ML23108A131
| ML23108A131 | |
| Person / Time | |
|---|---|
| Site: | 07109371 |
| Issue date: | 04/21/2023 |
| From: | Storage and Transportation Licensing Branch |
| To: | QSA Global |
| Shared Package | |
| ML23108A127 | List: |
| References | |
| EPID L-2022-RNW-0023, CoC No. 9371, Rev. 4 | |
| Download: ML23108A131 (1) | |
Text
SAFETY EVALUATION REPORT
Docket No. 71-9371 Model No. 360 Series Package Certificate of Compliance No. 9371 Revision 4 GENERAL EVALUATION
By application dated August 29, 2022 (Agencywide Documents Access and Management System {ADAMS} Accession No. ML22251A097), as supplemented on March 22, 2023, March 29, 2023, and March 31, 2023 (ADAMS Accession Nos. ML23086C020, ML23090A172, and ML23095A068, respectively), QSA Global, Inc. requested an amendment to and renewal of Certificate of Compliance No. 9371, for the Model No. 360 Series package. Changes made to the enclosed certificate are indicated by vertical lines in the margin.
Following staff review of changes made to the associated safety analysis report (SAR), the staff finds that they do not affect the ability of the package to meet the requirements of title 10 of the Code of Federal Regulations (10 CFR) Part 71.
Packaging Drawings
The applicant submitted two revised drawings:
R36000, Rev. K (Sheets 1-10) Model 360 Transport Package
R360-USER, Rev. F (Sheets 1-2) Model 360 Transport Package
EVALUATION
The staff has reviewed the revised SAR and have determined that the changes have no impact on the packaging design, structural integrity, or safety functions. Therefore, the staff determined that the changes are acceptable.
The staff finds that the changes do not affect the ability of the package to meet the requirements of 10 CFR part 71.
Description of Structural Design
The applicant has proposed removal of the package hoist/tie-down rings, which are currently employed during package lifting as well as tie-down during transport. Therefore, the applicant is proposing sole reliance on the package grip brackets for lifting and tie-down operations. The proposed changes are reflected in revision 7 of the SAR and are illustrated in section 1.3.1 (drawing R36000, Rev. K) and 1.3.2 (drawing R360-USER, revision F). The drawings in SAR sections 1.3.1 and 1.3.2 are also proposed to be revised to indicate the material for the attachment hardware associated for the grip brackets.
The applicant has also proposed an alternate material of nylon-coated carbon steel (from the original stainless steel) for the optional cable assembly on the source securing mechanism shown in SAR figure 1.2L and section 1.3.1 (drawing R36000).
2
Hoist/tie-down rings
The hoist/tie-down rings and their associated hardware are removed from the package drawings and the body of the SAR. Staff notes that the hoist rings are still presented in the lifting evaluation presented in section 2.12.5 of the SAR, as the applicant determined that it should remain as legacy documentation.
Grip brackets
The materials of the grip brackets and their associated hardware are added to SAR table 3.2a, Materials of Components Important to Safety as they are employed as lifting and tie-down for this Type B Special Form transportation package, and as such, are identified as Category B package components per NUREG/CR-6407, Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety. The materials of the grip brackets and their associated hardware presented in sections 1.3.1 and tables 2.2a and 3.2a. Staff reviewed these SAR sections and concludes that the materials meet the requirements of 10 CFR 71.43(d) as well as not being susceptible to brittle failure at the cold environmental operating conditions required per 10 CFR 71.71(c)(2).
The structural evaluation of the grip brackets as lifting devices is presented in SAR section 2.12.5, while their evaluation for tie-down purposes is presented in revised SAR section 2.12.6. Staff reviewed the lifting evaluation for the grip brackets employed in tandem and determined that they are capable of withstanding the required loading, considering the factor of safety of three (3), without exceeding the material yield strength. The staff reviewed the tie-down evaluation for the grip brackets, and determined that, based on the tie-down configuration in SAR Figure 3.3, they are capable of withstanding the required loading without exceeding the material yield strength. Therefore, staff determined that the lifting and tie-down requirements of 10 CFR 71.45 are satisfied.
Cable assembly
The optional cable assembly of the source securing mechanism attaches to the top of the cap cover and is anchored to a lower part of the mechanism assembly, allowing easy retrieval of the cap cover once it is removed. The staff determines that the applicants proposed alternate material change to nylon-coated carbon steel is acceptable because the cable assembly is optional and serves no safety function for meeting 10 CFR Part 71.
Evaluation Findings
The staff reviewed the proposed changes summarized above and has the following findings:
Drawings submitted with the application provide a sufficiently detailed description of the structural and material properties of the package that meets the requirements of 10 CFR 71.33.
The staff has reviewed the package and concludes that the applicant has met the requirements of 10 CFR 71.43(d) for materials that exhibit no chemical or galvanic reaction with other packaging components or contents, as well as materials that exhibit no degradation when irradiated.
Enclosure 2 3
The staff has reviewed the lifting and tie-down systems for the package and concludes that they satisfy the material yield strength limitation requirements of 10 CFR 71.45(a) for lifting and 10 CFR 71.45(b) for tie-down.
The staff reviewed the material performance of the packaging under the normal conditions of transport required by 10 CFR 71.71(c)(2) and concludes that there will be no substantial reduction in the effectiveness of the packaging such that it satisfies the requirements of 10 CFR 71.51(a)(1) for a Type B package.
Based on review of the statements and representations in the application, the NRC staff concludes that the package has been adequately described and evaluated to demonstrate that it satisfies the structural and material integrity requirements of 10 CFR Part 71.
CONDITIONS
In addition to small editorial changes to the certificate, the following changes have been made:
Condition No. 5(a)(2), Description, was revised to reflect updated dimensions resulting from the removal of the hoist rings in the package description.
Condition No. 5(a)(3), Drawings, was updated to reflect the latest revisions of drawing Nos.
R36000, Revision K (Sheets 1 - 10), Model 360 Transport Package, and R360-USER, Revision F (Sheets 1 - 2), Model 360 Transport Package.
Condition No. 5(b)(1), Contents, was edited to correct a typo.
Condition No. 6 has been edited to add an element to the condition identifying a reference containing details of lifting and tie-down procedures for the user of the package found in QSA Global, Inc. Service Bulletin SB-19 Revision March 2023.
Condition No. 8 has been edited to specify the termination date of the previous revision of the certificate (Revision 3).
Condition No. 9 has been revised to reflect a new expiration date of August 31, 2028.
The application date for this amendment was added to the REFERENCES section.
CONCLUSION
Based on the statements and representations in the application and the conditions listed above, the staff concludes that the Model No. 360 package design has been adequately described and evaluated, and that these changes do not affect the ability of the package to meet the requirements of 10 CFR Part 71.
Issued with Certificate of Compliance No. 9371, Revision No. 4.
Enclosure 2
ML23108A127; ML23108A131 OFFICE NMSS/DFM/STLB NMSS/DFM/MSB NSIR/DSO/SOSB NMSS/DFM/MSB NAME NDevaser ND JSmith JS JCurry JC TBoyce PKoch for PK DATE Apr 18, 2023 Apr 19, 2023 Apr 19, 2023 Apr 20, 2023 OFFICE NMSS/DFM/STLB NAME YDiaz-Sanabria BWhite for BW DATE Apr 21, 2023