ML23136B167

Letter from Richard W. Boyle (DOT) to Norma Garcia Santos, Response to the Request for Additional Information for the Revalidation of Japanese Certificate of Approval J/2043/B(U)F for the Model No. JRF-90Y-950K Package, Docket 71-3036

ML23136B167
Person / Time
Site:	07103036
Issue date:	05/11/2023
From:	Boyle R US Dept of Transportation (DOT), Office of Hazardous Materials Safety
To:	Garcia-Santos N Storage and Transportation Licensing Branch
Garcia-Santos N
Shared Package
ML23136B145	List: ML23136B167 ML23136B168
References
EPID L-2023-DOT-0000, CAC 001794, J/2043/B(U)F
Download: ML23136B167 (6)

Text

U.S. Department East Building, PHH-23 of Transportation 1200 New Jersey Avenue SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration May 11, 2023 Norma Garcia Santos, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards (NMSS)

U.S. Nuclear Regulatory Commission 11545 Rockville Pike Rockville, MD 20852-2738

Dear Ms. Garcia Santos:

In accordance with the Memorandum of Understanding between our agencies, on January 5, 2023 I requested that you review the Japanese Certificate of Approval No. J/2043/B(U)F for the JRF-90Y-950K transport package and make a recommendation concerning our revalidation of the package for import and export use. On May 1, 2023, you sent a Request for Additional Information (RAI) regarding this review.

Our applicants response to your RAI was received and has been electronically transmitted to you and your staff and is attached to this correspondence.

If you have any questions or need any additional safety information, please feel free to contact me at (202) 697-1301 or via email at rick.boyle@dot.gov.

Sincerely, Richard W. Boyle, Radioactive Materials Division of Sciences and Engineering Office of Hazardous Materials Safety Enclosure RICHARD BOYLE Digitally signed by RICHARD BOYLE Date: 2023.05.11 14:14:55

-04'00'

Request for Additional Information U.S. Department of Transportation Japanese Approval Certificate No. J/2043/B(U)F, Revision 2 Docket No. 71-3036 Certificate of Compliance No. 3036 Model No. JRF-90Y-950K By letter dated January 5, 2023 (Agencywide Documents Access and Management System

[ADAMS] Accession Number ML23006A104) and supplemented on March 2, 2023 (ML23061A186),

you submitted an application to the U.S. Nuclear Regulatory Commission (NRC) for the review of the Certificate of Competent Authority No. J/2043/B(U), Model No. JRF-90Y-950K. In your application you requested that the NRC provides a recommendation to revalidate the Model No.

JRF-90Y-950K 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.

Materials Evaluation RAI 7-1. Provide details on how the heat insulator (hard polyurethane foam) and shock absorber (balsa wood) are considered to be in a sealed state (e.g., encased in welded stainless steel), such that the materials are adequately protected from damage due to moisture or water intrusion. If the polyurethane foam and wood are not permanently sealed, please address how these materials are inspected for water damage and repaired/replaced, as needed, since both are susceptible to degradation over time when exposed to moisture or water intrusion. Also, Revise the SAR with additional details to remove the ambiguity.

JAEA Official Response The heat insulator (hard polyurethane foam) and shock absorber (balsa wood) are encased in the outer shell body and lid (welded stainless steel plate) as shown below. In addition, fusible(melting) plugs (solder, stainless steel) are attached to the outer shell body and lid. The fusible(melting) plugs are for venting gas in case of fire and are not to be removed during normal operation, so that moisture and water cannot enter the container.

The main body, outer shell lid, and fusible(melting) plugs are inspected prior to shipping (prior to transportation) as described in (III)-A-1 to 4 to check for any abnormalities. The scope of the visual inspection includes the main body, inner shell lid, and outer lid, and the appearance of the balsa wood and the component (stainless steel) that contains the polyurethane foam inside is inspected.

<()-C-6>

2.1 Main body (Refer to ()-Fig. C.6)

The main body is cylindrical in shape with 1,559mm in height and 840mm in outer diameter and consists of the outer shell and inner shell.

The outer shell consists of 3mm thick stainless steel and 6mm thick stainless steel at the bottom.

The inner shell consists of 10mm thick stainless steel and 35mm thick stainless steel at the bottom.

The shell and bottom plate are welded completely. The space between the outer and inner shells, heat insulators and shock absorbers are applied to reduce the heat gain caused by fire and to absorb impact energy caused by drop. At the upper side of the main body, the eye-plates are welded at 4 places to lift the packaging.

Eight fusible(melting) plugs are provided on the outer shell. These plugs are provided to avoid the pressure raise by steam or gas generated from the heat insulator and shock absorber due to heat during fire.

<()-C.8>

2.4 Outer lid (Refer to ()-Fig. C.9)

The outer lid is cylindrical in shape with 398mm in height and 840mm in outer diameter.

The outer cover plate consists of 3mm thick stainless steel shell and 6mm thick stainless steel upper plate. The inner cover plate consists of 3mm thick stainless steels.

The space between the outer and inner cover plates, the heat insulators and shock absorbers are applied to reduce the heat gain caused by fire and to absorb impact energy caused by drop.

4 eye-bolt bosses for lifting are welded to the outer lid. 4 fusible(melting) plugs are provided on the outer cover plate. These plugs are used to avoid the pressure raise by steam or gas generated from the heat insulator and shock absorber due to heat during fire.

The staff is unclear if the polyurethane foam and wood materials are sealed in the main body and the outer lid only when the package is sealed closed for transportation, or if both the main body and the outer lid provide independent sealed compartments even when the outer lid is not installed on the main body.

JAEA Official Response Both the body and the outer lid provide independent sealed compartments even when the outer lid is not attached to the body. In the drawings below, all outside lines indicate stainless steel; polyurethane foam and wood materials are inside this.

()-C-10: Main Body (Refer to ()-Fig. C. 6.)

()-C-13: Outer shell lid (Refer to ()-Fig. C. 9.)

If both these materials are only considered to be in a sealed state when the outer lid is installed on the main body, how are the polyurethane foam and wood materials visually inspected and repaired/replaced if damage is found? Visual inspection requirements in Section III-Table A.1 for pre-shipment inspection, and Section (III) B for maintenance requirements only mention visual inspection of inner and outer surfaces of the main body, fuel basket, inner lid and outer lid.

JAEA Official Response From the above response, both the body and the outer lid provide independent hermetic compartments even when the outer lid is not attached to the body. Therefore, the visual inspection requirement in (III)-

B-1 inspects the inner stainless steel (and some solder).

Revise the SAR with additional details to remove the ambiguity. This information is needed to determine compliance with SSR-6 2018 Edition, paragraphs 613A and 809(f).

Enclosure Observations Observation 7-1 In SAR Section (III)-A package handling methods, on Page (III)-A-1 and Page (III)-A-2, the pre-shipment content inspection is referenced to be in section (IV)-A.2 and (IV)-Table A.1.

However, the pre-shipment inspection of the package is found on Page (III)-A-3 under (III) Table A.1.

JAEA Official Response This appropriate advice is correct, and the sentences on the SAR was incorrect.

Therefore, we amended them as below; Page 596 :

Incorrect : (IV)-A.2 Correct : ()-A. 2.

Page 597 :

Incorrect : (IV)-Table A. 1 Correct : ()-Table A. 1