ML24222A719

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Enclosure 2 - Request for Additional Information Robatel RT-200 Type B(U) Cask - Non-Proprietary
ML24222A719
Person / Time
Site: 07109384
Issue date: 08/30/2024
From:
Storage and Transportation Licensing Branch
To:
Robatel Technologies
Shared Package
ML24222A717 List:
References
EPID L-2024-NEW-0003, CAC 01029
Download: ML24222A719 (1)


Text

Enclosure 2 Request for Additional Information Robatel Technologies, LLC Certificate of Compliance No. 9384 Docket No. 71-9384 Revision No. 0 Model No. RT-200 Type B(U) Cask This request identifies additional information that is needed by the U.S. Nuclear Regulatory Commission (NRC) staff in connection with its review of the application. The NRC staff used NUREG-2216, Standard Review Plan for Transportation Packages for Spent Fuel and Radioactive Material, in its review of the application.

Each question describes information needed by the NRC staff to complete its review of the application and to determine whether the applicant has demonstrated compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 71.

The questions are listed by technical discipline of review.

General Information (G)

RAI-G-1 Clarify where the information related to impact limiters is discussed.

The applicant in safety analysis report (SAR) section 1.2.1.1 stated that the two impact limiters consist of stainless-steel casings filled with foam. However, section 3.1 states that the impact limiters are made from a foam material as detailed in Chapter 8, section 8.5.1.

This information is required by the staff to determine compliance with 10 CFR 71.33.

Structural Evaluation (St)

RAI-St-1 Provide the details of how the hypothetical accident conditions (HAC) puncture test satisfied 10 CFR Part 71.73(c)(3).

In safety analysis report (SAR) section 2.7.3.1.1.2, 3D Puncture Model Boundary Conditions, the puncture load is applied to a 150 mm diameter region which corresponds to a 150 mm diameter pin. The load is simulated with an evenly distributed pressure load equal to the dynamic flow stress of the pin. The dynamic flow stress is taken to be 324 MPa corresponding to 5% plastic deformation in the pin. Explain the methodology for calculating the 5% deformation of the pin as a result of the impact considering the 1-m drop required by the regulation.

This information is needed to determine compliance with 10 CFR Part 71.73(c)(3).

RAI-St-2 Provide the details of how the finite elements (FE) model impact limiter reaction force is applied.

2 In SAR section 2.6.7.2.2.3, Impact Limiter Reaction Force, the applicant stated that during impact, the shock absorber is crushed between the cask body and the ground surface. Thus, for each drop case, the impact limiter generates a force distributed over the surface of the cask body which depends on the crush depth and cask orientation. In RT-200 NTE 2004, RT-200 -

Cask Body Calculations, Revision B, section 6.3.2.3, Impact Limiter Reaction Force, the applicant stated that the load is distributed over the area corresponding to the projected area where the impact limiter contacts the ground. The projected areas are highlighted in the pictures in the same section. For the end-drop, the load is applied to the area parallel to the impact area with the ground. For other drop tests, the projected areas of impact are not in a single plane.

Provide details of how the projected areas of impact were estimated in cases where the impact involves more than one plane.

This information is needed to determine compliance with 10 CFR Part 71.71(c)(7) and 71.73(c)(1).

RAI-St-3 Provide the time step used for the transient analysis, clarify whether an implicit or explicit solution mode was selected and why such solution is selected for this analysis.

In SAR section 2.6 NORMAL CONDITIONS OF TRANSPORT, and 2.7 HYPOTHETICAL ACCIDENT CONDITIONS, the same methodology of two-step analysis is used for various drop analyses. These two analyses include a calculation of the crushing forces and g-loads of the cask RT-200 NTE 2101, Drop Calculations, and a structural FE analysis RT-200 NTE 2004, Cask Body Calculations, using the first calculation result as an input. Applicant stated that, with all other boundary conditions applied, a transient structural analysis is performed using Impact Limiter Reaction Force vs. time curve as analysis input. In RT-200 NTE 2101, RT-200 - Drop Calculations, Revision B, sections 7.1.1 to 7.2.3, various drop test result curves are presented using a 0.01ms time step. However, in RT-200 NTE 2004, RT-200 - Cask Body Calculations, the time step is not identified for transit analysis. In addition, it is not clear whether an explicit or implicit method is used for transient analysis and whether the performed analysis is suitable for such a short duration of the impact load.

