ML24086A314
| ML24086A314 | |
| Person / Time | |
|---|---|
| Site: | 07109315 |
| Issue date: | 04/01/2024 |
| From: | Bernie White Storage and Transportation Licensing Branch |
| To: | Shenk J US Dept of Energy, Office of Packaging and Transportation |
| References | |
| EPID L 2022 LLA 0116 | |
| Download: ML24086A314 (7) | |
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April 1, 2024 Julia C. Shenk, Director Office of Packaging and Transportation U.S. Department of Energy EM-4.24/Germantown Building 1000 Independence Ave, S.W.
Washington, DC 20585
SUBJECT:
APPLICATION FOR REVISION OF CERTIFICATE OF COMPLIANCE NO. 9315 FOR THE MODEL NO. ES-3100 PACKAGE - REQUEST FOR SUPPLEMENTAL INFORMATION
Dear Julia Shenk:
By letter dated February 5, 2024 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML24060A090), the U.S. Department of Energy (DOE) submitted an application for revision of certificate of compliance no. 9315 to the model no. ES-3100 transport package. Among other changes, the application proposes addition of tri-structural isotropic (TRISO) fuel and addition of Packcrete thermal insulating and impact limiting material.
The U.S. Nuclear Regulatory Commission (NRC) staff performed an acceptance review of your application to determine if the application contains sufficient technical information in scope and depth to allow the staff to complete the detailed technical review. This letter is to advise you that, based on our acceptance review, the application does not contain sufficient technical information. The information needed to continue our review is described in the enclosure to this letter. Staff included observations to allow you to start earlier on items containing the potential to be asked at a later date. Responses to observations are not required for staff to begin a detailed technical review. Observations are not the result of a detailed technical review and may be resolved once the staff begins a detailed review.
In order to schedule our technical review, this information should be provided by 2 weeks from the date of this letter. If the information described is not received by this date, the application may not be accepted for review.
In accordance with Title 10 of the Code of Federal Regulations, Part 2, Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. The PDR is open by appointment. To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.gov or call 1-800-397-4209 or 301-415-4737, between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except Federal holidays.
J. Shenk Please reference Docket No. 71-9315 and Enterprise Project Identifier (EPID) No.
L-2022-LLA-0116 in future correspondence related to this request.
Sincerely, Bernard H. White IV, Senior Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-9315 EPID No. L-2022-LLA-0116 Signed by White, Bernard on 04/01/24
ML24086A314 OFFICE DFM DFM DFM DFM DFM NAME BWhite SFigueroa BPatel JCarlson JBorowsky DATE 3/26/2024 3/26/2024 3/26/2024 3/27/2024 3/28/2024 OFFICE DFM DFM DFM DFM DFM NAME JDrabble TBoyce DMarcano DJonhson YDiaz-Sanabria DATE 3/28/2024 3/28/2024 3/29/2024 3/28/2024 4/1/2024
Enclosure Request for Supplemental Information Model No. ES-3100 Transportation Package Docket No. 71-9315 This request for supplemental information (RSI) identifies information needed by the staff in connection with its acceptance review of the model no. ES-3100 transportation package application, dated February 5, 2024 (Agencywide Documents Access and Management System Package Accession No. ML24060A090.
The requested information is listed by chapter number and title in the applicants safety analysis report (SAR).
2.0 Structural Evaluation RSI-St-1 Provide the following documents used to support normal conditions of transport and hypothetical accident conditions evaluation of the amended ES-3100 Package:
(i) DAC-EA-801699-A001, Impact Analysis of ES3100 Design Concepts Using Borobond, BWXT Y-12, Y-12 National Security Complex, Nov. 22, 2004; (ii) DAC-EA-801699-A002, Impact Analyses of ES3100 Design Concepts Using HABC, BWXT Y-12, Y-12 National Security Complex, Feb. 24, 2005; (iii) DAC-M900000-0002, ASME [American Society of Mechanical Engineers] Code Subsections NB and WB Stress Analysis of ES-3100 Containment Vessel, B&W Y-12, Y-12 National Security Complex, April 19, 2011; (iv) DAC-M900000-0003, Stress Analysis of ES-3100 Containment Vessel with Viton O-rings, B&W Y-12, Y-12 National Security Complex, May 23, 2012; and (v) RP 802282-0002 000 02, Packcrete Material Properties, Consolidated Nuclear Security, Y-12 National Security Complex, June 2016.
