ML23113A003
| ML23113A003 | |
| Person / Time | |
|---|---|
| Site: | 07103097 |
| Issue date: | 05/02/2023 |
| From: | Garcia-Santos N Storage and Transportation Licensing Branch |
| To: | Boyle R US Dept of Transportation, Office of Hazardous Materials Safety |
| Shared Package | |
| ML23118A121 | List: |
| References | |
| EPID L-2022-DOT-0008 | |
| Download: ML23113A003 (3) | |
Text
May 2, 2023 Richard W. Boyle, Chief Sciences Branch Division of Engineering and Research Office of Hazardous Materials Safety U.S. Department of Transportation 1200 New Jersey Ave., S.E.
Washington, D.C. 20590
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR REVIEW OF THE CERTIFICATE OF COMPLIANCE NO. 3097, MODEL NO. FCC-4 (EPID L-2022-DOT-0008)
Dear Richard W. Boyle:
By letter dated August 18, 2023 (Agencywide Documents Access and Management System
{ADAMS} Accession Number ML22277A733), and supplemented on January 26, 2023 (ML23026A302), you submitted an application to the U.S. Nuclear Regulatory Commission (NRC) for the review of the Certificate of Competent Authority No. F/348/AF-96, Revision Gw, Model No. FCC-4. In your application you requested that the NRC provide a recommendation to revalidate the Model No. FCC-4 package.
In connection with our review, we need the information identified in the enclosure to this letter.
To assist us in scheduling the staff review of your response, we request that you provide this information by 30 days from the date of this letter. Inform us at your earliest convenience, but no later than 15 days from the date of this letter, if you are not able to provide the information by that date. If you are unable to provide a response in the requested time, our review may be delayed.
Please reference Docket No. 71-3097 and EPID L-2022-DOT-0008 in future correspondence related to this request. The staff is available to meet to discuss your proposed responses. If you have any questions regarding this matter, I may be contacted at Norma.GarciaSantos@nrc.gov.
Sincerely, Signed by Garcia Santos, Norma on 05/02/23 Norma Garcia Santos, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-3097 EPID L-2022-DOT-0008
Enclosure:
Request for Additional Information
Request for Additional Information U.S. Department of Transportation French Approval Certificate No. F/348/AF-96, Revision Gw Docket No. 71-3097 Certificate of Compliance No. 3097 Model No. FCC-4 By letter dated August 18, 2023 (Agencywide Documents Access and Management System
{ADAMS} Accession Number ML22277A733), and supplemented on January 26, 2023 (ML23026A302), you submitted an application to the U.S. Nuclear Regulatory Commission (NRC) for the review of the Certificate of Competent Authority No. F/348/AF-96, Revision Gw, Model No. FCC-4. In your application you requested that the NRC provides a recommendation to revalidate the Model No. FCC-4 package.
This request for additional information (RAI) identifies information needed by the NRC staff (the staff) in connection with its review of the application. The staff used International Atomic Energy Agency (IAEA) Specific Safety Requirements No. 6 (SSR-6), Regulations for the Safe Transport of Radioactive Material, 2018 Edition, in its review of the application.
The RAI describes information needed by the staff to complete its review of the application and to determine whether the applicant has demonstrated compliance with the regulatory requirements of the IAEA SSR-6, 2018 Edition.
STRUCTURAL EVALUATION RAI-St-1 Provide the calculation package, FCC4 - Containers for fresh fuel assemblies -
Lifting points mechanical verification (Document No. D02-ARV-01-186-617 EN, Index A).
In Appendix 2.1-4 of the safety analysis report (SAR) (Document No. DOS 021166-012, Version 1.0) for the Model No. FCC-4 package, the applicant noted that the results of the structural analysis lifting under routine conditions of transport are provided in the calculation package, FCC4 - Containers for fresh fuel assemblies - Lifting points mechanical verification, (Document No. D02-ARV-01-186-617 EN, Index A). However, the applicant did not provide the calculation package, which is a proprietary version. The calculation package is needed for completing the review.
This information is necessary to demonstrate compliance with the requirements of paragraphs in paragraphs 503(a) and 609 of IAEA SSR-6, Revision 1, 2018 Edition.
Enclosure
RAI-St-2 Provide the technical justifications of the applicability of proposed criteria to other materials for cladding including the following information:
- a. Explain whether the proposed five criteria are only applicable to those materials (Zirconium alloy, possibly pre-oxidized and possibly chromium-plated) specified in the French Competent Authority Certificate (FCAC).
- b. If the applicant is proposing the criteria beyond the cladding materials specified the CAC to any other materials, provide technical justifications of the applicability of the proposed criteria in the CAC to other possible cladding materials to be transported in the Model No. FCC-4 with different chemical compositions.
- c. Provide the materials and corresponding description of the specimens (i.e, Duplex, PCA-2b and Zr1Nb) used in the tests for the cladding materials.
- d. Provide a detailed description of the cladding materials that the applicant requested approval for to the French Competent Authority. The FCAC is not specific on the charactreristics of the cladding In section 5.2, Cladding Material, of Appendix 2.1-6, Transportation in FCC Container Mechanical Aspects Related to a Change in the Fuel Assembly Material (Identification: FFDC04223-EN, Revision 4.0), of the SAR, the applicant noted that any material is acceptable for cladding if the strength parameters (i.e., yield stress, ultimate stress, and total elongation) of a material meet one of the five criteria provided in the table. The NRC staff understands that those five criteria were developed based on the tests on the different specimens (e.g.,
Zircaloy-4, Duplex, PCA-2b, Zr1Nb, uncoated Zy4, M5, etc.).
However, it is not clear if the proposed five criteria only apply to the materials specified in the French Competent Authority Certificate (FCAC) or more specifically to the materials included in the table in section 5.2 of the SAR. Also, the staff needs clarification information related to the tests performed on cladding materials as well as materials characteristics to adequately assess the performance of the materials during expected conditions This information is necessary to demonstrate compliance with the requirements of paragraphs 648 and 726 of IAEA SSR-6, Revision 1, 2018 Edition.
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