ML23163A231

Tn Americas LLC, Letter of Authorization to Supplement NRC Certificate of Compliance, 9291, Revision 11

ML23163A231
Person / Time
Site:	07109291
Issue date:	06/12/2023
From:	Shaw D TN Americas LLC
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
Shared Package
ML23163A230	List: ML23163A231
References
E-62416
Download: ML23163A231 (1)

Text

orano June 12, 2023 E-62416 Orano TN 7160 Riverwood Drive Director, Division of Fuel Management Suite 200 Office of Nuclear Material Safety and Safeguards Columbia, MD 21046 U.S. Nuclear Regulatory Commission USA Two White Flint North - Mail Stop 4 B34 Tel: 410-910-6900 Fax: 434-260-8480 11555 Rockville Pike Rockville, MD 20852-2738

Subject:

Letter of Authorization to Supplement NRC Certificate of Compliance, 9291, Revision 11 TN Americas LLC (TN) is making this submission of an application to request approval to allow use of the Model No. Liqui-Rad (LR) Transport Unit Package with a change to the operating procedure included by reference in Certificate of Compliance (CoC), USA/9291/B(U)F-96, Revision 11. 10 CFR Part 71, Subpart DApplication for Package Approval, §71.39 Requirement for additional information allows conditions in a CoC to be modified. This application requests NRC approval to modify operating instructions by issuing a letter authorization to allow package users to continue using specific packages identified by serial number for a defined timeframe that meet the modified inspection criteria for inspections before each shipment.

Review of the application is urgently needed to allow continued use of the LR package for shipping low-enriched uranium (LEU) products to Westinghouse Columbia for conversion to products used for reactor fuel fabrication. The transport of the LEU for the Department of Energys National Nuclear Security Administration (NNSA) allows down-blending of highly enriched uranium (HEU) for national security purposes.

There are no other approved packages to ship this LEU material.

The application consists of a description of the requested change in the operating procedure as Enclosure 1, sections of the LR safety analysis report (SAR) that are relevant to the request as Enclosure 2, a copy of the detailed written instructions for inspection of the LR as Enclosure 3, and evidence of inspections done to identify LR packages that meet criteria for continued use as Enclosure 4. Both Enclosure 3 and Enclosure 4 are marked as Proprietary Information, and a request to withhold this information from public disclosure is provided by affidavit as Enclosure 5. Certain SAR information in Enclosure 2 is marked as security-related and requested to be withheld. Accordingly, a public version of Enclosure 2 is provided as Enclosure 6.

Because Enclosures 3 and 4 are entirely proprietary, no public versions are provided.

Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.

E-62416 Document Control Desk Page 2 of 2 Should the NRC staff require additional information to support review of this application, please contact Peter Vescovi at 336-420-8325, or by email at peter.vescovi@orano.group.

Sincerely, Digitally signed by Don Don Shaw Shaw Date: 2023.06.12 11:11:44

-04'00' Don Shaw Licensing Manager TN Americas LLC

Enclosures:

1. Description of Change - Letter Authorization Approval for LR Transport Unit

2. SAR pages (Security-Related Version)

3. SR16907 Special Routing

4. SR16907 Form TAF-502-1

5. SAR pages (Public Version)

6. Affidavit cc: Pierre Saverot, U.S. Nuclear Regulatory Commission Jean-Luc Palayer, TN Americas LLC Jay Thomas, TN Americas LLC Peter Vescovi, TN Americas LLC Wes Stilwell, Westinghouse Mike Frassica, Westinghouse Tanya Sloma-DeLosier, Westinghouse Matt Walker, BWX Technologies Jason Walker, BWX Technologies

Enclosure 1 to E-62416 Description of Change - Letter Authorization Approval for LR Transport Unit

1.0 DESCRIPTION

OF NONCONFORMANCE 1.1 Summary of Nonconforming Condition During an NRC inspection of Part 71 transportation activities at a facility where the Liqui-Rad Transport Unit Package (LR) is being used by an NRC licensee, corrosion was observed on the exterior surface of the LR packages.

