ML23345A211
| ML23345A211 | |
| Person / Time | |
|---|---|
| Site: | OPTIMUS-L |
| Issue date: | 12/11/2023 |
| From: | Baldner H NAC International |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| EPID L-2020-LLA-0202, ED20230153 | |
| Download: ML23345A211 (8) | |
Text
ED20230153 Atlanta Corporate Headquarters 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com December 11, 2023 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Attention:
Document Control Desk
Subject:
Submission of Replacement Pages for Supplemental Responses to the NRC¶s Request for Additional Information to NAC¶s for the NAC OPTIMUS-L Transportation Package, Certificate of Compliance 71-9390, and Safety Analysis Report, Revision 1 Docket No. 71-9390 EPID - L-2020-LLA-0202
References:
- 1.
USNRC CoC No. 9390, Revision 1, Model No. NAC OPTIMUS-L Transportation Package, Dated January 24, 2022
- 2.
ED20210192, Submission of the NAC OPTIMUS-L Transportation Package, Safety Analysis Report, November 12, 2021
- 3.
ED20220156, Notification of Intent to Submit a Request for a Revision to NAC OPTIMUS-L Transportation Package, Certificate of Compliance 71-9390, September 29, 2022
- 4.
ED20220161, Submission of Data Files to Support the Submission of a Request for a Revision to Certificate of Compliance (CoC) No. 9390 for the NAC-OPTIMUS-L Transport Cask to Authorize the Transport of TRISO compacts, November 1, 2022
- 5.
Request for a Revision to NAC OPTIMUS-L Transportation Package, Certificate of Compliance 71-9390
- 6.
Additional Drawing changes for the Request for a Revision to NAC OPTIMUS-L Transportation Package, Certificate of Compliance 71-9390
- 7.
Request for Additional Information for the Review of the Model No.
OPTIMUS-L Package, July 17, 2023
- 8.
ED20230122, Submission of Responses to the NRC¶s Request for Additional Information (RAI) to NAC¶s for the NAC OPTIMUS-L Transportation Package, Certificate of Compliance 71-9390, September 8, 2023
- 9.
P. Saverot, Personal Communication, ³3 outstanding issues for OPTIMUS-L TRISO to be resolved before CoC issuance', September 26, 2023
- 10.
ED20230153, Submission of Supplemental Responses to the NRC¶s Request for Additional Information to NAC¶s for the NAC OPTIMUS-L Transportation Package, Certificate of Compliance 71-9390, and Safety Analysis Report, Revision 1, November 15, 2023
ED20230179 Atlanta Corporate Headquarters 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com U.S. Nuclear Regulatory Commission December 11, 2023 Page 2 of 2 NAC International Inc. (NAC) hereby submits replacement pages for the supplement to the NRC Request for Additional Information (RAI) and SAR revision 1 provided on November 15, 2023 (Reference 10).
The NRC document Accession numbers for the package is ML23320A201 which includes ML23320A202, ML23320A203, ML23320A204 for the Cover Letter, Non-proprietary submittal and Proprietary submittal respectively. The pages for both the submittal and the SAR are common to the Non-proprietary submittal and Proprietary Should there be any questions regarding this request, please contact me via email at hbaldner@nacintl.com or via phone at 678-328-1252.
Sincerely, Heath Baldner Director, Licensing Engineering Attachment +/- OPTIMUS-L Response Supplement Replacement Pages +/- OPTIMUS-L SAR Revision 1 Replacement Pages
ED20230179 OPTIMUS-L SAR (Docket No 71-9390)
RAI Response Supplement Replacement Pages NAC International November 2023
OPTIMUS-L Package SAR November 2023 Docket No. 71-9390 Revision 23C NAC International 1.2-12 Maximum Quantity of TRISO Compacts per Package:
- 1. Maximum total weight 581 pounds (263 kg).
- 2. Maximum enrichment 20% U-235.
- 3. Total mean uranium loading 68 kgU
- 4. Maximum mean matrix density 1.8 g/cc.
For TRISO Compacts, the fuel may originate from enriched slightly contaminated uranium with trace quantity limits. The following table shows the maximum concentrations of the content, including contaminants. U-238 is not listed as it is assumed to be the remainder of the uranium concentration.
Isotope Concentration U-232 2.6 x 10-9 g/gU-235 U-234 1.00 x 10-2 g/gU-235 U-235 2.00 x 10-1 g/gU U-238 Balance of Uranium Np-237 3.85 x 10-6 g/gU-235 Pu-238 1.56 x 10-10 g/gU-235 Pu-239/Pu-240 4.29 x 10-8 g/gU-235 Fission Products 0.25 mCi/gU Loading Restrictions:
- 1. TRISO compacts shall be shipped in the GEO basket assembly.
- 2. TRISO compacts shaall not protrude above the top end of the GEO basket fuel tubes.