This information is needed to determine compliance with 10 CFR Part 71.71(c)(7) and 71.73(c)(1).

RAI-St-4 Explain why the prying force of the lid is generating a compression stress in the bolt.

In RT-200 NTE 2005, RT-200 - NTE Bolt Evaluation, Revision B, section 6.1.1, NCT Load Combination for Closure Lid Bolts, the Fap_c caused by the prying action of the lid is 24.1 kN/bolt. In section 6.1.1, HAC Load Combination for Closure Lid Bolts, the Fap_c caused by the prying action of the lid is -209.1 kN/bolt. This difference led to a larger bolt tension force of 348kN/bolt in the NCT condition compared to a smaller bolt tension force of 335.7kN/bolt in the HAC condition. The negative value of tension force for HAC condition indicates that the bolt is subject to compression and the prying action is helping to reduce the tension. Similar situations are also stated for the cover plate bolts. Figure III.10 of NUREG-6007 shows the bolt is in tension in both inward and outward load conditions. It is not clear how compression is generated by the prying action.

3 This information is needed to determine compliance with 10 CFR Part 71.71(c)(1), 71.71(c)(2),

71.71(c)(3), 71.71(c)(4), 71.71(c)(5), 71.71(c)(7), 71.73(c)(1), 71.73(c)(3), and 71.73(c)(4).

Thermal Evaluation (Th)

RAI-Th-1 Provide the radiant heat transfer equation and inputs used for radiation heat transfer modeling during normal conditions of transport (NCT) and the fire hypothetical accident condition (HAC),

including the cooldown period.

(A) Although section 3.4.2 of the application and section 3.2 of the thermal calculation document (RT-200-NTE 3002 Rev. C) provided convection heat transfer rates during NCT and HAC and discussed the temperatures associated with radiant heat transfer to the ambient, a description of the ANSYS numerical radiation modeling method, the radiant heat transfer equation (e.g., Stefan Boltzmann), and how the emissivity and absorptivity were used in the equation (including the fire emissivity, which was not clearly specified), should be provided in order to clarify the implementation of radiant heat transfer in the thermal model.

(B) Equation 1 of the thermal calculation document (RT-200-NTE 3002 Rev. C) appears to imply that adjacent surfaces have the same emissivity values. However, some of the opposing surfaces that form the gaps described in section 6.3.1 and figure 4 of the thermal calculation document would have different emissivity/absorptivity surface values.

These surface values should be specified (i.e., some were not provided) and clarified that their (different) values would not impact the results of the thermal analysis.

This information is needed to determine compliance with 10 CFR 71.35.

RAI-Th-2 Clarify that the package is open to the ambient during transport and there are no covers that would adversely affect thermal performance of the package.

Although safety analysis report (SAR) section 1.2.1.5 indicated that personnel barriers are not required to meet dose limits, it was not clear to the staff if a covering is used during transport operations. Correspondingly, it was not clear in SAR Chapter 7, Package Operations, whether evaluations would be performed to ensure a covering, if it were to be used, would not adversely affect thermal performance of the package.

This information is needed to determine compliance with 10 CFR 71.35.

RAI-Th-3 Clarify that the emissivity and absorptivity of the packages outer surface will be maintained during operations.

Thermal calculation document (RT-200-NTE 3002 Rev. C) section 6.6.3 and table 8 stated that the thermal analyses were based on the packages outer surface having an absorptivity of 0.4.

Considering that the condition of the packages outer surface can change over time due to exposure with the ambient and that a 0.4 absorptivity value may not exist after the fire due to

4 soot, there was no sensitivity analysis performed regarding absorptivity and thermal performance and no clarification in the SARs Acceptance Tests and Maintenance Program chapter that procedures are in place to ensure the surfaces low absorptivity value.

This information is needed to determine compliance with 10 CFR 71.35.

RAI-Th-4 Provide details of the non-metallic content that can be pyrophoric in nature and that may auto-ignite or undergo phase transformations and clarify measures that ensure the content does not result in adverse operations during transport.