The LR is being used by licensees who maintain a copy of the operating controls and procedures as approved by the NRC Certificate of Compliance number 9291 (Ref. 1) that incorporates-by-reference the pre-loading inspection in the LR Safety Analysis Report (SAR)

Chapter 7 - Operating Procedures.

7.1.1 Pre-loading inspection

a. Inspect the LR exterior for visible flaws. Visually inspect all accessible welds for cracks or corrosion. The exterior welds should be free of cracks, and the exterior surface should not be torn or substantially crushed (more than 2 inches of crush depth).

If the exterior surface is torn or substantially crushed, or if cracks or corrosion are discovered, the unit should not be used.

The licensee using the package is expected to issue more-detailed facility procedures that includes the essential elements of the SAR operating procedures. NUREG-2216, Chapter 8-Operating Procedures Evaluation describes information that should be presented in the application, and NUREG/CR-4775, Guide for Preparing Operating Procedures for Shipping Packages, describes information that should appear in the package users more-detailed operating procedures.

Requirements for pre-loading inspection in the LR SAR lack sufficient detail for the package user to specify acceptance criteria for corrosion observed on the exterior of packages in more-detailed operating procedures. An engineering evaluation has been done to establish acceptance criteria for corrosion observed during pre-loading inspection. LR packages meeting the visual inspection standards used for pre-loading inspection may continue to be used.

1.2 Demonstration of Compliance with Part 71 The intent of pre-loading inspection requirements is to demonstrate compliance in part with a provision in Subpart G, Operating Controls and Procedures, specified as:

§ 71.87 Routine determinations.

Before each shipment of licensed material, the licensee shall ensure that the package with its contents satisfies the applicable requirements of this part and of the license. The licensee shall determine that (b) The package is in unimpaired physical condition except for superficial defects such as marks or dents.

Inspections required by SAR Chapter 7 - Operating Procedures, Sections 7.1.1 Pre-loading inspection are provided to demonstrate compliance with § 71.87 Routine determinations.

Page 1 of 7

Enclosure 1 to E-62416 In addition to the routine inspections prior to loading the LR package, the package owner is expected to inspect and maintain the packaging using guidelines provided in SAR Chapter 8 -

Acceptance and Maintenance Programs, Section 8.2 Maintenance Programs. Periodic inspection includes a visual check for corrosion, pitting or scaling. Typical conditions for discontinued use include through-the-thickness corrosion, weld cracks through a structural member, or damage to the extent that adequate thermal or impact protection of the containment vessel is no longer provided by the packaging.

8.2 Maintenance Programs The user shall establish written procedures for the annual maintenance and inspection of each LR requiring the following as a minimum.

a. Inspect the LR exterior for visible flaws. Visually inspect all accessible welds for cracks or corrosion. The exterior welds should be free of cracks, and the exterior surface should not be torn or substantially crushed (more than 2 inches of crush depth). If the exterior surface is torn or substantially crushed or cracks are discovered, the unit should be repaired by the owner and re-certified for use. The user may remove light surface corrosion by polishing as required. If the corrosion is not easily removed or if pitting or scaling is observed, the unit should be repaired by the owner and re-certified for use.

Package users are expected to have more detailed written instructions for annual maintenance and inspections for the LR packages and maintain a record of the inspection results.

1.3 Proposed Changes to Inspection Criteria The SAR did not include a detailed enough rationale for corrosion acceptance criteria for corrosion discovered on the exterior of the package during routine operations and periodic maintenance. Some degree of corrosion is expected on a package with carbon steel structural components due to scratches or wear through the protective painted coating from routine use.

The following change to the pre-loading inspection is proposed to allow for corrosion on the external structure of the packaging.

Pre-loading inspection Inspect the LR exterior for visible flaws. Visually inspect all accessible welds for cracks or corrosion. The exterior welds should be free of cracks, and the exterior surface should not be torn or substantially crushed (more than 2 inches of crush depth). If the exterior surface is torn or substantially crushed, or if weld cracks or corrosion are discovered, the unit should not be used. Corrosion on the exterior structure of the LR package is allowed to the extent that the physical condition of the package is not impaired.