In order to evaluate the impact of the changes made to the production hardware of the package after compliance testing of the test units, the applicant has conducted and documented analytical drop simulations in references DAC-EA-801699-A001 and DAC-EA-801699-A002. The applicant has analyzed the containment vessel (CV) in references DAC-M900000-0002 and DAC-M900000-0003 for applicable loads and load combinations and to demonstrate that the stresses in the CV and closure nut do not exceed the stress limits established by the ASME Boiler and Pressure Vessel Code for normal condition of transport (NCT) and hypothetical accident conditions (HAC). To confirm the thermal-insulating and impact-limiting material equivalency of Packcrete to the previously used Kaolite material, material properties are evaluated and the results, including a force/deflection curve for Packcrete, are documented in reference RP 802282-0002. These supporting documents should be readily available or included in the application so that the staff can perform the evaluation using information that is relevant to the proposed design.
This information is needed to determine compliance with Title 10 of the Code of Federal Regulations (10 CFR) 71.71 and 71.73.
2 4.0 Thermal Evaluation RSI-Th-1 Provide the NCT and HAC calculation package documents (e.g.,
DAC-M80194-0002) that describe the thermal models and results for the updated package design associated with the current amendment.
Section 1.2.1.2 and section 1.2.2.7 of the safety analysis report (SAR) noted thermal-related revisions of the current amendment, including increasing decay heat to 5 W (from 0.4 W) and using Packcrete insulation rather than Kaolite insulation. However, the description of the thermal design in SAR Chapter 3 did not provide NCT and HAC thermal model information necessary for review, including details associated with heat transfer modes, internal and external model boundary conditions, HAC damaged package model description, confirmation of appropriate steady-state spatial resolution and transient time-step values, thermal model convergence values (e.g., residuals), and package component allowable temperatures. However, SAR section 3.3 and section 3.4.3 appear to indicate that NCT and HAC thermal model details of the updated package design were provided in document DAC-M80194-0002.
This information is needed to determine compliance with 10 CFR 71.35.
4.0 Containment Evaluation RSI-Co-1 Provide the document that describes the evaluation and testing for revising the periodic leakage rate test frequency of the ES-3100 DOE package and its ethylene propylene diene monomer (EPDM) O-rings.
SAR section 4.4 noted that document RP 801580-0022 described the internal testing (and its corresponding analysis) of the ES-3100 package and EPDM O-rings that were used to justify the revised periodic testing frequency; however, a review of the justification was unable to be performed because this document was not provided in the application.
This information is needed to determine compliance with 10 CFR 71.35.
6.0 Criticality Evaluation RSI-Cr-1 Provide a copy of the reference YAREA-F-0524, Validation of SCALE6.1.3 for Criticality Safety Analyses of HEU Systems using Workstations ENGHPC, CENGHPC, and ENGHPC02, Consolidated Nuclear Security, LLC, Y-12 National Security Complex, September 2016.
Section 6.8, Benchmark Experiments, provides a very high level overview of the results of the benchmarking analysis. for the criticality evaluation, this document is needed. A review of the benchmarking analysis was unable to be performed because this document was not provided in the application.
This information is needed to determine compliance with 10 CFR 71.55 and 10 CFR 71.59.
3 7.0 Materials Evaluation RSI-Ma-1 Provide cited reports (listed below) detailing material properties and evaluations of Packcrete and Kaolite 1600.