SAR section 1.2.2.2.10 stated that pyrophoric radionuclides may be present as content in residual amounts less than 1% by weight. In addition, content may include materials that can auto-ignite or undergo phase transformations at temperatures less than 140 °C. Staff notes that the modeling assumption of applying a flux to the inner package surface (rather than modeling a volumetric source) may not provide a bounding content temperature; therefore, it is not certain that content temperature would be sufficiently less than the above-mentioned 140 °C, especially during the fire HAC. In addition, and recognizing a 1% by weight quantity does not necessarily indicate negligible adverse effects, there was little information regarding these contents and the measures to ensure their presence would not be detrimental to the safe function of the package.

Likewise, there was no explicit mention of the acceptance criteria for limiting this content in SAR Chapter 7, Package Operations.

This information is needed to determine compliance with 10 CFR 71.35.

Editorial comment: The meaning or intent of SAR section 3.4.3.2.4 text According to 0 was not clear.

Containment Evaluation (Co)

RAI-Co-1P1 Provide the amount of time that the O-ring temperature can remain above the normal/continuous operations maximum allowable temperature limit and up to [Information Withheld Pursuant 10 CFR 2.390] (depending on the O-ring manufacturer) in the application (e.g., SAR section 4.6.3). Also, clarify consistency of the allowable elastomer O-ring temperature range between SAR table 4.6.3-1 and SAR section 8.1.5.2, for normal/continuous operations.

The applicant provided the operating temperatures from three different manufacturers data documents in SAR section 4.6.3.2 and defined the temperature range of ethylene-propylene-diene-monomer (EPDM) in SAR table 4.6.3-1 which shows an elastomeric O-ring temperature range [Information Withheld Pursuant 10 CFR 2.390], depending on the O-ring manufacturer, for a short period of time. However, the amount of time for the short period has not been provided for each O-ring manufacturer.

However, the applicant stated, in SAR section 8.1.5.2, that the normal/continuous operating 1 RAIs containing or referencing proprietary information are identified with the letter P.

5 temperature shall be in a narrower allowable temperature range of -40 °C to 120 °C (SAR chapter 8 is included in Certificate of Compliance).

This information is required to determine compliance with 10 CFR 71.51(a)(1) and (a)(2).

RAI-Co-2 Define the containment boundary components of the RT-200 package more precisely in SAR chapter 4. Also, clarify whether the closure bolts associated with the lid, vent port cover plate, and drain port cover plate are part of the containment boundary components.

The applicant stated, in SAR section 4.1.1, that the package containment system is defined as the containment vessel (the inner shell, the rear forging plate, and the front forging flange),

together with the associated lid, O-ring seals and lid closure bolts. The applicant also described the containment welds and O-rings in SAR section 4.1.3.

However, SAR figure 4.6-1 appeared to indicate that the containment boundary components include the following: the containment vessel (the inner shell, the rear forging plate, and the front forging flange) together with the lid, the inner O-ring seals for the lid, vent port cover plate, and drain port cover plate, the cover plates at vent port and drain port, and the containment welds. It could be clearer to, in addition, describe the entire containment boundary in SAR section 4.1.1, as is briefly described in section 1.2.1.3 of the SAR.

The American National Standards Institute (ANSI) N14.5, American National Standard for Radioactive Material - Leakage Tests on Packages for Shipment, defines the containment boundary as The designated boundary of the containment system, which is designed to prevent leakage of radioactive material. The containment boundary may include the containment vessel, shell, welds, seals, lids, cover plates, and valves. This basically means items that are in contact with the fluid being contained, and the lid bolt, and the vent and drain port cover plate closure bolts are not in contact with the fluid. The lid closure bolts and the vent and drain port closure bolts are part of the closure system though that compresses the containment boundary O-rings, which are part of the containment boundary.

The application should clarify whether the closure bolts associated with the lid, vent port cover plate and drain port cover plate are part of the containment boundary components (these bolts are not shown in SAR figure 4.6-1).

This information is required to determine compliance with 10 CFR 71.33(a)(4) and 71.43(c).