More detailed acceptance criteria for allowable corrosion are provided by an engineering evaluation that establishes visual inspection standards to ensure the physical condition of the package is not impaired. The visual standards are included in the package users more detailed written instructions for pre-loading inspection of the LR packaging.

2.0 ENGINEERING EVALUATION This evaluation compares the current state of the LR packaging with the requirements of the licensing drawing and the SAR and provides recommendations for inspection of the packaging.

Page 2 of 7

Enclosure 1 to E-62416 2.1 Component Safety Classification The exterior components of the LR packaging are carbon steel with a protective coating to prevent corrosion. These exterior components consist of a framing system and outer vessel.

The framing system is a rectangular frame constructed of steel angle and bar that is used to support the cylindrical vessel. The framing system provides attachment points for lifting and tie down of the LR package. The outer vessel is a cylindrical steel shell that encloses the foam insulation and ceramic fiber insulation. The containment boundary consists of the containment vessel, and primary and secondary lids with O-ring seals. The foam and ceramic insulation protect a containment vessel that contains the liquid radioactive material payload. There is no shielding function for the LR package components. The outer vessel, framing system and insulation provide protection for the containment system during normal conditions of transport (NCT) and hypothetical accident conditions (HAC), (Ref.1). The LR package is shown in Figure 1.

USAJ9291/B(U)F-96 TYPE 8 ua,11-IIM> (LR) TRANSPORT UNIT PACKAG(

1111SfWGHOUSl fl£CTRIC COMPANY, LLC S,Ol llUFf AOAO, HOPKINS, SC USA UN Jlll ltAOIOACTM MATIRIAl,

• Tfl'f I (VJ PACKAGE, flSSIU

~T.MEWEIGKT MA)(. IOAD(O GROSS WEIGKT 2.MIIIS l.>9HG 5,6!12 LIS 2,5161G MAX. CARGO CAPACITY 2JO GAL l70LTIIS US MTINT NO. 5,395,007 US PATINT NO. 5,595,319 Figure 1. Typical LR-230 Package Based on the function of the external carbon steel structure for tie-down, lifting, skid, forklift channel, and outer shell, these components are classified as important-to-safety Category B.

The outer shell maintains the configuration of the package in an accident condition to provide impact and thermal protections. The foam impact limiter material or ceramic thermal insulation protect the inner vessel that functions as the containment boundary for the liquid contents.

2.2 Corrosion Evaluation This assessment focuses on regions or corrosion identified on the LR-230 package during inspection and defines corrosion limits for these areas. Note 2 of the SAR drawing number LR-SAR, Liqui-Rad Transport Unit, states that the material thickness shall be within mill tolerance under appropriate material specification shown in Note 3 (Ref. 2). Corrosion allowance is established based on the tolerances allowed for thickness of specified material of construction.

Page 3 of 7

Enclosure 1 to E-62416

2. All TOLERANCES UNLESS OTHERWISE NOTED: 12" AND OVER +/-3/8" 1" UP TO 12" +/-1/8" O" UP TO 1" :1:1/16" ANGLES +/-Y MATERIAL THICKNESS SHALL BE WITHIN MILL TOLERANCE UNDER APPROPRIATE MATERIAL SPECIFICATION.

3. COMPONENT PART MATERIAL OF CONSTRUCTION CONTAINMENT VESSEL PLATE ASTM A2 40 304 316 ss HEADS ASTM A'l40 ;J04 3 16 ss PRIMARY LID *'-TM *?40 ..>u4 '316 ss I.

