ML23143A184
| ML23143A184 | |
| Person / Time | |
|---|---|
| Site: | 07109365 |
| Issue date: | 05/19/2023 |
| From: | Shakhatreh A Robatel Technologies |
| To: | Division of Fuel Management |
| Shared Package | |
| ML23143A177 | List: |
| References | |
| Download: ML23143A184 (1) | |
Text
Page 1 of 2 May 19, 2023 2021-035-SCL-02 ATTN: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Amendment request for the Certificate of Compliance No. 9365 and Revision of the Safety Analysis Report for the RT-100 Package Need by Date: 06/30/2023
Reference:
RT-100, Certificate No. 9365 USA/9365/B(U)-96 Docket No. 71-9365 Document Control Desk,
Dear Sir or Madam:
Pursuant to 10 CFR 71.38, Robatel Technologies, LLC hereby submits its Safety Analysis Report (SAR)
Revision 9, to address the Requests for Additional Information (RAIs) letter dated February 27, 2023 to amend the Certificate of Compliance No. 9365 Revision 2. We have attached a table summarizing the changes in SAR Revision 9. These changes incorporate additional calculations to address the RAIs.
This license amendment supports decommissioning nuclear power plants, such as Indian Point Energy Center, Oyster Creek, Palisades, Pilgrim, Vermont Yankee, and Crystal River via the safe and efficient transport of activated reactor vessel internals. The amendment would help maintain decommissioning workforce dose as low as reasonably achievable (ALARA) through the creation of larger segments requiring less cutting and loading of fewer packages, and by reducing the number of truck shipments of Class 7 material, reduce risk to the public. In particular, the amendment will support efficient shipments of segments of large cylindrically shaped components as well as smaller components that satisfy the specific activity requirements for definition of LSA-II material per 49 CFR 173.403 that either individually or as a packaged group of segments/components, have 3m dose rates that exceed the 1R/hr limit at 3m of 49 CFR 173.427(a)(1) thereby necessitating shipment in a Type B package.
Below is a high-level summary of the major changes in each Chapter. All changes are marked with revision bars and summarized on the Record of Revisions_RT-100 SAR REV 9 that is attached to this cover letter.
- Chapter 1 - Editorial change in Section 1 to revise the SAR revision from 8 to 9.
- Chapter 2 - Changes to this chapter are limited to Appendix 2.13 (Closure Bolt Evaluation) and Appendix 2.16, more specifically the following changes were incorporated into the SAR, Revision 9,
o Revised Sections 2.13.2.2.2 and 2.13.2.2.4 (HAC Fire Temperature Loads) using temperatures provided in the SAR table 3.1.3-3 to demonstrate the most unfavorable primary and secondary lid bolt stresses.
o Revised Sections 2.13.2.3.1 and 2.13.2.3.2 (Bolt Preloads) to add the minimum preload and torsional moment calculations for the primary and secondary lid bolts.
o Added Section 2.13.2.8 (Vibration-induced Loads) to include the vibration-induced loads for the primary and secondary lid bolts that were previously submitted in Robatels RSI response letter dated November 22, 2022 (ADAMS Accession No. ML22335A081).
5115 Bernard Drive
- Suite 304
- Roanoke, VA 24018 540-989-2878 www.robateltech.com
Page 2 of 2 o Revised Section 2.13.3 (Load Combinations) to correct numerous load values and the headers of tables 2.13.3-1 and 2.13.3-2, add vibration-induced loads, and make minor editorial changes in Sections 2.13 and 2.13.3.1.
o Added Section 2.13.4 (Fatigue Analysis) to include the fatigue analysis in accordance with the methods presented in Table 6.2 of NUREG/CR-6007 based on the procedures provided in ASME Section III NB-3222.4(e) and NB-3232.3 for the primary and secondary lid bolts. Additionally, Appendix 2.16 was added to reference the design fatigue curves for high strength steel bolting.
- Chapter 8 - Revised 8.2.3.2 to mandate replacing the primary and secondary lid bolts after 500 cycles. This requirement is based on the fatigue analysis presented in Section 2.13.4 of the SAR.
Some of the content of the Safety Analysis Report is Robatels proprietary and trade secret information.
The exact details and references are made in the attached affidavit related to this submittal.
Should you or members of your staff have any questions about this submittal, please contact me at ashakhatreh@robateltech.com or Jared Bower at jbower@robateltech.com.
Thank you for your attention to this submittal.
Respectfully, Abdulsalam Shakhatreh Engineering Manager Robatel Technologies, LLC ashakhatreh@robateltech.com Attachments:
- 1) Affidavit_RT-100 SAR REV 9, concerning confidential information and trade secrets
- 2) Record of Revisions_RT-100 SAR REV 9
Enclosures:
- 1) RT-100 Safety Analysis Report Rev 9 (PROPRIETARY), Dated May 19, 2023.
- 2) RT-100 Safety Analysis Report Rev 9 (Non-PROPRIETARY), Dated May 19, 2023.
5115 Bernard Drive
- Suite 304
- Roanoke, VA 24018 540-989-2878 www.robateltech.com