(1) of IAEA SSR-6, 2012 Edition.