SECONDARY LID ASTM A240 304 316 ss VELAN HB- 20 00 BALL VALVE ss ASTM A312 304,316 SS ISTM A276 3 04131 6 SS A ~ ~ 3 B8M CLASS 2 316 SS

,. 4 B8M CLASS 2 316 SS TS u OR 18 8 SS 0 SILIC RUBBER OR VITON GLT, 70-80 DUROMETER TEST PORT CONNECTIONS 18/8 OR 300 SS (OPTION 1/2), OR ASTM

~ BRASS (OPTION 3 PN B VC0 4)

INC' 'LATION CERAMIC Al3£R BlANKET Fl- l REV. 1

• OAM i/8 FOAM REV. 0 OUTER VESSEL PLATE A A1011 OR A1008 ASTM A36 CS B **glNr. ASTM A36 ASTM A500C * ~

u~ B CS ASME SA193 CLASS 2 316 SS NUTS /WASHERS ASME SA194 CLASS 2 316 SS THREAD INSERTS 300 SERIES 8 SS LIFTING SHACKLES CSLALLOY RATED AT 6,000 LBS vnTH A SAFETY FACTOR OF 4.0 FLAT GASKET SILICONE RUBBER OR VITON Gl T, 70-80 DUROMETER VENT PLUGS PLASTIC MELT TEMP FROM 300 TO 400F our~" 1111 PLATE ASTM A1011 A1008 or *"TM A240 304/3 16 S!

CERAMIC FIBER BOARD ESP-CFl - 2 REV. 1 LID HANDLES SS RATED AT 250 LBS WITH A SAFETY FACTOR OF 4.0 VALVE .., AN HB-2000 BALL VALVE SS STUDS* ASME SA 193 BBM CLASS 2 3 16 SS NUTS/WASHERS ASME SA194 BBM CLASS 2 3 16 SS THREAD INSERTS 300 SERIES OR 18 8 SS

• ALL STUDS USE THREAD INSERTS.

2.2.1 Types of Corrosion Corrosion observed on the external structure of the package is due to carbon steel exposure to environmental conditions. The package is painted to prevent corrosion, but different types of corrosion may be visible during in-service inspections of the packaging exterior. Weld corrosion arises from variations in composition and microstructure of the material. Specific corrosion types may include:

• Uniform corrosion: generating a uniform layer of rust (formation of oxide) over the surface of the metal exposed to atmosphere. In principle, uniform corrosion can reduce the rate of corrosion by limiting the contact surface between the base metal and the atmosphere.

• Galvanic Corrosion: This type of localized corrosion occurs by the differences between ion concentration in dissimilar environments (different ion concentration) inside and outside of the small crevice.

• Pitting Corrosion: One of the most common forms of corrosion with local attack which can form holes (pits) into the base metal.

• Stress Corrosion: In the presence of corrosive environment and applied tensile stress, brittle cracking occurs in the base metal.

• Spot Rusting: Spot rusting occurs when the bulk of the rusting is concentrated in a few localized areas of the painted surface.

• Pinpoint Rusting: Pinpoint rusting occurs when the rust is distributed across the surface as very small individual specks of rust.

Page 4 of 7

Enclosure 1 to E-62416 2.2.2 Sheet Metal Corrosion Allowance 10-gauge carbon steel is specified for the outer shell sides on the SAR drawing number LR-SAR, Sheet 1, Sectional View. The top is shown as -inch-thick carbon steel and the bottom is shown as 1/4-inch-thick carbon steel on the SAR drawing, Sheet 2, Detail F Wall Section. The outer vessel plate steel material is specified as ASTM A1011 or A1008 (Ref. 3) on the SAR Drawing, Sheet 3, Note 3. The specified tolerance range for these carbon steel specifications is defined by ASTM A568, Standard Specification for Steel, Sheet, Carbon, Structural, and High-Strength, Low-Alloy, Hot-Rolled and Cold-Rolled, General Requirements for (Ref. 4). Table 1 provides the tolerances based on specified width and thickness. A nominal thickness for 10-gauge sheet metal is 0.1345 inches (Ref. 5) and for the sheet size required to fabricate the outer vessel as shown on the license drawings (Ref. 2), nominal thickness is reduced by 0.012 divided equally over and under. The corrosion thickness limit for the outer shell is the minimum that would be allowed for specified ordered thickness. Therefore, the minimum allowed thickness is taken as the nominal thickness of 0.1345 inch minus 0.006 inch, or 0.1285 inch thickness.

