ML24116A212
| ML24116A212 | |
| Person / Time | |
|---|---|
| Site: | 07109389 |
| Issue date: | 04/25/2024 |
| From: | Shaw D TN Americas LLC |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| E-63422 | |
| Download: ML24116A212 (1) | |
Text
Orano TN 7160 Riverwood Drive Suite 200 Columbia, MD 21046 USA Tel: 410-910-6900 Fax: 434-260-8480 April 25, 2024 E-63422 U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852
Subject:
Application for Revision 1 of Certificate of Compliance for the Model No. TN-40HT Package (Docket No. 71-9389)
Reference:
[1] Revision 0 of Certificate of Compliance No. 9389 for the Model No. TN-40HT
[2] TN-40HT Transportation Packaging Safety Analysis Report, Revision 0, December 2023 In accordance with 10 CFR 71.31(b), TN Americas LLC (TN) submits an application for revision to Certificate of Compliance (CoC) No. 9389 for the Model No. TN-40HT
[1].
The TN-40HT is a dual-purpose cask that is designed for use as a spent nuclear fuel storage cask and a Type B, fissile material transportation package. This revision of the 10 CFR Part 71 CoC for transportation adds a new ASME Code alternative for TN-40HT fabrication.
Changes to the Safety Analysis Report (SAR) [2] are summarized in Enclosure 1.
Preliminary changed pages are provided as Revision 1A in Enclosure 2. SAR Revision 1A changes are indicated by italicized text and revision bars. A consolidated SAR Revision 1 will be submitted upon completion of the NRC review.
Should the NRC staff have any questions or require additional information regarding this submittal, please contact Mr. Peter Vescovi by telephone at (336) 420-8325, or by e-mail at peter.vescovi@orano.group.
Sincerely, Don Shaw Licensing Manager TN Americas LLC SHAW Donis Digitally signed by SHAW Donis Date: 2024.04.25 09:25:23
-04'00'
E-63422 Document Control Desk Page 2 of 2 cc:
Pierre Saverot, Senior Project Manager, U.S. Nuclear Regulatory Commission Chris Laughlin, Project Manager, Orano TN Americas
Enclosures:
- 1.
Summary of Changes
- 2.
TN-40HT Transportation Packaging SAR, Revision 1A, Changed Pages to E-63422 Page 1 of 4 Summary of Changes to CoC 9389 TN-40HT SAR Revision 1A Summary of Changes:
This revision of the 10 CFR Part 71 CoC for transportation requests a new ASME Code alternative.
Description of Changes:
The proposed activity is to allow the use of an ASME B&PV Code Section III alternative to the surface examination requirements of NB-5130 for the TN-40HT casks, which would be captured in the TN-40HT ASME Code Alternatives table in Appendix 1.6.3 of the TN-40HT SAR. The proposed alternate tests consist of a restricted radiographic examination (RT) or a supplementary phased array UT (PAUT) examination.
NOTE: Use of this alternative is optional. The surface examination required by Paragraph NB-5130 may be used.
The shell flange side of the shell flange to inner shell weld if 2 inches (50 mm) or more in thickness at the time of welding may be exempt from the magnetic particle or liquid penetrant examination required by NB-5130, provided Conditions 1 and 2 below are met:
- 1. The shell flange is produced from a forging.
- 2. The volumetric examination of the completed weld shall be modified or supplemented under option a or b below:
- a. Radiographic examination (RT): The acceptance standard for RT of the completed weld joint shall be tightened (smaller allowance of defects). The criterion for elongated indications shall be NB-5320(b)(1) instead of NB-5320(b)(2). This tighter criterion shall be applied in addition to NB-5320(a), (c), (d), and (e), without change. In addition, tighter criteria for the selection of penetrometers per NB-5111(a) shall be applied. A 0.016-inch diameter source side image quality indicator (IQI) wire shall be used as the essential wire. The area of interest shall cover the weld, the weld volume and 0.5 inches beyond the toe of the weld on the forging side.
- b. Phased Array Ultrasonic examination method (PAUT): PAUT shall be performed on the completed weld joint with a defined area of examination of the weld surface and 0.5 inches beyond the toe of the weld on the forging side. The PAUT is in addition to completion of RT of the joint with acceptance standards of NB-5320 without modification.
The acceptance standards of the PAUT shall be NB-5331(a)(1) and (b). Later editions of the ASME Section V can be used for completion of the PAUT procedure and qualification.
Justification of Changes:
ASME Code Section V Paragraph T-720 states in part, The magnetic particle examination method may be applied to detect cracks and other discontinuities on or near the surfaces of to E-63422 Page 2 of 4 ferromagnetic materials. Typical types of discontinuities that can be detected by this method are cracks, laps, seams, cold shuts, and laminations.
Section V Paragraph T-620 states, The liquid penetrant examination method is an effective means for detecting discontinuities which are open to the surface of nonporous metals and other materials. Typical discontinuities detectable by this method are cracks, seams, laps, cold shuts, laminations, and porosity.
