ML24109A299
| ML24109A299 | |
| Person / Time | |
|---|---|
| Site: | 07109393 |
| Issue date: | 04/18/2024 |
| From: | Backus C Orano Federal Services |
| To: | Pierre Saverot Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| EPID L-2021-NEW-0003, FS–24–0047 | |
| Download: ML24109A299 (1) | |
Text
April 18, 2024 FS-24-0047 www.orano.group 1
ATTN: Document Control Desk Director, Division of Fuel Management (DFM) c/o Pierre Saverot, Project Manager, NRC Storage and Transportation Licensing Branch (STLB)
U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Request for Extension of CR3MP Special Package Authorization, Docket No. 71-9393, EPID L-2021-NEW-0003
References:
- 1) Nuclear Regulatory Commission, Special Package Authorization for the CR3 Middle Package (CR3MP) - Docket No. 71-9393, NRC Accession Number ML23208A147, dated August 4, 2023.
- 2) Nuclear Regulatory Commission, Safety Evaluation Report, Docket No. 71-9393, NRC Accession Number ML23208A145, dated August 4, 2023.
- 3) Orano Federal Services, Enclosure 4: CR3MP Transport Package Safety Analysis Report, Revision 4 (Non-Proprietary version), NRC Accession Number ML23159A277, dated May 31, 2023.
Dear Mr. Saverot:
Regarding the CR3 Middle Package (CR3MP) Special Package Authorization (SPA) (Reference 1), Orano Federal Services (Orano FS) is requesting an extension to the allowable transport duration identified in Condition #10 of the SPA.
Currently, there is a 6-month transport duration limit between purging the CR3MP air gap and transport completion. Orano FS is requesting to extend that SPA Condition #10 limit by 3 months for a total new duration of 9 months.
The reason for the request is to account for delays on receipt of state permits which are necessary to begin the road portion of the CR3MP shipment. The currently scheduled road portion of the CR3MP shipment is slated to begin on Monday, April 29th, 2024. The CR3MP was purged of gases on Friday, December 1st, 2023, with the vent port plug welded and inspected the same day. As such, the 6-month SPA condition #10 clock started on that day, with expiration on June 1st, 2024. Since the road trip is scheduled to begin on 4/29/24 with an estimated total 27 days from departure to arrival, this will give less than a 1-week margin to the 6/1/24 deadline. Therefore, if the CR3MP doesnt depart by Thursday, May 2nd, 2024, this may challenge the 6-month SPA condition. Hence, to be conservative, Orano FS is requesting an extension on the SPA Condition #10 duration for an additional 3 months (9 months total) to allow the CR3MP to arrive before September 1st, 2024.
Orano Federal Services LLC 32125 32nd Avenue S Suite 220 Federal Way WA 98001 Tel: +1 253-552-1322
April 18, 2024 FS-24-0047 www.orano.group 2
To support this request, we are reiterating information included in our transport application Safety Analysis Report (SAR) (Reference 3) and providing clarifying additional details pertinent to SPA Condition #10. As referenced in Section 4.2 of the NRCs Safety Evaluation Report (SER) (Reference 2), a 1-year shipment window is stated in SAR Chapter 7 upon closure of the CR3MP. In accordance with SAR Appendix 5.5.4 (Reference 3), closure of the CR3MP is supported by an evaluation period greater than 365 days. Since the NRC did not know the duration between purging of the air gap and subsequent welding of the vent port plug (containment boundary completion state), SPA condition #10 was restricted to a 6-month duration, instead of the full 12 months.
By including an additional 6-month period between purging of the air gap and welding of the vent port plug, the NRC added conservatism to account for any further accumulation of radiolysis gases. Since, as stated above, both the air gap purging and vent port closure occurred on the same day, such a reduction on the allowed shipment period is unwarranted. As such, the request to extend the SPA condition #10 duration limit to 9 months should be acceptable to the NRC staff, observing that there is a continued 3-month plus buffer to the evaluation limit in the SAR. In conclusion, this adjustment to the SPA condition #10 limit results in no change to the CR3MP safety basis, and no change to what had been previously approved by the NRC in the SAR (Reference 3), as referenced by the SPA (Reference 1). Therefore, we would request that the SPA condition #10 be changed to 9 months, from the current 6-month duration.
Of note to the NRC, the evaluations in SER Sections 3.5.2 and 4.2 (Reference 2) currently reflect a 6-month limit as well.
Should you have any questions regarding this SPA condition #10 extension request, please dont hesitate to contact me at: (253) 552-1322 or via email (chris.backus@orano.group).
Yours Truly, Chris Backus Packaging Licensing Manager, Orano Federal Services LLC Copies (per email):
Tom Criddle, Project Manager, Orano Federal Services LLC Sebastien Guillot, VP Operations, Orano Decommissioning Services LLC Larry McDougal, Project Manager, Orano Decommissioning Services LLC Ricky Furr, ODS Asset Manager, Orano Decommissioning Services LLC Digitally signed by BACKUS Christopher