Table 1. Thickness Tolerances for ASTM A568 Hot-Rolled Steel Specified Ordered Thickness, in.

Over 0.051 to Over 0.057 to Over 0071 to Over 0.098 to Specified Width. in.

0.027 to 0.051, 0057, 0.071, 0.098, 0.180, 0.180 to 0.230, incl incl incl incl excl excl To 20 incl 0.008 0.008 0.009 0.009 0.010 0.010 Over 20 to 40, incl 0.008 0.008 0.009 0.010 0.010 0.012 Over 40 to 48, incl 0.008 0.009 0.090 0.010 0.012 0.014 Over 48 to 60, incl 0.009 0.010 0.010 0.012 0.015 Over 60 to 72. incl 0.010 0.010 0.012 0.012 0.016 Over 72 0.012 0.012 0.018 Note: The tolerances provided in the table are based on minimum thickness (tolerance over, no tolerance under). For nominal thickness, the tolerance is divided equally over and under.

2.2.3 Structural Steel Corrosion Allowance Other structural flat bar, angle, and square tubing carbon steel components of the LR packaging meet the requirements specified in ASTM A6 (Ref. 6) for permitted variations in thickness.

ASTM A6 permits variations in thickness when materials are purchased. Table 2 below is a partial recreation of ASTM A6, Table 1 Ref. (Ref. 6), which provides the permitted variations for components thickness and width. For the range of materials used to fabricate the LR package, the permitted variation in thickness due is 0.03 inches. Therefore, for unpainted or structural steel components, the maximum variation in thickness is 0.03 inches. Therefore, the minimum thickness of angle and other 1/4 inch thick steel is nominal steel thickness of 0.25 inch minus 0.03 inch, or 0.22 inch.

Table 2. Permitted Variations in Carbon Steel ASTM A6 Components Permitted Variation Over Specified Thickness for Widths Given in Inches, in.

Specified Over 48 Thickness, in. 48 and to 60, 60 to 72, 72 to 84, 84 to 96, 96 to 108 to 120 to 132 to 144, under excl excl excl excl 108, excl 120, excl 132, excl excl To 1/4, excl 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.04 1/4 to 5/16, excl 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.04 0.04 5/16 to 3/8, excl 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.04 0.04 Page 5 of 7

Enclosure 1 to E-62416 2.2.4 Weld Corrosion Allowance The weld must maintain a thickness greater than or equal to the minimum thickness of the components that make up the weld joint or the weld dimension specified on the license drawing, whichever is less. For example, the fillet welds at the interface of the 0.25-inch bottom plate and 10-gauge shell must maintain a minimum thickness of the shell material as 0.1285 inch (see Table 2) or licensing drawing dimension of 0.125 inch. Therefore, the minimum weld thickness is 0.125-inch. Full penetration welds must meet the minimum thickness for the base metal.

3.0 NOTIFICATION TO REGISTERED USERS Following the discovery of the insufficient acceptance criteria for visual inspection of the LR exterior, registered users of the package were notified by TN Americas to suspend use of the packaging pending further evaluation to establish acceptance criteria for inspections of the exterior surface. TN confirmed that there were no packages in transit when the error was identified.

4.0 PATH FORWARD AND CORRECTIVE ACTION PLAN

a. LR package users have performed the pre-loading inspection of exterior surfaces on all packages in service for corrosion using detailed written instructions and visual acceptance standards that demonstrate compliance with the revised inspection criteria for corrosion.

Packages not conforming to the more-detailed acceptance criteria for corrosion (Ref. 7) have been removed from service.

b. The LR package certificate holder will prepare an application to revise the CoC. A revised SAR will include more-detailed inspection criteria for corrosion on the exterior surface of the package, and other changes to improve the guidelines provided for operating and maintaining the package in an unimpaired physical condition.

c. The LR package owner will perform activities required by the maintenance program for the LR packages removed from service to include repair of the packaging as needed.

Packaging shall be restored to the specifications for carbon steel components as shown in the SAR.

