ML24002B142
| ML24002B142 | |
| Person / Time | |
|---|---|
| Site: | 07201052 |
| Issue date: | 12/01/2023 |
| From: | Garcia-Santos N Storage and Transportation Licensing Branch |
| To: | |
| Shared Package | |
| ML23326A007 | List: |
| References | |
| Download: ML24002B142 (2) | |
Text
OFFICIAL USE ONLY - PROPRIETARY INFORMATION
MATERIALS RAI Docket No. 72-1052 Dry Storage System CASTOR geo69
RAI-M-1 Provide additional information on the cast iron package coating s that demonstrate coating durability and support the emissivity value s credited in the thermal analysis.
The specifications and minimum requirements for inner and outer coatings are provided in SAR Section 8.2.6.1, which does not provide any det ails about materials qualification data, manufacturer data sheets or other bases that demonstrate the performance of the coating under the elevated h eat and radiation exposures of the internal package environment. The ap plicant states the coating is important to safety as thermal analysis relies o n emissivity values, however it is not indicated in the bill of materials or the dra wing package. The staff notes that the emissivity specification and how the emiss ivity value will be verified is important, as well as what standard the applicant i s using to verify and validate these values.
This information is needed to demonstrate compliance with 10 CF R 72.236(b),
10 CFR 72.236 (f) and 10 CFR 72.236 (g).
RAI-M-2 Provide additional information on the classification of undamag ed versus damaged spent nuclear fuel. Alternatively confirm that the guid ance in NUREG-2215 Section 8.5.15.1, Spent Fuel Classification, is used to differentiate between damaged and undamaged spent nuclear fuel.
SAR section 8.4.1 states that the storage package relies on fue l cladding to meet fuel specific and DSS related regulations. However, it does not explicitly state that the applicant is taking credit for fuel cladding in their analysis and the fuel specific as well as system related functions.
This information is needed to demonstrate compliance with 10 CF R 72.236(h) and (m).
RAI-M-3 Provide additional information to demonstrate that the package drying criteria are adequate to prevent an unacceptable loss of cladding toughness due to hydride reorientation.
SAR Section 7.1.2 provides process steps but is not clear why t his will provide adequate drying without any adverse effects to the material (fu el cladding).
This information is needed to demonstrate compliance with 10 CF R 72.236(g) and 10 CFR 72.236(m).
RAI-M-4 Justify that the [withheld per 10 CFR 2.390] fuel basket plates will have adequate fracture performance in a drop accident to maintain the assumed fuel configuration in the criticality analyses.
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION
The SAR does not include toughness testing requirements to veri fy that brittle fracture will not affect the structural integrity of the basket in a drop accident. The staff notes that the criticality analysis relies on the mainten ance of configuration of the neutron absorber plates and fuel assemblies.
Although nonferrous materials are generally excluded from fract ure acceptance testing in consensus standards, the proprietary [withheld per 10 CFR 2.390]
metal matrix composite is a non-code material that contains bor on carbide ceramic particles that may diminish fracture performance relati ve to the conventional aluminum material that are considered in the ASME BPVC.
This information is needed to demonstrate compliance with 10 CF R 72. 236 (b) and (g).
RAI-M-5 Provide analysis to demonstrate that the package drying criteri a of [withheld per 10 CFR 2.390] is adequate to remove residual moisture such that it limits hydrogen generation and clarify operational procedures that wou ld prevent accumulation of hydrogen during loading operations.
SAR Section 9.1.2 provides process steps but is unclear why thi s will provide adequate dryness and removal of moisture. Additionally in Table 9.1-2 Operations for loading of contents, it is unclear how and if hydrogen levels are monitored to ensure that flammable gas mixture is monitored and mitigated.
This information is needed to demonstrate compliance with 10 CF R the requirements in 10 CFR 72.236(h).
OFFICIAL USE ONLY - PROPRIETARY INFORMATION