RAI-Co-3 Provide responses on items (A) and (B) below, which are related to package draining and hydrogen gas generation, as described in SAR sections 4.5, 4.6.6, and 7.5, to ensure that hydrogen generation in the package cavity will be below 5 volume percent (vol%) throughout the entire shipping period:

(A) describe the procedure in the application (e.g., SAR chapter 7) for verification that a dewatering criterion of 10% or less is met through the draining operation, and

6 (B) provide adequate information to justify the assumption that the energy absorbed from alpha particles is defined by a 0.01 fraction or consider a conservative approach to assume that all decay energy is in the form of alpha decay (

= 1.0 and Geff, = 1.60).

The applicant described hydrogen gas generation in SAR sections 4.5 and 7.5.1 and provided example of hydrogen gas generation calculations in SAR sections 4.6.6 and 7.5.2. The applicant referred to NUREG/CR-6673, Hydrogen Gas Generation in TRU Waste Transportation Packages, to derive equations for the effective G value (Geff) and the maximum allowable shipping time (tmax), assuming that the package is drained with a dewatering criterion of 10%, a fraction of 0.01 for the decay energy due to alpha decay (GH2 = 1.60) and a fraction of 0.99 for the decay energy due to beta and gamma decay (GH2 = 0.45).

Section 3.3.1.1 of the NUREG/CR-6673 notes: In many instances, detailed information concerning the radionuclides and their concentrations in a waste material may be unavailable, and determination of the separate decay fractions (

) may not be possible. For most waste types and waste configurations, a conservative approach is to assume that all decay energy is in the form of alpha decay, but the conservatism of this approach needs to be justified.

This information is required by the staff to determine compliance with 10 CFR 71.43(d).

RAI-Co-4 Describe the alternative method used to determine the shipping time to reach the required hydrogen concentration of 5 volume percent (vol%), in accordance with NUREG/CR-6673, and clarify that similar results to the method in SAR section 7.5 would be achieved.

The applicant stated, in SAR section 7.5.3, that alternatively, the user can follow another applicable method in accordance with NUREG/CR-6673 to determine the shipping time to reach the required hydrogen concentration of 5 vol%. However, the applicant does not provide sufficient details of the alternative process and procedures in the application to ensure similar performance would be achieved. The applicant should provide details of the alternative method in the SAR (e.g., chapter 7 or chapter 8) for users to follow.

This information is required to determine compliance with 10 CFR 71.43(d).

RAI-Co-5 Clarify the following items in table 8.3.2-1 of the SAR to be consistent with ANSI N14.5.

SAR table 8.3.2-1 provides the maximum leakage rate of 1 x 10-3 ref-cm3/sec for the vent/drain ports and the maximum leakage rate of LHe (e.g., 1.0 x 10-7 ref-cm3/sec) for the vent/drain port cover plates. SAR figure 4.6-1 illustrates that the vent (or drain) port cover plate is located next to the vent (or drain) port to cover the vent (or drain) port. It is unclear to the staff:

(A) Why the allowable leakage rate of LHe for the vent/drain port cover plates is different from the allowable leakage rate of 1.0 x 10-3 ref-cm3/sec for the vent/drain port.

(B) How the leakage rates are measured at the vent/drain ports and at the vent/drain port cover plates when the maximum allowable leak rates are different, and the ports are covered/enclosed by port cover plates?

7 (C) Whether the vent and drain ports in the sixth row of table 8.3.2-1 refer to the lid, vent and drain port O-rings and whether they are tested to: No leakage at a sensitivity (< 1x10-3 ref-cm3/sec), or (< LHe).

(D) Whether the empty cask, cask lid, vent port cover plate, and drain port cover plate material in the seventh row needs to be tested annually, or alternatively, whether this row refers to a combination of: 1. the ANSI N14.5 periodic leakage rate testing on the lid, vent, and drain port O-rings performed within 12 months prior to shipment and 2. the ANSI N14.5 maintenance leakage rate testing performed prior to returning a package to service following maintenance, repair, or replacement of components of a containment boundary. Describing the ANSI N14.5 periodic leakage rate testing in one row and ANSI N14.5 maintenance leakage rate testing in another row could be a clearer option.

(E) Whether the two rows, at the bottom of SAR table 8.3.2-1, that describe the pre-shipment leakage rate testing on Cask Lid and Vent and Drain Port Cover Plates, refers to the associated O-rings.