5.0 SERIAL NUMBER OF PACKAGES AUTHORIZED FOR TRANSPORTATION Evidence that packages selected for continued use meet the condition for inspections prior to use is provided as a completed inspection form using the approved detailed written inspection procedure for each of the packages.

The following packages meet the acceptance revised criteria for corrosion on the exterior surfaces. These packages are in unimpaired physical condition except for superficial defects such as marks or dents.

LR230-02 LR230-13 LR230-25 LR230-36 LR230-42 LR230-07 LR230-14 LR230-27 LR230-37 LR230-44 LR230-08 LR230-17 LR230-28 LR230-38 LR230-46 LR230-09 LR230-18 LR230-30 LR230-39 LR230-47 LR230-10 LR230-21 LR230-32 LR230-40 LR230-48 LR230-12 LR230-24 LR230-35 LR230-41 LR230-50 Page 6 of 7

Enclosure 1 to E-62416 6.0 TIMEFRAME FOR SHIPMENTS Shipments using the authorized LR packages will continue up until the expiration of the CoC 9291 Letter Authorization.

7.0 END DATE FOR IMPLEMENTATION OF CORRECTIVE ACTIONS Corrective action to revise the SAR operating and maintenance instructions will be completed prior to expiration of the CoC 9291 Letter Authorization. After the CoC 9291 is revised, LR packages authorized for use by the Letter Authorization may continue to be used using the SAR operating procedure inspection criteria incorporated in the revised CoC 9291, and packages removed from service may be returned to service after maintenance activities are completed.

8.0 REFERENCES

1. NRC Certificate of Compliance No. 9291, Revision 11, Liqui-Rad Transport Unit.

2. Safety Analysis Report for Packaging (SARP) for the Liqui-Rad Transport Unit, Rev. 9, USA/9291/B(U)F-96.

3. ASTM International, Standard Specification for Steel, Sheet, and Strip, Hot-Rolled, Carbon, Structural, High-Strength Low-Alloy, High-Strength Low-Alloy with Improved Formability, and Ultra-High Strength, A1011/A1011M - 18a.

4. ASTM International, Standard Specification for Steel, Sheet, Carbon, Structural, and High-Strength, Low-Alloy, Hot-Rolled and Cold-Rolled, General Requirements, A568/A568M - 19a.

5. Avallone, A. A., Baumeister III, T., Marks Standard Handbook for Mechanical Engineers, Eleventh Edition, 2007.

6. ASTM International, Standard Specification for General Requirements for Rolled Structural Steel Bars, Plates, Shapes, and steel pilings, A6/A6M - 22.

7. Westinghouse Procedure Number TAF-502, Special Routing SR16907, Inspections on the Liquid-Rad Packaging for NRC Letter of Acceptance Submittal.

Page 7 of 7

Enclosure 2 to E-62416 SAR Pages (Security-Related)

Withheld Pursuant to 10 CFR 2.390

Enclosure 3 to E-62416 SR16907 Special Routing Withheld Pursuant to 10 CFR 2.390

Enclosure 4 to E-62416 SR16907 Form TAF-502-1 Withheld Pursuant to 10 CFR 2.390 to E-62416 SAR Pages (Public Version)

8 I 7 I 6 I 5 l 4 I 3 I 2 I H H G G F F Security Related Information E E for Drawing LIQUI-RAD TRANSPORT UNIT Rev. 11 D

Withheld Pursuant to 10 CFR 2.390 D C C B B A A 8 I 7 I 6 I 5 f 4 I 3 I 2 I

7 OPERATING PROCEDURES The LR is loaded, unloaded, inspected and handled in accordance with standard, in-plant, operating procedures as stipulated in this section. The only approved commodity is uranyl nitrate solution that falls within the specifications delineated in Section 1.2.3.

7.1 Procedure for Loading the LR The isotopic distribution of the material to be shipped must be determined prior to loading and the contents must meet the specifications of Section 1.2.3. If the contents are verified and documented as containing less than an A2 quantity, the leak test requirement of 7. I .2(d) can be waived.

