ML20317A151
| ML20317A151 | |
| Person / Time | |
|---|---|
| Site: | 07103097 |
| Issue date: | 11/12/2020 |
| From: | Garcia-Santos N Storage and Transportation Licensing Branch |
| To: | Boyle R US Dept of Transportation, Office of Hazardous Materials Safety |
| Garcia-Santos N | |
| Shared Package | |
| ML20317A042 | List: |
| References | |
| EPID L-2020-NEW-0000 | |
| Download: ML20317A151 (3) | |
Text
Request for Additional Information U.S. Department of Transportation French Approval Certificate No. F/348/AF-96, Revision Fq Docket No. 71-3097 Certificate of Compliance No. 3097 Model No. FCC-4 By letter dated January 14, 2020 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML20022A001], and as supplemented on June 29, 2020 (ADAMS Package Accession No. ML20189A607), the U.S. Department of Transportation requested that the U.S. Nuclear Regulatory Commission (NRC) staff performs a review of the French Approval Certificate Number F/348/AF-96, Revision Fq, Model No. FCC-4 transport package, and make a recommendation concerning the revalidation of the package for import and export use.
This request for additional information (RAI) identifies information needed by the NRC staff (the staff) in connection with its review of the application. The staff used 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.
The RAI describes information needed by the staff to complete its review of the application and to determine whether the applicant has demonstrated compliance with the regulatory requirements of the IAEA SSR-6, 2012 Edition.
CRITICALITY SAFETY (Cr)
RAI-Cr-1 Provide the cross sections used to perform the criticality evaluations in App. 2.5-1 and 2.5-2 of the safety analysis report. If they are not the same as those used within the benchmarking evaluations for the criticality codes in App. 2.5-6, justify the use of these cross sections.
Appendix 2.5-6 of the SAR shows that the applicant used the JEF 2.2 cross section library to perform the benchmarking of the CRISTAL V1.1 criticality code package. App. 2.5-1 and 2.5-2 of the SAR that documents the criticality evaluations for the FCC-4 does not state what cross section library the applicant used in its evaluations.
The applicant needs to verify that it used the same cross section library in its criticality evaluations as it did to perform the benchmarking analyses, or provide justification that the criticality code uncertainty established in App. 2.5-6 is applicable to the cross sections used in the FCC-4 criticality evaluations.
In responding to this RAI, the applicant may refer to information provided in Reference 1 in response to RAI-Cr-5 for the FCC-3 (Docket No. 71-3083) and state if it is applicable to the FCC-4.
The staff requests this information so that it can determine compliance with Paragraphs 682, 684, and 685 of the IAEA SSR-6, 2012 Edition.
Enclosure
RAI-Cr-2 Explain how the uncertainty from the MORET code, associated with the Monte Carlo method, is applied to the results of the criticality analyses for the FCC-4.
In Section 3 of App. 2.5-1, 2.5-2, and 2.5-3 of the SAR, the applicant notes that the uncertainty value of the CRISTAL code (as determined by App. 2.5-6 of the SAR) is added to all of the reactivity values in the report. However, the staff requests clarification on how the uncertainty of the MORET code associated with the Monte Carlo method for each calculation is applied to each of the results.
Typically, applicants will add 2 to the nominal keff value calculated. The staff cannot find in the application how this was treated in App. 2.5-1, 2.5-2, and 2.5-3 of the SAR.
In responding to this RAI, the applicant may refer to information provided in Reference 1 (and any additional follow-up information) in response to RAI-Cr-6 for the FCC-3 (Docket No. 71-3083) and state if it is applicable to the FCC-4.
This information is needed to determine compliance with the requirements in Paragraphs 682, 684, and 685 of the IAEA SSR-6, 2012 Edition.
RAI-Cr-3 Provide the following information related to assumptions for the array calculations under accident conditions in the FCC-4 criticality evaluations for Content Nos.
1, 2, 3, and 12:
a) a demonstration showing that the condition of empty space between packages is more reactive than a condition with hydrogenous material between packages; and b) the assumed spacing between the packages and justification for this spacing.
In Section 5.3.2 of App. 2.5-1 of the SAR, the applicant notes that there is empty space between the packages. Paragraph 685(a) of the SSR-6 notes that criticality analysis for arrays under accident conditions shall have hydrogenous moderation between the packages. The staff requests that the applicant provide information demonstrating compliance consistent with Paragraph 685(a) of SSR-6, or update the criticality analysis to justify the applicants assumption of the most reactive packages for the array condition under accident conditions.
The staff did not find a discussion in App. 2.5-1 of the SAR on the spacing of the packages for the array condition under accident conditions for the criticality analysis for the FCC-4 Content Nos. 1, 3 and 12 in App. 2.5-1 of the SAR.
In responding to this RAI, the applicant may refer to information provided in Reference 1 in response to RAI-Cr-5 for the FCC-3 (Docket No. 71-3083) and state if it is applicable to the FCC-4.
This information is needed to determine compliance with the requirements in Paragraph 685(a) of the IAEA SSR-6, 2012 Edition.
RAI-Cr-4 Provide a justification related to the assumptions used to represent the neutron absorber within the criticality analysis are appropriate to incorporate the effects of 2
the thermal test in SSR-6 Paragraph 728 and that the neutron absorber would not melt under credible accident conditions. Include the following information as part of your response:
a) Justification for the conditions of the package and assumptions used to determine the effects of thermal tests on the neutron absorber resin; b) Documentation justifying the glass transition temperature of the neutron absorber resin; and c) Explanation of the statement that a boron gradient was formed within the material in Appendix 2.2-4 of the SAR.
The applicant demonstrated the effects of the thermal tests described in SSR-6 Paragraph 728 on the neutron absorber resin in the following appendices to the application:
- Appendix 2.2-4 of the SAR, which discusses the direct flame and furnace fire tests on the neutron absorber resin, and
- Appendix 2.2-1 of the SAR, which includes a thermal analysis using the STAR-CD code.
The condition of the neutron absorber within the criticality evaluation (10% loss of boron and loss of hydrogen in the outer 10mm) is more consistent with the results of the tests in Appendix 2.2-4 rather than Appendix 2.2-1, which shows that the neutron absorber resin could melt. The staff recognizes that the differences in these effects are likely due to the assumptions of the condition of the package used in the tests/modeling.
The staff requests that the applicant provide additional information justifying the conditions that are most appropriate for use in the thermal evaluation so that the staff can determine if the effects on the resin within the criticality evaluation are appropriate. The staff is primarily concerned with the possibility of the neutron absorber resin melting and whether this is more limiting from a criticality perspective.
In responding to this RAI, the applicant may refer to information provided in Reference 1 in response to RAI-Cr-8 for the FCC-3 (Docket No. 71-3083) and state if it is applicable to the FCC-4.
This information is needed to determine compliance with the requirements in Paragraphs 673, 682, and 685 of the IAEA SSR-6, 2012 Edition.
Reference 1: Letter from Orano, TN to U.S. DOT, Request for Additional Information, U.S.
Department of Transportation, Docket no. 71-3083 / EPID L-2020-LLA-0011, French Approval Certificate Number F/347/AF-96, Revision Fs, Model No. FCC-4 Package, September 8, 2002, ADAMS Accession No. ML20309A842.
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