This information is necessary to clarify that the containment boundary components are being tested in accordance with ANSI N14.5.

This information is required to determine compliance with 10 CFR 71.51(a)(1) and (a)(2).

RAI-Co-6 (A) Describe/provide either the methodology or the procedure, used to determine the helium permeation time for the elastomeric O-rings, in the application (e.g., SAR chapter 7) for the users to follow.

(B) Provide source books or References with pages showing the permeation time of the elastomeric O-rings used for RT-200 package.

(C) Provide the procedures in SAR chapter 7 or 8 to distinguish the permeation from the helium leakage for the helium leakage rate test.

The applicant stated, in SAR section 8.1.4, that (1) the containment system includes the elastomeric O-rings and therefore permeation can be a problem when a leakage rate test procedure is being used to demonstrate that the system is leak tight, and (2) the degree of permeation is affected by seal material, seal surface area, time, and temperature. The applicant referred to recommendations of ANSI N14.5 to be considered to eliminate permeability as a factor in leakage rate measurements, and stated, in SAR section 8.1.4, that the test duration should be such as (System Response Time < Test Duration < Helium Permeation Time).

The staff accepts that the test duration should be such as (System Response Time < Test Duration < Helium Permeation Time). However, instead of the statement that the degree of permeation is affected by seal material, seal surface area, time, and temperature, the applicant needs to describe either the methodology or the procedure, used to determine/derive the helium permeation time, for the users to follow at their own loading operations (e.g., maintenance and periodic leakage rate tests). The applicant needs to provide source books or References with pages illustrating the permeation time of the elastomeric O-rings used for RT-200 package.

The applicant needs to provide information, requested above, in the application (e.g., SAR

8 chapter 7) to ensure that the derived helium permeation time for the elastomeric O-rings is acceptable and the helium leakage rate testing is reliable at the sites.

This information is required to determine compliance with 10 CFR 71.51(a)(1) and (a)(2).

RAI-Co-7 Provide the procedures of the leakage rate tests in the application (e.g., SAR chapter 8). The procedures should describe measurement of the helium leak rate (step by step) when the tracer gas used in the leakage rate test is a mixture of helium and air.

The applicant stated, in SAR section 4.4.2, that the leakage tests may be performed with an air/helium mixture and the helium component (LHe) of this leak rate (Lmix) is determined by multiplying the leak rate of the mixture by the ratio of the helium partial pressure to the total mix pressure (LHe = Lmix PHe / Pmix).

The applicant noted, in SAR section 8.1.4, that the partial pressure of the tracer gas (e.g.,

helium) in the envelope should be at least 10% of the total gas pressure and must be known, consistent with the statement by ANSI N14.5 (section A.3.6) that the partial pressure of tracer gas in the test mixture should be at least 10% of the total pressure and must be known.

Besides providing an example calculation of the air/helium mixture in SAR section 4.4.2, the applicant needs to provide procedures of the leakage rate tests using the air/helium mixture in the application (e.g., SAR chapter 8).

This information is required to determine compliance with 10 CFR 71.51(a)(1) and (a)(2).

RAI-Co-8 Describe or revise the use of the term, Welded seals, in SAR section 8.1.5.2.

The applicant stated, in SAR section 8.1.5.2, that in the case of welded seals when manufacturing large diameter O-rings from a single cord, the joint must be made using hot vulcanization. Gluing is prohibited. However, the applicant has not described the use of welded seals for containment boundary components in other parts of the application.

This information is required to determine compliance with 10 CFR 71.33(a)(4) and 71.51(a)(1) and (a)(2).

RAI-Co-9 Provide the O-ring compression, the groove dimensions, and the groove dimension tolerances of the O-rings located at lid and the vent/drain ports in SAR chapter 4 and license drawings.

The applicant stated, in SAR section 4.1.4, that the lid is attached to the cask body by thirty M42 round head hex bolts. Two concentric elastomer O-rings are retained in machined grooves at the lid perimeter. Groove dimensions prevent over-compression of the O-rings by the closure bolt preload forces and hypothetical accident impact forces.

