ML22061A208
| ML22061A208 | |
| Person / Time | |
|---|---|
| Site: | 07103092 |
| Issue date: | 03/15/2022 |
| From: | Nishka Devaser Storage and Transportation Licensing Branch |
| To: | Boyle R US Dept of Transportation, Radioactive Materials Branch |
| N DEVASER NRC/NMSS/DFM/STLB 3014155196 | |
| References | |
| EPID L-2021-DOT-0005 | |
| Download: ML22061A208 (3) | |
Text
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 NO. F/381/AF-96, REVISION EL FOR THE MODEL NO. TNF-XI PACKAGE -
REQUEST FOR ADDITIONAL INFORMATION, DOCKET NO. 71-3092
Dear R. Boyle:
By letter dated July 14, 2021 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML22061A162), the U.S. Department of Transportation requested that the U.S. Nuclear Regulatory Commission (NRC) staff perform a review of the French Certificate of Approval No. F/381/AF-96, revision EI for the TNF-XI transportation package and make a recommendation concerning the revalidation of the package regarding the addition of content 9 as described in the French certificate.
In connection with our review, this letter is to advise you that the information needed to continue our review, described as a request for additional information, is in the enclosure to this letter.
Addressing the request for additional information does not preclude the staff from issuing further requests for additional information during the detailed technical review of this application.
In order to complete our technical review on schedule, your response should be provided within 30 days of the date of this letter. If you have any questions regarding this matter, I may be contacted at (301) 415-5196 or at Nishka.Devaser@nrc.gov.
Sincerely, Nishka Devaser, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-3092 EPID L-2021-DOT-0005
Enclosure:
Request for Additional Information March 14, 2022 Signed by Devaser, Nishka on 03/14/22
R. Boyle 2
2
SUBJECT:
REQUEST FOR REVALIDATION OF FRENCH CERTIFICATE OF APPROVAL NO. F/381/AF-96, REVISION EL FOR THE MODEL NO. TNF-XI PACKAGE -
REQUEST FOR ADDITIONAL INFORMATION, DOCKET NO. 71-3092 DATE: March 14, 2022 DISTRIBUTION:
ADAMS Memo Accession No.: ML22061A208 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME NDevaser SFigueroa RRodriguez OKhan JSmith DATE 03/03/22 03/03/22 03/04/22 03/04/22 03/04/22 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME DMarcano TBoyce MDiazMaldonado B. White for YDiazSanabria DATE 03/07/22 03/04/22 03/08/22 03/09/22 OFFICIAL RECORD COPY
Enclosure Request for Additional Information Docket No. 71-3092 Model No. TNF-XI Package French Certificate F/381/AF-96 By letter dated July 14, 2021 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML22061A162), the U.S. Department of Transportation requested that the U.S. Nuclear Regulatory Commission staff perform a review of the French Certificate of Approval No. F/381/AF-96, revision EI for the TNF-XI transportation package and make a recommendation concerning the revalidation of the package for import and export use.
This request for additional information identifies information needed by the U.S. Nuclear Regulatory Commission staff (the staff) in connection with its technical review of the Model No. TNF-XI package application.
Structural Evaluation 2-1 Provide clarity on the addition of spacers and centering system.
Clarify the use of the spacers system and reinforcement steel disk as discussed in safety analysis report (SAR) Chapters 0 and 0A (ADAMS Accession No. ML22061A162). It is not clear to the staff if these components are credited with a structural role or some other function. In addition, Figure 9 in SAR Appendix 1-9, shows plastic top and bottom spacers. The staff could not identify these plastic spacers in Table 0.1 List of Packaging Components in SAR Chapter 0. It is not clear to the staff if these plastic spacers are intended to be a part of the packaging. Please clarify the role of these components.
This information is necessary to comply with International Atomic Energy Agency (IAEA)
SSR-6 (2012) paragraph 727.
Criticality Evaluation 5-1 Provide a justification that the use of 1620 grams of CH2 in each cavity of the TNF-XI package is a bounding limit for moderation of the package contents.
The applicant stated in their criticality safety evaluation (SAR Chapter 5A-7) that moderation of the TNF-XI package is dominated by the up to 1620 grams of CH2 allowed in each cavity of the package. Staff was unable to determine that this is bounding for all potential moderators that may be contained in the TNF-XI. Staff recognizes that an optimum mixture of water and CH2 moderation was provided by the applicant (as outlined in SAR Chapter 5A-7 Section 5.1.3), however, it is unclear whether the assumed quantity of CH2 is bounding for all moderating materials allowed in the TNF-XI package. In addition, the French Certificate of Approval for a Package Design (F/381/AF-96) states that the mass of additives with a greater hydrogen content than water may not exceed 390 grams. This lower limit is not addressed in the criticality safety evaluation provided.
This information is required to ensure that the applicant has identified the most reactive credible configuration of the materials to be shipped as required by IAEA SSR-6 (2012),
paragraphs 676-686.
2 Materials Evaluation 7-1 Provide the manufacturer data sheet, test data, or other analysis that supports the increase in the maximum allowable short-term temperature for the primary lid elastomer seal.
The maximum allowable temperature for the EPDM seal was increased 20 °C above the limit reviewed in the staffs prior revalidation of the TNF-XI package. SAR Chapter 0 states that maximum operating temperature for 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> peak is 180 °C (356 °F). In the SAR evaluated in the staffs prior review (ADAMS Accession No. ML19219A036) of the TNF-XI package, the maximum temperature criterion was 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> peak at 160 °C (320 °F) (ADAMS Accession No. ML19232A157).
Given that the primary lid seals have been calculated to reach 178°C (352°F) in a fire accident, which is above the short-term accident limit previously defined in the SAR, provide the technical basis to demonstrate that the EPDM seal is capable of maintaining the configuration of the contents. The staff notes that, in support of the staffs prior revalidation review of the original lower temperature limit, the applicant provided a manufacture data sheet that cited a 170 °C (338 °F) operating limit (ML19219A036).
This information is required to demonstrate compliance with IAEA SSR-6 (2012) paragraphs 728.
7-2 Provide additional information on the inspection method and acceptance criteria for the check of the containment system welds added to SAR Chapter 7A.
Section 3 of SAR Chapter 7A states as part of the maintenance program that welds will be checked every three years, however there is no inspection criteria or standard provided as a benchmark. The added instruction provides no details on the inspection methodology (e.g., visual) or the acceptance criteria for that inspection.
This information is needed to satisfy the requirements of IAEA SSR-6 (2012) paragraph 501(b).
ML22061A208 OFFICE NMSS/DFM/STLB NMSS/DFM/MSB NMSS/DFM/STLB NMSS/DFM
/NARAB NAME NDevaser OKhan SFigueroa JSmith DATE Mar 3, 2022 Mar 4, 2022 Mar 3, 2022 Mar 4, 2022 OFFICE NMSS/DFM/MSB NMSS/DFM NMSS/DFM/MSB NMSS/DFM/FFLB NAME RRodriguez DMarcano TBoyce MDiaz DATE Mar 4, 2022 Mar 7, 2022 Mar 4, 2022 Mar 8, 2022 OFFICE NMSS/DFM/STLB NMSS/DFM/STLB NMSS/DFM/STLB NAME YDiaz-Sanabria BWhite for NDevaser NDevaser DATE Mar 9, 2022 Mar 10, 2022 Mar 14, 2022