7.1.1 Pre-loading inspection

a. Inspect the LR exterior for visible flaws. Visually inspect all accessible welds for cracks or corrosion. The exterior welds should be free of cracks, and the exterior surface should not be torn or substantially crushed (more than 2 inches of crush depth). If the exterior surface is torn or substantially crnshed, or if cracks or corrosion are discovered, the unit should not be used.

b. If the l'vIVE feature is present, remove the MVE lid and verify that the test valve is closed, If the optional MVE feature is used, verify that the valve is operational. If the valve is found to be non-operational it should be replaced prior to loading the LR. After verification, replace the i'vfVE lid and torque the bolts to 75 ft-lbs [+10-0].

c. Remove the outer lid and check the annulus space for radioactive contamination or debris. If radioactive contamination is present, decontaminate. Remove any solid debris. If standing water is present, it must be removed. Visually inspect the outer lid for corrosion or damage to the stud holes. Visually inspect the studs for stripping, cracking and corrosion. If any are found to be defective, replace them with an equivalent stud.

d. Remove the secondary lid and inspect for corrosion or damage to the bolt holes.

Visually inspect the bolts for stripping, cracking and corrosion. If any are found to be defective replace them with an equivalent bolt. Visually inspect the optional elbow fitting (if present) and the secondary lid flange at the elbow connection for deformation or misalignment. While deformation or misalignments at this location do not impact the performance of the containment boundary, they could be a source of over-estimation of the pre-shipment, maintenance or fabrication leakage rate, and should be corrected if possible.

e. Check for scratches or nicks on sealing surfaces. If scratches or nicks are observed, leak check the package prior to loading per 7.1.2 (d).

f. Visually inspect the LR secondary lid O-rings and the outer lid gasket. They should be in place, intact, and in serviceable condition. If any are found to be defective, they must be replaced. Regular replacement of the O-rings is LiquiRad SAR Rev. 7 7-1 August 2011

8 ACCEPTANCE AND MAINTENANCE PROGRAMS This section describes the activities to be performed in compliance with Subpm1 G of 10CFR71 to assure that the LR conforms to the requirements ofthis Safety Analysis Repmt for Packaging and remains in conformance following loading.

8.1 Acceptance Tests Each newly fabricated LR shall be inspected to document compliance with the following requirements:

a. The as-built dimensions of the following components shall be within the tolerances prescribed by the fabrication drawings:

Containment vessel dimensions Outer package dimensions Closure bolt locations Lifting shackles

- Assembled package weight

b. Installation of the following components shall be verified and documented:

Gaskets and O-rings

- Security seal tabs Fastening Components Permanent markings and nameplates

c. Prior to acceptance for use, each packaging shall be subjected to the following tests:

Prior to first use, leak rate testing of the primary lid and secondary lid seals shall be performed per ANSI N 14.5- I 997 to a rate less than 1.0 x 10*7 std. cc/sec. and per the requirements of Sections 4 of this SARP. After testing the primary lid, tamper indicating devices shall be installed at the primary lid seal.

- Hydrostatic testing of the contaimuent vessel per the requirements of ASME Section 8, Division 1 8.2 Maintenance Programs The user shall establish written procedures for the ammal maintenance and inspection of each LR requiring the following as a minimum.

a. Inspect the LR exterior for visible flaws. Visually inspect all accessible welds for cracks or con-osion. The exterior welds should be free of cracks, and the exterior surface should not be torn or substantially crushed (more than 2 inches of crush depth). If the exterior surface is tom or substm1tially crushed or cracks are discovered, the unit should be repaired by the owner and re-certified for use. The user may remove light smface corrosion by polishing as required. If the corrosion is not easily removed or if pitting or scaling is observed, the tmit should be repaired by the owner and re-certified for use.

LiquiRad SAR Rev. 7 8-1 August 2011

b. Remove the MVE lid and verify that the test valve is operational and closed. If the valve is found to be non-operational is must be replaced. After verification, replace the MVE lid and torque the bolts to 75 ft-lbs [+10 -OJ.

c. Remove the outer lid and check the annulus space for radioactive contamination and debris. If radioactive contamination is present, decontaminate. Remove any solid debris.