The applicant stated, in SAR section 4.1.4, that the two quick-disconnect valves are housed under a stainless-steel cover plate. The two quick-disconnect valve cover plates are attached to the cask body with six equally spaced M16 round head hex bolts. Two concentric elastomer O-

9 rings are retained in machined grooves at the cover plate perimeter.

The applicant listed torque requirements for the lid and cover plate bolts in table 1.3-5 in SAR Appendix 1.3.8.

The applicant needs to provide the O-ring compressions, the groove dimensions, and the groove dimension tolerances of the O-rings located at the lid and at the vent/drain ports in SAR chapter 4 and license drawings for review to ensure there is no over-compression of the O-rings under NCT and HAC.

This information is needed to determine compliance with 10 CFR 71.33.

Materials Evaluation (Ma)

RAI-Ma-1 Provide the materials specifications (SA240, SA479, etc.) for important to safety (ITS) materials in RT-200 Bill of Materials, Section 1.3.3 of the SAR.

The applicant described the fabrication of the RT-200 system in SAR Section 2.1.4, and stated that containment components are fabricated in accordance with ASME Boiler and Pressure Vessel (B&PV) Code,Section III, Subsection NCD and non-containment components in accordance with Subsection NF. The staff understands that these applicable subsections of ASME B&PV Code require materials that conform to the requirements of one of the specifications for materials given in ASME B&PV Code,Section II Part D per Section NCD-2121 and Section NF-2121, respectively. However, the applicant did not provide the material specifications for the ITS materials in the SAR. The staff needs the materials specifications for ITS materials in RT-200 Bill of Materials, Section 1.3.3 of the SAR to verify that the package is designed and constructed in accordance with ASME B&PV Code,Section III.

This information is needed to confirm compliance with 10 CFR 71.31(c), 71.33(a)(5), 71.35(a),

71.51(a).

Operations (Op)

RAI-Op-1 Revise section 7.1.1.3, Drain and Vent Port Cover Plate Removal, section 7.1.2.3, Cask Lid Replacement, and section 7.1.2.5, Drain and Vent Port Cover Plate, to point the user to follow the prerequisite steps in section 7.1.1, when damage and remediate as appropriately is mentioned these sections. Operational steps in section 7.1.1 will require the user to perform maintenance leakage rate testing in accordance with section 8.2.2.1 prior to returning a package to service following maintenance, repair (such as a weld repair), or replacement of components of a containment boundary.

The applicant in SAR sections 7.1.1.3, Drain and Vent Port Cover Plate Removal, 7.1.2.3, Cask Lid Replacement, and 7.1.2.5, Drain and Vent Port Cover Plate Replacement, stated in part, that when signs of damage and remediate as appropriate but does not point to specific section of the SAR for the user to follow for remediate actions.

This information is needed to meet the requirements of 10 CFR 71.87 and 71.111.

10 RAI-OP-2 Clarify or modify the removal and replacement procedures for the impact limiters.

Section 7.1.1.2 describes a general procedure for removing/replacement of front and rear impact limiters; however, the operational procedure does not provide the loading sequence operations for removal of each impact limiter and securing the cask to prevent dropping or damage. If rear impact limiter is removed prior to the front impact limiter or vice versa, indicate how the package will be lifted, and cask secured and protected from damage. Provide detail sequence of steps illustrated by a visual diagram of the loading operation.

This information is needed to meet the requirements of 10 CFR 7.87 and 71.111.

RAI-OP-3 Describe/provide the methodology or procedure in SAR section 7.1.1.5, for removing freestanding water from the basket.

The applicant in SAR section 7.1.1.5 stated that the basket and the interior of the cask shall be visually inspected to verify they are undamaged, free of debris, and freestanding water removed. However, the applicant did not include operational steps for removing freestanding water from the basket.

This information is needed to meet the requirements of 10 CFR 71.111.

RAI-OP-4 Discuss the need to prevent contamination during unloading.

(A) The potential for release of radioactive gases, volatiles, etc., as well as combustible gases, from the package during unloading (such as quick-disconnect valve failure, etc.) of contents should be discussed, especially in Section 7.2.2 (B) If available, provide field data that shows the activity from the void/headspace from a package with the proposed contents.

