ML24159A807
| ML24159A807 | |
| Person / Time | |
|---|---|
| Site: | 07109291 |
| Issue date: | 06/03/2024 |
| From: | Pierre Saverot Storage and Transportation Licensing Branch |
| To: | Yates D Orano TN Americas |
| References | |
| Download: ML24159A807 (1) | |
Text
From:
Pierre Saverot To:
YATES Douglas (ORANO)
Cc:
VESCOVI Peter (ORANO); SEWELL Philip (ORANO)
Subject:
Request for Additional Information (RAI) LR230 Date:
Monday, June 3, 2024 2:44:00 PM
- Doug,
The 3 RAIs below are concurred by the Branch Chief. I will put the email in ADAMS and give you, in a little while, the ML No. you will refer to in your official RAI response cover letter which will include also those we have accepted (email May 29).
Please share your draft responses before preparing the consolidated SAR to be submitted to Doc. Control.
Thanks
Pierre
RAI M-1: 8.3.1.3.4 Visual Standards - The photographs are an integral part of documentation of the visual inspection, which are recorded in the inspection report forms. As the applicant states no changes were made since the inspection procedures were approved in the letter authorization of 2023, the staff requests the applicant to explain why the requirement to take photographs were removed from the visual inspections as required in the letter authorization of 2023?
For example, if the visual inspection was conducted in accordance with ASME Section XI IWA-2210 and 2211, with personnel qualified in accordance with IWA-2300 for VT-1 examinations. For VT-3 examinations may be conducted in accordance with ASME Section XI IWA-2210 and 2213, with personnel qualified in accordance with IWA-2300.
This information is needed to determine compliance with Title 10 of the Code of Federal Regulations (10 CFR), Section 71.31(c) and 71.87(b).
RAI M-2: While the applicant stated that shackles were to be changed to handles, for the change to Sheet 2, Detail X, the staff noted that shackles are still mentioned in 1.2.1.2, 2.5, Table 2.1, Appendix B Section 2.0, 7.1.2, 8.1, 8.2. The staff request that the applicant address this change consistently through throughout the application.
Additionally, regarding the change in the drawing to remove outer vessel lifting shackles and outer lid handles, the staff requests the applicant to clarify if the shackles and handles are being removed from the existing packaging(s) as well or rendered inoperable, for the change to Sheet 4, Note 3. As required by 10 CFR 71.87(h), Any structural part of the package that could be used to lift or tie down the package during transport is rendered inoperable for that purpose.
This information is needed to determine compliance with Title 10 of the Code of Federal Regulations
(10 CFR), Section 71.87(h) and 71.45.
RAI M-3: The staff request the applicant to clarify which ANSI standards will be used to the fabrication leakage test of the O-rings as described in SAR Section 7 and for the periodic leakage rate test as described in SAR Section 8.
The staff noted that in SAR Section 4, the standard described is ANSI N14.5-1997 for both leak tests performed pre-shipment, post fabrication, and periodically.
This information is needed to determine compliance with Title 10 of the Code of Federal Regulations (10 CFR), Section 71.31(c).
From: YATES Douglas (ORANO) <douglas.yates@orano.group>
Sent: Wednesday, May 29, 2024 4:28 PM To: Pierre Saverot <Pierre.Saverot@nrc.gov>
Cc: VESCOVI Peter (ORANO) <peter.vescovi@orano.group>; SEWELL Philip (ORANO)
<philip.sewell@orano.group>
Subject:
[External_Sender] Proposed Responses to Ops RAIs/Clarifications for LR-230
- Pierre, Please see below what we envision for the Ops responses and associated MUs. Hopefully, we just need to close the loop on Materials going forward after your reviewer digests the information.
In the current SAR, Section 7.1.1.a includes acceptance criteria for tears and crush depth - no tears and crush depth <= 2 inches. The proposed SAR revisions in Chapter 7 do not include any acceptance criteria for these two potential issues and the new Appendix 8.3.1 for visual inspection does not address these either.
SAR Section 7.1.2(a) changed to add back in the requirement for tears and no crush greater than 2 in.
Section 7.3 for preparing the LR for transport with residual contents describes calculating the A2 value and then performing surveys and marking, labeling, and placarding the shipment, but does not direct the user on how to perform any other actions such as installing and torquing the lid, performing the preshipment leak check if required, etc. The current SAR points back to a previous section in Chapter 7 to perform those activities but the proposed SAR does not.
SAR Section 7.3 (b) and (c) deleted and a new Section 7.3(b) added to point back to Section 7.1.3(b) through (i) for preparing the package for transport.
The last sentence of the initial NOTE in Section 7.3 states. Residual contents not exceeding
an A2 quantity may be classified as Type A or Type B, and residual contents exceeding an A2 quantity shall be classified as Type B. With regards to the first phrase of the sentence, if the residual contents do not exceed an A2 quantity, the shipment should be classified as Type A, NOT Type B. The shipper should call it what it is to ensure all the packaging/transportation regs/requirements are met as appropriate. It would also give incorrect information to emergency responders in the case of an accident and the shipment is not classified according to the actual contents.
Sentence in this NOTE revised to clarify that contents less than an A2 shall be Type A and contents greater than an A2 shall be Type B.
Typo in Section 8.2.a. 3rd sentence should state If the welds have visible cracks OR significant corrosion Currently, it has OF in place of OR that changes the meaning of the sentence.
Typo Corrected.
- Regards, Doug
Doug Yates Licensing - Orano 227 Gateway Drive Aiken, SC 29803 P: 434.832.3101 M: 803.443.9716 Douglas.Yates@orano.group
The information contained in this e-mail and any accompanying documents may contain information that is confidential or otherwise protected from disclosure. If you are not the intended recipient, please immediately alert the sender by reply e-mail and then delete this message, including any attachments. Any dissemination, distribution or other use of the contents of this message by anyone other than the intended recipient is strictly prohibited.
CONFIDENTIALITÉ L'information contenue dans ce message et ses pices jointes est confidentielle et établie l'intention exclusive de ses destinataires. Au cas o ce message ne vous serait pas destiné, nous vous remercions de bien vouloir en aviser immédiatement l'émetteur et de le supprimer. Toute copie, diffusion ou autre utilisation du contenu de ce message par toute personne autre que le destinataire est interdite.