If standing water is present, it must be removed. Visually inspect the outer lid for corrosion or damage to the stud holes. Visually inspect the studs for stripping, cracking and corrosion. If any are found to be defective, replace them with an equivalent stud.

d. Check that the lifting shackles and all closure bolts and supports are sound and free from weld cracks, damage and deterioration.

e. Check that the outer lid and secondary lid closure surfaces are sound and undamaged.

f. Check that outer lid gasket, secondary lid 0-ring, and primary lid 0-ring is in place, intact, and is not damaged or deteriorated. The owner recommends rep 1ace men t of O-rin gs and gaskets every 12 months. After replacement of O-rings, each package shall be leak tested as per paragraph (h) below.

g. Check that the weld of the draw pipe to the primary lid and the draw pipe itself are in good condition, with no cracks; repair if necessary.

h. Periodic leak tests, as described by ANSI Nl4.5-1997, shall be performed to verify that the containment boundaries of the package remain capable of limiting leakage of the payload to less than the maximum allowable leakage rate criterion of 1.0 x 10-3 ref-cc/sec (see Section 4 ). The seal at the primary lid and the seal at the secondary lid shall be leak tested to a rate less than 1.0 x 10-3ref-cc/sec using a test having a sensitivity of at least 0.5 x 10-3 ref-cc/sec. Ifthe leak test results are unacceptable, remove the lid and inspect the sealing surface and 0-rings. Clean the sealing surface and replace the 0-ring as required. Also inspect the optional elbow fitting on the secondary lid flange (if present) and assure that it is properly installed. Install the lid, liberally using an anti-seize lubricant on the stud threads. Tighten all studs/bolts, alternating opposing sides of the lid, to the proper torque of 7 5 ft-lbs [+ 10 -0]. Re-test as per above. If the leak results continue to be unacceptable, the unit should be repaired by the owner and re-certified for use.

1. As a minimum, the optional elbow fitting (if present) located at the secondary lid flange 1 should be inspected yearly by successful leak test examination at the exterior stress groove. If any defects are found, the elbow should be replaced with an identical item per drawing provided in Appendix 1.3 .1

j. Sandblasting is permitted provided material thickness remains greater than minimum wall thickness. Coating of sandblasted surfaces shall use Sherwin Williams Macropoxy 646 Fast Cure B58 Series primer or equivalent.

LiquiRad SAR Rev. 8 8-2 as supplemented to E-62416 Affidavit

Westinghouse Non-Proprietary Class 3 AFFIDAVIT AW-23-021 Page 1 of 2 State of South Carolina:

County of RICHLAND:

(1) I, Wes Stilwell, Director, NF Transport, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2) I am requesting Proprietary Enclosures Special Routing number SR16907 and Procedure Forms TAF-502-1 be withheld from public disclosure under 10 CFR 2.390.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged, or as confidential commercial or financial information.

(4) Pursuant to 10 CFR 2.390, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.

(ii) The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouses knowledge, is not available in public sources.

(iii) Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Nevertheless, public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

• • • This record was final approved on 6/7/2023, 9:22:40 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT AW-23-021 Page 2 of 2 (5) Westinghouse has policies in place to identify proprietary information. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(6) The attached submittal contains proprietary information throughout, for the reasons set forth in Sections (5) (a) through (f) of this Affidavit. Accordingly, a redacted version would be of no value to the public.

I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief. I declare under penalty of perjury that the foregoing is true and correct.

Executed on: 6/7/2023 _____________________________

Signed electronically by Wes Stilwell

• • • This record was final approved on 6/7/2023, 9:22:40 AM. (This statement was added by the PRIME system upon its validation)

AW-23-021 Revision 0 Non-Proprietary Class 3

• • This page was added to the quality record by the PRIME system upon its validation and shall not be considered in the page numbering of this document.**

Approval Information Manager Approval Stilwell William Jun-07-2023 09:22:40 Files approved on Jun-07-2023

• • • This record was final approved on 6/7/2023, 9:22:40 AM. (This statement was added by the PRIME system upon its validation)