ML23066A293
| ML23066A293 | |
| Person / Time | |
|---|---|
| Site: | 07109371 |
| Issue date: | 03/10/2023 |
| From: | Nishka Devaser Storage and Transportation Licensing Branch |
| To: | Flanigan M QSA Global |
| References | |
| EPID L-2022-RNW-0023 | |
| Download: ML23066A293 (1) | |
Text
Mary Flanigan Senior Regulatory Affairs Specialist Regulatory Affairs Department QSA Global, Inc.
40 North Avenue Burlington, MA 01803
SUBJECT:
APPLICATION FOR RENEWAL 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 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, 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-RNW-0023
Enclosure:
Request for Additional Information March 10, 2023 Signed by Devaser, Nishka on 03/10/23
Enclosure Request for Additional Information QSA Global Docket No. 71-9371 Certificate of Compliance No. 9371 360 Series Transportation Package Renewal By application dated August 29, 2022 (Agencywide Documents Access and Management System 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 justification for the appropriate important to safety (ITS) classification of the following package components used for lifting/hoist and tie-down: rings, grip brackets and associated connection hardware.
Update the QSA Global, Inc. Model 360 SAR content as necessary based on the justification:
(a)
Update SAR tables 2.2a and 3.2a to include these package components and their material properties, including the standard, grade and heat treatment temperature, as applicable.
(b)
Update drawings in SAR section 1.3 to reflect these package components material standard, grade and heat treatment temperature, as applicable.
(c)
Review these package component materials for chemical or galvanic reaction potential, radiation degradation, and brittle fracture susceptibility and update applicable SAR sections to address these evaluation results, as required.
The staff notes that per the guidance in section 5.4.2 and table 5 of NUREG/CR-6407, Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety, lifting and tie-down components and their associated hardware for Type B (special form) transportation packages are ITS Classification Category B. SAR section 2.3.1 states that the Model 360 package components are procured, manufactured and inspected per the QSA Global, Inc. quality insurance program which is based on the classification guidance of NUREG/CR-6407. Section 3 of NUREG/CR-6407 explains that the transportation package items determined to be ITS are
2 classified as Category A, B or C, allowing a graded approach to quality.
Technical Report Nos. 226 and 227 of the SAR evaluate the structural capacity of the rings, grip brackets and associated hardware as serving both lifting and tie-down functions for the Model 360 package.
The staff was unable to locate identification of the material standards or properties associated with the 630 stainless steel lifting and tie-down rings evaluated in Technical Report Nos. 226 and 227 of the SAR. The tabulated entry for the hoist ring on sheet 1 of drawing R36000 does not identify the stainless-steel material standard, grade or heat treatment temperature. The omission of material specifications for package components on engineering drawings does not adhere to the guidance in section 3.3 of NUREG/CR-5502, Engineering Drawings for Title 10 of the Code of Federal Regulations (10 CFR), Part 71 Package Approvals.
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 lifting and tie-down devices and their associated hardware.
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, the lifting and tie-down devices are currently not identified as ITS in table 3.2a.
Specifically, the 630 stainless steel employed for the lifting and tie-down rings must be addressed, as some heat treatments may be more susceptible to cold-temperature embrittlement than others.
This information is necessary to demonstrate compliance with 10 CFR Parts 71.33(a)(5)(iv), 71.43(d), 71.45(a), 71.45(b) and 71.107.
Ltr ML23066A293 OFFICE NMSS/DFM/STLB NMSS/DFM/STLB NMSS/DFM/MSB NMSS/DFM/MSB NAME NDevaser WWheatley JGoodridge for JSmith TBoyce DATE Mar 8, 2023 Mar 9, 2023 Mar 9, 2023 Mar 10, 2023 OFFICE NMSS/DFM/STLB NMSS/DFM/STLB NAME YDiaz-Sanabria NDevaser DATE Mar 10, 2023 Mar 10, 2023