Paragraph NB-5130 requires either magnetic particle (MT) or liquid penetrant (PT) examination of weld edge preparation surfaces in material 2 inches (50 mm) or more in thickness. The NB-5130 examination checks for subsurface defects in thick plate that become exposed during the machining of weld preparations prior to welding. Such defects can propagate in size during the completion of a full penetration weld joint, resulting in rejection of the weld joint from the volumetric examination.
A laminar defect is the type of defect of most concern because it could have length parallel to the weld joint that results in extensive repairs upon identification. Laminar defects do exist in ferrous base metals but are commonly found only in rolled plate. It is noted that the requested code alternative is applicable to a weld preparation that is machined into a forging only, not rolled plate. Forgings, however, can have internal conditions that are remnant from the ingot formation process and consist of voids or material inclusions, but not laminar in form. Any internal condition that is detrimental in size would be identified and eliminated when the mill of origin performed the ultrasonic (UT) examination required on all forgings in Paragraph NB-2540.
Thus, it is unlikely that the surface examination requirements of Paragraph NB-5130 will find laminar defects in a forging.
Non-laminar indications could exist in a machined surface of a weld preparation. This is possible for rolled plate and forgings. The potential concern with these types of indications is a resulting lack of fusion during the completion of the weld joint. There are two outcomes when completing the full penetration weld that has a nonlaminar indication in the weld preparation. First, and most likely, is that the weld process has sufficient heat input to create weld deposition into the weld preparation, not just at the surface, and thereby eliminates the preexisting non-laminar indication in the weld preparation. The second possibility is that the non-laminar indication is not fully removed, and the imperfection is identified in the radiographic (RT) film of the weld and evaluated for acceptability in accordance with NB-5320. If the imperfection results in a rejection of the weld, the weld would be repaired. In both scenarios, the result is a final weld that meets the NDE requirements of NB-5000.
In addition, the other tests and examinations required by the ASME Code and the TN-40HT license provide assurance of the final quality of the weld. These tests and examinations are as follows:
MT or PT of the surface of the weld to the acceptance criteria of NB-5340 or NB-5350, Hydrostatic testing to 1.25 times the design pressure followed by MT or PT examination in accordance with NB-6200 and NB-5410, and Helium leak-testing per the American National Standards Institute (ANSI) N14.5 to the acceptance criteria of 10-7 reference cubic centimeters per second.
to E-63422 Page 3 of 4 These tests and examinations provide assurance that any weld defects do not exceed the maximum allowable size, that the weld has been fabricated properly by stressing the weld, and that there are no significant leak paths that could reduce the components confinement functions.
To provide further assurance of the acceptability of the final weld, the following conservative changes to the NDE required of the final weld are proposed. The fabricator could select either of the two options described below, which are found equivalent in terms of the final results of the weld:
Option 1 The first option is to tighten the radiographic acceptance standard when evaluating the area of interest with Paragraph NB-5320(b), as shown below:
NB-5320 Current Requirement NB-5320(b)(2)
Proposed Alternative NB-5320(b)(1)
Change Max indication size 0.5 inches 0.25 inches 50% reduction In addition, the penetrameter requirements of NB-5111(a) shall be tightened as shown below:
NB-5111 Current Requirement NB-5111(a)
Proposed Alternative NB-5111(a)
Change Source Side Image Quality Indicator wire size for the 1.50 inches thick material 0.032 inches 0.016 inches 50%
reduction Indications characterized as cracks, lack of fusion, or incomplete penetration remain unacceptable regardless of length.
Option 2 The second option is in addition to the standard RT examination required by NB-5000. Option 2 shall also include performance of PAUT of the weld joint and 0.5 inch from the toe of the weld on the forging side of the weld joint. The acceptance standard is NB-5331 but for an assumed plate size of 0.75 inches inclusive (NB-5331(a)(1)), thus any imperfection is unacceptable with a length exceeding 0.25 inches. Indications characterized as cracks, lack of fusion, or incomplete penetration remain unacceptable regardless of length.
It is prudent that two NDE options are proposed since the availability and capability of NDE methods and equipment can vary geographically. Either method of volumetric examination reduces the allowable indication size to 0.25 inches in the final weld and adjacent base metal of the forging side of the weld joint. Indications characterized as cracks, lack of fusion, or incomplete penetration remain unacceptable regardless of length. This alternative does not represent a reduction in quality. The code alternative allows a fabricator to eliminate an unnecessary surface examination on a weld preparation by agreeing to select source material (i.e., forging) that is recognized to be free from laminar defects and perform more conservative volumetric examinations of the final weld and adjacent base metal. Thus, no evaluations (e.g.,
structural calculations for NB-3000 compliance) are necessary since allowable imperfections are reduced by 50% from that currently allowed in NB-5000.
to E-63422 Page 4 of 4 Conclusion As an option from fully complying with NB-5130, during fabrication activities, the proposed activity requests an alternative to the ASME Code Paragraph NB-5130 requirement for magnetic particle or liquid penetrant examination of the full penetration weld edge preparation surface of the shell flange side of the inner shell to shell flange weld joint, if 2 inches (50 mm) or more in thickness at the time of welding.
