ML23004A071
| ML23004A071 | |
| Person / Time | |
|---|---|
| Site: | 07109371 |
| Issue date: | 01/12/2023 |
| From: | Nishka Devaser Storage and Transportation Licensing Branch |
| To: | Flanigan M QSA Global |
| References | |
| EPID L-2022-LLA-0157 | |
| Download: ML23004A071 (1) | |
Text
January 11, 2023 Mary Flanigan Senior Regulatory Affairs Specialist Regulatory Affairs Department QSA Global, Inc.
40 North Avenue Burlington, MA 01803
SUBJECT:
APPLICATION FOR AMENDMENT REQUEST OF CERTIFICATE OF COMPLIANCE NO. 9371 FOR THE MODEL NO. 360 SERIES TRANSPORTATION PACKAGE - REQUEST FOR ADDITIONAL INFORMATION
Dear Mary Flanigan:
By application dated August 29, 2022 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML22251A094) QSA Global, Inc. requested renewal of Certificate of Compliance No. No. 9371, for the Model No. 360 Series package. In connection with the U.S. Nuclear Regulatory Commission staff review, we need the information identified in the enclosure to this letter. Additional information requested by this letter should be submitted in the form of revised pages.
In order to complete our technical review on schedule, please provide your response within one month of the date of this letter. If you have any questions regarding this matter, I may be contacted at (301) 415-5196.
Sincerely, Signed by Devaser, Nishka on 01/11/23 Nishka Devaser, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-9371 EPID L-2022-LLA-0157
Enclosure:
Request for Additional Information
Request for Additional Information QSA Global Docket No. 71-9371 Certificate of Compliance No. 9371 360 Series Transportation Package By application dated August 29, 2022 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML22251A094) QSA Global, Inc. requested renewal of Certificate of Compliance No. 9371, for the Model No. 360 Series package. This request for additional information identifies information needed by the U.S. Nuclear Regulatory Commission staff in connection with its review of Revision 6 of the safety analysis report (SAR or the application). The staff used guidance provided in NUREG-2216, " Standard Review Plan for Transportation Packages for Spent Fuel and Radioactive Material, in its review of the application.
The question describes information needed by the staff for it to complete its review of the application and to determine whether the applicant has demonstrated compliance with regulatory requirements.
Chapter 2: Structural Analysis RAI 2-1. Provide additional information, as listed below, for the carbon steel material proposed as an alternate to the 630 stainless steel hoist/tie-down rings currently specified in Rev. 6 of the SAR, Rev. H of Dwg. R36000, and Rev. D of Dwg. R360-USER; update the SAR and drawings to reflect the requested information:
(a) Justify the categorization of the hoist/tie-down rings (and other devices employed for the same purposes) as not-important-to-safety (NITS).
(b) Provide material specifications and properties including yield strength, tensile strength, and ductility values over the range of operating temperatures.
(c) Confirm that, by employing the alternate carbon steel material, the factors of safety for lifting and transport loads are not reduced from what is currently presented in the SAR for the original stainless steel ring material.
(d) Confirm that the alternate carbon steel material for the hoist/tie-down rings is not susceptible to brittle fracture during cold conditions of transport.
(e) Describe any coatings or other methods used to mitigate the potential for galvanic or environmental corrosion of the alternate carbon steel hoist/tie-down rings. Describe the maintenance program revisions that address pre-shipment inspection methods and acceptance criteria for the alternate carbon steel rings.
Enclosure
The staff notes that per the guidance in Table 5 of NUREG/CR-6407, lifting and tie-down components for Type B (special form) transportation packages are important-to-safety (ITS) Classification Category B. Furthermore, the staff notes that the hoist/tie-down devices are not currently included in the ITS grouping for the package shown in SAR Table 3.2a.
The staff was unable to locate identification of the material standards or properties associated with the 630 stainless steel or the proposed carbon steel hoist/tie-down rings in the SAR. The only material identification of the hoist ring as 630 stainless steel was found in Table 3.1 of the Technical Reports 226 and 227 attached to the SAR. The omission of material specifications for package components on engineering drawings does not adhere to the guidance in NUREG/CR-5502, section 3.3.
A statement regarding the susceptibility of ITS materials to brittle fracture during cold conditions of transport could be found in SAR Section 2.6.2. However, as noted above, it does not appear that the hoist/tie-down devices are included in the current ITS component grouping.
A statement regarding the galvanic reaction potential between materials could be found in SAR Section 2.2.2. However, this section refers to the contents of Table 2.2a which does not currently include the hoist/tie-down devices. The possibility of environmental corrosion of carbon steel is greater than that of galvanic reaction, however staff was unable to locate any coating or other corrosion protection measures for the rings in the SAR. Furthermore, no pre-shipment inspection requirements appear to have been added in the SAR for the carbon steel rings.
This information is necessary to demonstrate compliance with Title 10 of the Code of Federal Regulations (10 CFR), Parts 71.43(d), 71.45(a) and 71.45(b).
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- via email OFFICE NMSS/DFM/STLB NMSS/DFM/STLB NMSS/DFM/MSB* NMSS/DFM/MSB NAME NDevaser ND SFigueroa SF JSmith JS TBoyce TB DATE Jan 4, 2023 Jan 4, 2023 Jan 4, 2023 Jan 10, 2023 OFFICE NMSS/DFM/STLB NMSS/DFM/STLB NAME YDiaz-Sanabria YD NDevaser ND DATE Jan 11, 2023 Jan 11, 2023