ML20213B079
| ML20213B079 | |
| Person / Time | |
|---|---|
| Site: | 07102027 |
| Issue date: | 01/21/2020 |
| From: | Sewell P Daher-TLI, Transport Logistics International |
| To: | Office of Nuclear Material Safety and Safeguards, US Dept of Transportation, Office of Hazardous Materials Technology |
| NJDevaser NMSS/DFM/STL 415.5196 | |
| Shared Package | |
| ML20213B073 | List: |
| References | |
| LTR-19003-012 | |
| Download: ML20213B079 (3) | |
Text
Transport Logistics International, Inc.
8161 Maple Lawn Boulevard Suite 480 Fulton, Maryland 20759 t +1 301 421 4324 f +1 301 421 4326 LTR-19003-012 21 January 2020
Subject:
Response to NRC Request for Supplementary Information for United States Validation of Certificate J/2027/AF-96 for the RAJ-IIIS Package ATTN: Director OHMT - DH23 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Office of Hazardous Materials Technology East Building, PHH-20 1200 New Jersey Avenue SE Washington, DC 20590-0001 DAHER-TLI hereby submits responses to the request for supplemental information (RSIs) in the letter dated October 28, 2019 for the US DOT validation of the Japanese NRA Certificate of Approval, J/2027/AF-96, for the RAJ-IIIS.
Responses to the RSIs are provided below, with supplemental information included in the attached documents.
If you have any questions or need additional information, please contact me at the undersigned details. Thank you for your time.
Sincerely, Digitally signed by Philip Sewell Date: 2020.01.21 14:38:00 -05'00' Philip Sewell, Principal Engineer, Engineering and Packaging Services, DAHER-TLI email: psewell@tliusa.com phone: +1 (301) 421-4066 Attachments
- 1. Evaluation report on maximum deformation of fuel cladding tubes assuming the fuel pellets to be inserted.
(TTO-T19-001 Rev.0).
- 2. Annotated SAR Section (B)-B with direction for reference data.
- 3. SAR Section (B)-B Reference [1].
- 4. SAR Section (B)-B Reference [2].
- 5. RAJ-IIIS Drawings (TTO-T06-047-01 & TTO-T06-047-02)
Structural RSI 1 With respect to Item 5, Specification of Package, of the Certificate of Approval (CoA), provide legible drawings for the following:
- Figure (A)C-2, Structure of Inner Container (RAJ-IIIS)
- Figure (A)C-3, Structure of Outer Container (RAJ-IIIS)
The staff needs sufficiently high quality, large-scale, drawings to facilitate review of the package description.
Response
Higher quality versions of the drawings used to generate the drawing figures in the RAJ-IIIS SAR referenced in the J/2027/AF-96 certificate are provided in Attachment 5 to this letter.
Structural RSI 2 With respect to Table (B)-F.1, Evaluation of Compliance with the Ministerial Ordinance and Notification of the Competent Authority, provide clarification on how the Ministerial Ordinance Articles as identified in the table meet the International Atomic Energy Agency (IAEA) Standard SSR-6, Regulations for the Safe Transport of Radioactive Material (2012 Edition). Provide justification, including compensatory design evaluations as appropriate, to demonstrate that meeting the Ministerial Ordinance Articles indicates the package design compliance with the SSR-6 requirements.
Page 1 of the CoA notes that the package design complies with the design requirements of the IAEA Standard SSR-6.
In the Table (B)-F.1 evaluation of compliance with the Ministerial Ordinance Articles, the listed Standards and corresponding Explanation do not appear to be summarized to corroborate the CoA page 1 statement on meeting the SSR-6 standards. This information is needed for the package revalidation for meeting the IAEA SSR-6 requirements as stated in the CoA.
Response
Table(B)-F.1. shows evaluation results based on the requirements of Japanese regulations. Since Japanese regulations comply with the IAEA Guidance SSR-6, Regulations for the Safe Transport of Radioactive Material, the package complies with the requirements of SSR -6.
Structural Observation 1 Provide justification for the Section A.6.1.4, Slanting Drop, statement, [S]ince the energy absorption is eventually made in the same condition as the case of the horizontal drop, the impact force given to the fuel rods are less severe than the horizontal drop. Its generally known that the secondary impact as related to slanting drop may result in a higher impact force than that associated with the package horizontal drop. The slenderness of the proposed package design for non-irradiated (fresh) fuel rods needs to be evaluated explicitly for the secondary impact effect, per the IAEA Guidance SSR-26, Advisory Material for the IAEA Regulations for the Safe Transport of Radioactive Material (2012 Edition). Specifically, Paragraph 702.2 of SSG-26 states, [E]xperience suggests that the effect of secondary impact is often more severe for slender and rigid package, including:
(a) A package with an aspect ratio larger than 5, but sometimes even as low as 2; (b) A large package when significant rebound is expected to occur following the 9 m drop; (c) A package in which the contents are rigid and slender and particularly vulnerable to lateral impact.
This information is needed for the package revalidation for meeting the IAEA SSR-6 requirements as stated in the CoA.
Response
The package has not been subjected to a drop test with 9m slope in accordance with the advisory document of the IAEA SSG-26(2012 Edition). Instead of evaluating the results of the drop test with 9m slope, we evaluated the maximum deformation of the cladding tube (fuel rod) to ensure that there was no breakage. The evaluation result of this maximum deformation is equal to or better than the result obtained in the evaluation of the drop test required in the advisory document of the IAEA SSG-26. The evaluation results for the maximum deformation of the cladding tube (fuel rod) are shown in Attachment 1.
Thermal RSI 1 Provide the relevant thermal-related Attached Documents - 1 that supports the thermal analysis or provide a description of the documents if they are not integral to the thermal analysis and evaluation.
SAR Section B.6 of Page (B)B-32 indicates there are attached documents, presumably to support the thermal analysis. These documents should be provided if they are integral to the thermal analysis; if not then a description of their relevance should be provided. This information is needed for the package revalidation for meeting the IAEA SSR-6 requirements (paragraph 658) as stated in the CoA.
Response
The referenced attached documents are only used for the equations and reference data utilized, as marked by a [1]
or [2], throughout the thermal analysis section (B)-B of the SAR. An annotated version of section (B)-B of the SAR is included with this letter in Attachment 2 to point to data from references 1 and 2, provided in letter Attachments 3 and 4, respectively.