(i)
SPC M801794-000, Packcrete Preliminary Lot Qualification, Consolidated Nuclear Security, LLC, Y-12 National Security Complex, April 2021.
(ii)
SPC M801580-0003, ES-3100 Packcrete Final Lot Qualification and Production Processing, Consolidated Nuclear Security, LLC, Y-12 National Security Complex, August 2020.
(iii)
Y/DW-1661, Mechanical Properties of a Low Density Concrete for the New ES-2 Shipping/Storage Container Insulation, Impact Mitigation Media and Neutron Absorber, Lockheed Martin Energy Systems, Inc., Oak Ridge Y-12 Plant, Apr. 10, 1997.
(iv)
Coefficient of Thermal Expansion for Kaolite 1600, e-mail communication to P.A. Bales, BWXT Y-12, Dec. 9, 2004.
In Section 1.2.1.2 of the SAR Chapter 01, General Information, the applicant references several supporting documents that provide and assess the material properties for Packcrete and Kaolite 1600. The applicant is proposing to replace Kaolite 1600, which functions as both a thermal insulating and an impact limiting material, with Packcrete.
This information is needed to determine compliance with 10 CFR 71.55.
Observations 3.0 Thermal Evaluation OBS-Th-1 Provide the calculation that supports the minimum required CV void volume of 42.779 in3 (approximated as 43 in3, per SAR section 1.2.2.4) and discuss the application of that void volume and relevant bounding content in the analyses found in SAR appendix 3.5.1, appendix 3.5.2, and appendix 3.5.4.
Although SAR table 1 in appendix 3.5.1 mentions a 42.779 in3 minimum void volume for the containment vessel arrangement (CVA) in item 11 (CVA 11), the determination of this void volume to ensure acceptable gas expansion and off-gassing was not readily apparent. In addition, although CVA 11 is mentioned in appendix 3.5.1 and appendix 3.5.2, it was not clear what bounding content was transported in the analyses. Likewise, although 5 volume percent hydrogen concentration acceptance criterion is dependent on minimum volumes, a reason was not provided that explained why the CVA 11 minimum volume was not explicitly mentioned in appendix 3.5.4 for hydrogen gas buildup.
This information is needed to determine compliance with 10 CFR 71.35 and 71.43(d).
OBS-Th-2 Clarify that package temperatures would remain below allowable values during NCT and fire HAC when multiple packages are placed within the enclosed conveyance mentioned in SAR section 7.1.3.2.
4 SAR section 3.1.2 noted that the package decay heat is 5 W (an increase from the previous 0.4 W value). Considering that SAR section 6.1.3 noted that multiple packages can be shipped together, the thermal analyses did not address the potential impact of increased package temperatures from multiple packages within an enclosed conveyance with reduced heat transfer to the ambient. For example, although SAR table 3.3 provided the NCT temperature of the O-ring seals based on the stand-alone thermal model assumption, the extent of the temperature margin with the O-ring allowable value is uncertain when multiple packages are positioned within a single enclosure with reduced heat transfer.
This information is needed to determine compliance with 10 CFR 71.35.
4.0 Containment Evaluation OBS-Co-1 Clarify the leakage rate test results (e.g., leaktight) of the ES-3100 Test Units (TU) described in SAR section 4.2.
SAR section 4.2 indicated that the ES-3100 design verification leakage rate testing included a TU-4 leakage rate between O-rings of 2.4773E-5 ref cm3/sec (air) and a subsequent entire TU-4 containment boundary leakage rate test result of 2E-7 cm3/sec (helium). An analysis or discussion was not provided that explains reasons for designating a package as being ANSI N14.5 leaktight (which is the basis for the packages operation) when part of the containment boundary has a 2.4773E-5 ref cm3/sec (air) leak rate.
This information is needed to determine compliance with 10 CFR 71.35, 10 CFR 71.51.