It is reasonable to conclude that with the following conditions, the code alternative ensures an acceptable level of quality and safety:
- 1. The shell flange shall be made from forging material only. Plate is not allowed.
- 2. Volumetric NDE of the final weld and 0.5 inches of base metal on the side of the forging shall include one of the following two options:
- a. Option 1, RT acceptance standard uses NB-5320(b)(1) instead of NB-5320(b)(2). NB-5320(a), (c), (d), and (e) apply without modification in addition to tightened penetrameter requirements of NB-5111(a).
- b. Option 2, PAUT is performed with acceptance standard of NB-5331(a)(1) and (b) after completion of RT with acceptance standard of NB-5320 without modification.
Impact:
SAR Appendix 1.6.3 to E-63422 TN-40HT Transportation Packaging SAR, Revision 1A, Changed Pages
PUBLIC TN AMERICAS LLC 7160 Riverwood Drive, Suite 200
- Columbia, MD 21046 TN Americas LLC TN-40HT Transportation Package Safety Analysis Report Docket Number 71-9389 Revision 1A April 2024
TN-40HT Transportation Package Safety Analysis Report Rev. 1, 4/24 Page i RECORD OF REVISIONS Revision E-Document Number Transmittal Letter Date 0
E-59464 November 30, 2021 E-61956 August 1, 2023 E-62973 December 4, 2023 E-62955 December 7, 2023 1A E-63422 April 25, 2024
TN-40HT Transportation Package Safety Analysis Report Rev. 1, 4/24 Page 1.6.3-1 Code Alternatives TN-40HT ASME Code Alternatives Component Reference ASME Code/Section Code Requirement Alternatives, Justification &
Compensatory Measures TN-40HT, Basket NB/NF/NG-1100 NB/NF/NG-2130 NB/NF/NG-4121 Stamping and preparation of reports by the Certificate Holder, Use of ASME Certificate Holders The TN-40HT is not stamped, nor is there a code design specification or stress report generated. A design criteria document is generated in accordance with TN Americas (TN) Quality Assurance (QA) Program and the design and analysis is performed under TNs QA Program. The cask may also be fabricated by other than N-stamp holders and materials may be supplied by other than ASME Certificate Holders.
TN-40HT, Basket NCA All Not compliant with NCA. TN Quality Assurance requirement, are used in lieu of NCA-4000. Fabrication oversight is performed by TN personnel in lieu of an Authorized Nuclear Inspector.
Pressure Test of the Containment Boundary NB-6000 Hydrostatic testing The containment vessel is hydrostatically tested in accordance with the requirements of the ASME B&PV Code,Section III, Articles NB-6200 with the exception that some of the containment vessel may be installed in the shield shell during testing. The containment vessel is supported by the shield shell during all design and accident events.
TN-40HT Inner Shell Welds NB-5130 All full penetration weld edge preparation surfaces for joint Categories A, B, C, D, and similar joints in material 2 inches (50 mm) or more in thickness shall be examined by the magnetic particle or liquid penetrant method.
NOTE-----------------------
Use of this alternative is optional. The surface examination required by Paragraph NB-5130 may be used.
The shell flange side of the shell flange to inner shell weld if 2 inches (50 mm) or more in thickness at the time of welding may be exempt from the magnetic particle or liquid penetrant examination required by NB-5130, provided Conditions 1 and 2 below are met:
- 1) The shell flange is produced from a forging.
TN-40HT Transportation Package Safety Analysis Report Rev. 1, 4/24 Page 1.6.3-2 Component Reference ASME Code/Section Code Requirement Alternatives, Justification &
Compensatory Measures
- 2) The volumetric examination of the completed weld shall be modified or supplemented under option a or b below:
- a. Radiographic examination (RT):
The acceptance standard for RT of the completed weld joint shall be tightened (smaller allowance of defects). The criterion for elongated indications shall be NB-5320(b)(1) instead of NB-5320(b)(2).
This tighter criterion shall be applied in addition to NB-5320(a),
(c), (d), and (e), without change. In addition, tighter criteria for the selection of penetrameters per NB-5111(a) shall be applied. A 0.016-inch diameter source side image quality indicator (IQI) wire shall be used as the essential wire. The area of interest shall cover the weld, the weld volume and 0.5 inches beyond the toe of the weld on the forging side.
- b. Phased Array Ultrasonic examination method (PAUT):
PAUT shall be performed on the completed weld joint with a defined area of examination of the weld surface and 0.5 inches beyond the toe of the weld on the forging side. The PAUT is in addition to completion of RT of the joint with acceptance standards of NB-5320 without modification. The acceptance standards of the PAUT shall be NB-5331(a)(1) and (b). Later editions of the ASME Section V can be used for completion of the PAUT procedure and qualification.