ML22341A137
| ML22341A137 | |
| Person / Time | |
|---|---|
| Site: | 07201042 |
| Issue date: | 12/08/2022 |
| From: | Christian Jacobs Storage and Transportation Licensing Branch |
| To: | Narayanan P TN Americas LLC |
| Shared Package | |
| ML22341A136 | List: |
| References | |
| Download: ML22341A137 (1) | |
Text
EOS Amendment #3 New Scope Addition #3 - RAIs
- 1. Include the installation of the gantry box wheel chocks in the operating procedures in the Safety Analysis Report (SAR) section A.9.
It appears that wheel chocks are relied on in analyses of the MX-LC (e.g., the assumed boundary conditions for the seismic stability analysis in Calculation No. 41041-0205) and SAR statements (e.g., SAR section A.2.1.4.2.1.4 states, For these seismic analyses, a pair of wheel chocks is provided for each of the four gantry boxes to restrain the gantry lower boom from sliding under seismic loading.). However, the operating procedures for transferring the dry shielded canister (DSC) to the HSM-MX in SAR section 9.1 do not include the installation of the gantry box wheel chocks.
This information is needed to determine compliance with the regulatory requirements in Title 10 of the Code of Federal Regulations (10 CFR) Section 72.150.
- 2. Describe the approach that ensures the DSC is in an analyzed configuration after it is lifted with the MX-LC and prior to the installation of the gantry box wheel chocks.
It appears that the wheel chocks are relied upon to restrain the MX-LC in the analyses of lateral loads and that the DSC lifted by the MX-LC is in an unanalyzed configuration before installing the wheel chocks. The following are examples of approaches that could address this condition: (1) describe how this configuration without wheel chocks is bounded by the existing analyses; (2) clarify if the emergency brakes for the for the gantries are automatically applied, satisfy the seismic design requirements for single-failure-proof lifting devices in section 2.5 of NUREG-0554, and satisfy the boundary condition assumptions of the analyses or provide such emergency brakes; (3) limit the lifting height during these steps of the procedures to less than the maximum lift height of 65 inches for non-single-failure-proof lifting devices; or (4) analyze the MX-LC without relying on the use of the gantry box wheel chocks.
This information is needed to determine compliance with the regulatory requirements in 10 CFR 72.236(l).
- 3. Provide a summary description of how the maintenance and testing for the MX-LC satisfies the intent of paragraph 5.1.1(6) of NUREG-0612 and sections 7 through 9 of NUREG-0554 and update the SAR as necessary.
SAR sections A.1.2.1.4.2.1.10 through A.1.2.1.4.2.1.15 describe the testing and maintenance of the MX-LC. While the SAR describes the maintenance and testing activities, it does not describe the frequency and acceptance criteria associated with the activities. The staff notes that this information may currently be in the operating and maintenance manuals mentioned in SAR section A.2.1.4.2.1.14.
This information is needed to determine compliance with the regulatory requirements in 10 CFR 72.146, 72.150, and 72.162.
Enclosure