ML21173A323

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Alpha-Omega Services, Inc., Request to Amend Certificate of Compliance 9316
ML21173A323
Person / Time
Site: 07109316
Issue date: 06/22/2021
From: Hedger T
Alpha-Omega Services
To: Pierre Saverot
Document Control Desk, Division of Fuel Management
References
EPID L-2021-LLA-0071, FM9006.1-062021-004 AOS-FM9054, Rev J-2
Download: ML21173A323 (4)


Text

9156RoseStreetP.O.Box789Bell"ower,California,U.S.A90706 CustomerService(800)3467894(562)8040604Fax:(562)8040610 www.alphaomegaserv.com June 22, 2021 U.S. Nuclear Regulatory Commission Attn: Document Control Desk / Mr. Pierre Saverot - STLB Director, Division of Fuel Management - DFM Office of Nuclear Material Safety and Safeguards - NMSS 11555 Rockville Pike One White Flint North Rockville, MD 20852

SUBJECT:

AOS REQUEST TO AMEND CERTIFICATE OF COMPLIANCE 9316 USNRC

Reference:

EPID L-2021-LLA-0071, Docket No. 71-9316 AOS

Reference:

FM9006.1-062021-004 Mr. Saverot:

Alpha-Omega Services, Inc. (AOS) would like to request the amendment of Certificate of Compliance No. 9316.

In addition to our previous amendment request dated April 28, 2021 we propose the attached minor change, as described below.

1.

Revise the title to paragraph 7.1.3.3 Test B to read, Helium Mass Spectrometer Leak Test: For Normal Form Contents ; and to include reference to test method A.5.3 or A.5.4 from ANSI N14.5-2018 to the description of the leak test of the containment system.

Attached for your review are the revised pages from SAR FM9054 Revision J-2.

Best Regards, Troy Hedger, President Alpha-Omega Services, Inc.

Attachments:

SAR AOS-FM9054 Rev J-2 (3 pages)

AOS-FM9054 Rev. J-2, June 22, 2021 (Docket No. 71-9316)

Radioactive Material Transport Packaging System Safety Analysis Report for Model AOS-025, AOS-050, and AOS-100 Transport Packages Prepared by Alpha-Omega Services, Inc.

Bellflower, CA

J January 31, 2021 Consolidation of Revisions H - H7 (Revision I intentionally skipped)

Subsection 1.2.2 and Section 7.1 - Clarified that the shoring materials are structural Paragraphs 2.5.3.1.2 through 2.5.3.1.4 - Calculations revised to correct minor errors and typos Subsection 2.6.7 - Removed stale note created in Revision H-5 Figures 3-18 through 3 Replaced thermal transient plots for AOS Model-025 fire condition Figure 4 Changed port cover torque requirement Chapter 9 - Updated with current requirements, approval letter, and certificate Updated ANSI N14.5 references to 2014 edition Applied miscellaneous corrections (table of changes included with cover page of the submittal)

J-1 April 20, 2021 Revised Subsection 1.2.2 (added discussion related to cask loading temperature and backfilling pressure)

Revised Subsection 2.2.3 (expanded discussion related effects of radiation),

Paragraph 2.6.1.1 (revised initial conditions for NCT pressure calculations),

Table 2-31 and Table 2-54 (omitted footnotes b and c, respectively; updated calculated pressures); added new Reference [2.35]

Revised Subsection 3.2.2 (update calculated NCT pressures and elaborate on initial conditions and mechanisms that can increase internal cask pressure)

Revised Table 4-6 and Table 4-7 (omitted footnotes b and c, respectively; revised pressure calculations based on updated initial conditions)

Revised Paragraph 7.1.3.1 (revised instructions for wet-loading cask),

Figure 7-4 (updated to reflect current equipment), and Paragraph 7.1.3.3 (revised leak testing procedure)

Revised Table 8-1 footnote (clarified test procedure sensitivity),

Subsection 8.1.4 (revised fabrication leak testing requirements), Section 8.2 (removed statement regarding pre-shipment leak testing because this belongs in Chapter 7), Subsection 8.2.2 (updated leak testing requirements)

J-2 June 22, 2021 In Paragraph 7.1.3.3, changed title of Test B - Tracer Gas:

to Test B - Helium Mass Spectrometer Leak Test:

In Paragraph 7.1.3.3, Test B, step a, changed The cask lid seal, and vent and drain threaded pipe plugs must be leak-tested in accordance with ANSI N14.5-2014 [7.8]. to The cask lid seal, and vent and drain threaded pipe plugs must be leak-tested in accordance with test method A.5.3 or A.5.4 from ANSI N14.5-2014 [7.8].

Revision Date Description of Changes

Radioactive Material Transport Packaging System Safety Analysis Report 7-13 for Model AOS-025, AOS-050, and AOS-100 Transport Packages, Rev. J-2, June 22, 2021 (Docket No. 71-9316)

Test A2 - Gas Pressure Drop: For Special Form Contents (Tests: Cask Lid(s), Vent and Drain Ports)

To perform a pre-shipment verification of the elastomeric lid seal:

a.

Perform the test by pressurizing the space between the cask lid seals elastomeric O-Ring seals, -or-the cavities outside the cask vent and drain ports, and then measuring the pressure drop.

Notes:

The cask vent port and cask drain port need to be leak tested only if the ports have been opened since they were last tested.

The Gas Pressure Drop Leak test is performed using a test manifold, isolation valve, pressure gauge, and pressure supply. Use the test apparatus described in the test procedure or equivalent.

b.

Connect the test manifold to the test port. Evacuate the test volume to the required level.

and then close the isolation valve.

c.

Disconnect the pressure supply and then wait for the prescribed test time. After the test time, the acceptance criterion is a pressure drop that corresponds to no detectable leakage.

Test B - Helium Mass Spectrometer Leak Test: For Normal Form Contents (Tests: Lid (Cask Lid Seal), Vent and Drain Ports)

To leak test the containment system:

a.

The cask lid seal, and vent and drain threaded pipe plugs must be leak-tested in accordance with test method A.5.3 or A.5.4 from ANSI N14.5-2014 [7.8]. The acceptance criteria is 1 x 10-7 ref-cm3/sec air at an upstream pressure of a minimum of 1 atmosphere and downstream pressure of 0.01 atmosphere absolute or less. The test procedure sensitivity must be one-half of the reference air leakage rate (i.e., 5 x 10-8 ref-cm3/sec of air) or less.