- 3. TRISO compact shall be shipped dry (i.e., no free liquids).
- 4. Non-metallic components such as spacers and/or adhesive-backed seals or labels may be included, however, these components must have an auto-ignition temperature of 300 F or higher and must be evaluated for gas generation in accordance with Attachment 7.5-3 prior to shipment.
1.2.3 Special Requirements for Plutonium Plutonium contents in quantities greater than 0.74 TBq (20 Ci) must be in solid form.
OPTIMUS-L Package SAR November 2023 Docket No. 71-9390 Revision 23C NAC International 5.1-2 and cab (occupied position) dose rates are only calculated from the side of the package, as the package is only transported in the upright position.
For TRU waste, the contents of the package are variable, and the final isotope inventory is different for each TRU waste drum or irradiated fuel waste liner, the maximum dose rates are strongly dependent on the specific contents. As an example, maximum dose rates are calculated for the maximum allowable quantity of two individual isotopes. The two isotopes considered are Co-60 and Cf-252. Examples of the maximum activity in a package of the conveyance that would result in the limiting dose rate at 90% of the regulatory limit are provided in Table 5.1-2, along with the resulting total dose rates at each location. It should be noted from this table that, due to the relatively thin layers of shielding provided by the packaging, the maximum isotopic activities permissible in the contents are very limited. The primary content intended for transport in the package is drums of TRU waste with relatively low activity. Thus, the relative hazard of the contents is limited.
For TRISO compact contents, the payload is composed of fresh, unirradiated fuel, with trace quantities of contaminants as specified in Chapter 1, therefore dose rates on package surfaces will be negligible. Based on the significant shielding presented by the package design and that the payload is unirradiated material fresh fuel, no shielding evaluations are required.
ED20230179 OPTIMUS-L SAR (Docket No 71-9390)
OPTIMUS-L SAR Revision 1 Replacement Pages NAC International November 2023
OPTIMUS-L Package SAR November 2023 Docket No. 71-9390 Revision 1 NAC International 1.2-12 Maximum Quantity of TRISO Compacts per Package:
- 1. Maximum total weight 581 pounds (263 kg).
- 2. Maximum enrichment 20% U-235.
- 3. Total mean uranium loading 68 kgU
- 4. Maximum mean matrix density 1.8 g/cc.
For TRISO Compacts, the fuel may originate from enriched slightly contaminated uranium with trace quantity limits. The following table shows the maximum concentrations of the content, including contaminants. U-238 is not listed as it is assumed to be the remainder of the uranium concentration.
Isotope Maximum content U-232 2.6 x 10-9 g/gU-235 U-234 1.00 x 10-2 g/gU-235 U-235 2.00 x 10-1 g/gU U-238 Balance of Uranium Np-237 3.85 x 10-6 g/gU-235 Pu-238 1.56 x 10-10 g/gU-235 Pu-239/Pu-240 4.29 x 10-8 g/gU-235 Fission Products 0.25 mCi/gU Loading Restrictions:
- 1. TRISO compacts shall be shipped in the GEO basket assembly.
- 2. TRISO compacts shall not protrude above the top end of the GEO basket fuel tubes.
- 3. TRISO compact shall be shipped dry (i.e., no free liquids).
- 4. Non-metallic components such as spacers and/or adhesive-backed seals or labels may be included, however, these components must have an auto-ignition temperature of 300 F or higher and must be evaluated for gas generation in accordance with Attachment 7.5-3 prior to shipment.
1.2.3 Special Requirements for Plutonium Plutonium contents in quantities greater than 0.74 TBq (20 Ci) must be in solid form.
OPTIMUS-L Package SAR Docket No. 71-9390 November Revision NAC International 5.1-2 and cab (occupied position) dose rates are only calculated from the side of the package, as the package is only transported in the upright position.
For TRU waste, the contents of the package are variable, and the final isotope inventory is different for each TRU waste drum or irradiated fuel waste liner, the maximum dose rates are strongly dependent on the specific contents. As an example, maximum dose rates are calculated for the maximum allowable quantity of two individual isotopes. The two isotopes considered are Co-60 and Cf-252. Examples of the maximum activity in a package of the conveyance that would result in the limiting dose rate at 90% of the regulatory limit are provided in Table 5.1-2, along with the resulting total dose rates at each location. It should be noted from this table that, due to the relatively thin layers of shielding provided by the packaging, the maximum isotopic activities permissible in the contents are very limited. The primary content intended for transport in the package is drums of TRU waste with relatively low activity. Thus, the relative hazard of the contents is limited.
For TRISO compact contents, the payload is composed of fresh, unirradiated fuel, with trace quantities of contaminants as specified in Chapter 1, therefore dose rates on package surfaces will be negligible. Based on the significant shielding presented by the package design and that the payload is unirradiated material fresh fuel, no shielding evaluations are required.