ML24023A031

Edlow International Co., Response to Request for Additional Information for the Revalidation Request of the Japanese Certificate of Competent Authority No. J/2044/B(U)F, Model No. JMS-87Y-18.ST

ML24023A031
Person / Time
Site:	07103004
Issue date:	09/14/2023
From:	Neely R Edlow International Co
To:	Boyle R Office of Nuclear Material Safety and Safeguards, US Dept of Transportation (DOT), Office of Hazardous Materials Safety
References
001794, EPID L-2023-DOT-0005
Download: ML24023A031 (3)

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Edlow International Company 1666 Connecticut Ave., N.W., Suite 201 Washington, D.C. 20009 U.S.A.

Tel (202) 483-4959 Fax (202) 483-4840 FMC License No. 019368F

September 14, 2023

Richard W. Boyle Chief Sciences Branch Division of Engineering and Research Office of Hazardous Materials Safety U.S. Department of Transportation 1200 New Jersey Ave., S.E.

Washington, DC 20590

Dear M r. Boyle :

Subjects: Docket No. 71-3004 EPID L-2023-DOT-0005 Request for Additional Information for the Revalidation Request of the Japanese Certificate of Competent Authority No. J/2044/B(U)F, Model No.

JMS-87Y-18.ST.

The client has further updated the SAR for the JMS-87Y-18.ST package to address certain calculations highlighted in RAI-St-4. The explanation is below, and the updated SAR for the JMS package is attached.

Explanation:

JAEA understand the NRC's main point that the "Repeated peak stress of a component considering the effect of stress intensity" in the JMS's SAR should be modified to the same calculation method as that in JRC's SAR.

In JRC's SAR, stress intensity is considered in the following areas; (1) Lifting lug (in " A.4.4 Lifting Device" of JRC's SAR)

(2) Bolts for fastening lid (in " A.5.1.4 Comparison of allowable stress" of JRC's SAR)

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For (1), one pattern with the maximum stress has already been submitted in the supplement explan~ti_on to RAI-St-1 for JMS (" Attachment 4 Additional Explanation for RAI-St-1_ The Fatigue of lifting device(Stainless Steel).pdf"), but another pattern similar to JRC's SAR is added.

This revised part is added to A.4.4.3.3 & A.4.4.3.4 ((ll)-A-67 ~ (ll)-A-70) of the updated JMS's SAR.

For (2), the revised part is made in accordance with JRC's SAR as a reference.

This revised part is added to A.10.5 ((11)-A-378 ~ A.10.S ((ll)-A-383) of the updated JMS's SAR.

The followings are JAEA's understanding and supplement explanation of the corrections and additions made to JMS's SAR

"RAI-St-4 Based on the information in Table (ll)-A.31, page (II) A-317, the staff noted that the applicant is combining the NCT and ACT peak stresses and comparing to the repeated peak allowable stress intensity, which is conservative. However, for the fatigue evaluation, the applicant did not perform the calculation correctly and it is not conservative, because the applicant did not calculate repeated peak stresses in the components by accounting for the effects of stress concentration (see RA/ St-1). "

cc> JA EA understands they need to ca lculate the repeated peak stresses of the components to account for the effects of stress intensity.

"RAI-St-4 (continued)

Also, the applicant did not correctly adjust the allowable repeated peak stress intensity to account for differences between moduli of elasticity (see RA/ St-3). Therefore, the current comparison in Table (/l)-A.31 is not accurate."

cc> JAEA understand that this was already completed in the last response from JAEA.

"RAI-St-4 (continued)

The staff mentioned that in order to be an accurate comparison, the applicant needs to calculate the repeated peak actual stress intensity for each applicable component by making necessary corrections mentioned above and listing these va lues in a separate column in Table (//)-A.31 to compare against the repeated peak allowable stress intensity."

cc> Results addressed in RAI-St-1 are added to the table (11)-A.31

"RAI-St-1 The staff noted that the applicant refers to nominal stress values in their response related to

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fatigue calculations. The nominal stress values ignore the influence of any local stress-raising feature to accurately predict the behavior of the component, for example, at the discontinuity or change in cross section of the "member " (e.g., plate with a hole, bolt threads, etc.). The staff pointed out that the applicant needs to consider real stresses that account for stress increases at a local continuity or change in cross section of a member by considering stress concentration factors in their fatigue calculation. The staff noted that the JRC SAR includes stress concentration factors in fatigue calculations and a sim11ar factor needs to be considered for the JMS package fatigue analyses. "

Stress intensity is taken into account in JRC's SARs in the following.

A.4.4 - 2.1.3 Fatigue strength of the body lifting lug

[JMS's SAR] JAEA understand that this concept was no problem in the last response from JAEA.

However, the values are needed to be modified slightly.

A.4.4 - 2.2.4 Fatigue strength of the lid lifting lug

[JMS's SAR] This is added to JAEA's response to RAI-St-1. Originally, body lifting lug had a higher value and was more conservative according to JAEA's understanding, but it is added just in case.

A.5.1.4 Comparison of allowable stress A.10.5.2.1 is added to account for stress intensity in bolts for tightening lids.

A.10.5.2.2 is also added for the container body, lid, and basket just in case.

It is assumed that the RAI-St-3 is understood well by the staff with the revised data such as A. 10.5.1.

Thank you for your assistance and please let me know of any other questions or information needs.

Sincerely,

~/~ 17 A A j)__ /

Russell Neely ',..,....,. - - f Chief Operating Officer

Attachment (Sept. 14.2023 rev 4_2. English version of SAR for JMS-87Y-18.ST(l).pdf)

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