This information is needed to meet the requirements of 10 CFR 71.43(d), (f) and 71.51.

RAI-OP-5 Provide instructions in Chapter 7 that indicate contents are limited such that the concentration of combustible gases must be below 5%, by volume, at the end of the shipping period.

Chapter 7 should provide instructions to indicate that contents are limited such that the concentration of combustible gases must be below 5%, by volume, at the end of shipping period.

This information is needed to meet the requirements of 10 CFR 71.43(d).

11 RAI-OP-6 Provide operational steps in Chapter 7 after completion of last operation and before preparation of transport, to confirm the package has been loaded and closed in accordance with written procedures and that the final configuration is as shown in the SAR drawings.

This information is needed to meet the requirements of 10 CFR 71.87(f).

RAI-OP-7 Provide additional operational procedures in section 7.4 related to: 1) removing package from the transport trailer, 2) reloading of package onto the transport trailer, and 3) tightening methods and equipment for torquing of components such as bolts and the acceptance criteria.

This information is needed to determine compliance with 10 CFR 71.43(f) and 71.51.

Acceptance and Maintenance Tests (AM)

RAI-AM-1 Provide the methodology or procedure for conducting leak rate test to be performed during fabrication, assembly and maintenance of RT-200 components. The procedure should include the test methodology, precautions, pre-test inspections, test parameters, personnel qualifications and acceptance criteria for the user to follow.

The applicant stated in SAR sections 8.2.2.1 and 8.2.2, that the test methods, leak test sensitivity and test acceptance criteria for all applicable equipment to be tested annually or after maintenance are located in Table 8.3.2-1. However, the leak test discussion in Chapter 7 and 8 lacks details as evidenced further in subsequent RAI comments. Confirm that appropriate leak testing procedure is established, per quality assurance requirements.

This information is needed to meet the requirements of 10 CFR 71.87 and 71.111.

RAI-AM-2 Clearly indicate the dimensions, design criteria, fabrication criteria, and acceptance tests required for all important to safety, non-standard materials and components.

The Bill of Materials indicates O-rings, impact limiter foam, fusible plug and ceramic paper as non-standard items. In order to adequately describe the proposed design, provide either the detailed drawings showing dimensions, or include specific reference to the desired part. If a reference is provided, enough detail is needed to understand the design details of the specific component. Further, an understanding of the data that is used to develop material properties, design allowable, and acceptance tests for these components is needed. In SAR section 4.6.3.1, the applicant specifies elastomer seals from Parker, Trelleborg, and James Walker.

However, section 8.1.5 does not discuss the method of procurement of these non-standard components to ensure the materials meets all specifications critical to safety.

A description of those tests that are required to ensure the safety of the package is needed in Chapter 8 of the application. This can be accomplished by detailing the tests in Chapter 8. For

12 example, for the impact limiter foam, a test matrix of the formulation, batch and pour tests required to ensure that the desired properties are achieved could be provided. Acceptance tests may also be proposed for the seals and the carbon fiber thermal shield. Alternatively, if this information is already contained in another document such as a commercial-grade dedication plan, that document can be referenced and provided as an appendix to Chapter 8. For procurement of non-standard materials used in RT-100 package, the applicant in RT-100 SAR section 8.1.5 stated that for these materials a commercial-grade dedication (CGD) plan is prepared to ensure that materials meet all specifications critical to safety and the CGD plan is prepared in accordance with RT quality assurance program requirements.

This information is needed to meet the requirements of 10 CFR 71.31(c), 71.33 (a)(5), 71.71, 71.73, and 71.85.

RAI-AM-3 Provide in details test methods, test standards, and acceptance criteria for verifying the physical characteristics of the O-rings in SAR Chapter 8 for test personnel to follow. Provide any supplementary physical properties tests to be performed to meet service requirements. In addition, the SAR should identify specific provisions of the quality assurance program requirements used in all aspects of the packaging testing.

The applicant stated in SAR section 2.2.2.1 that RT-200 utilizes seals formed from EPDM, a synthetic rubber elastomer. In section 4.6.3 the applicant provides information on the O-rings manufacturer, operating temperature range, gap permeability and compression set for the material. However, the SAR needs to include the test methodology, applicable test standards, and acceptance criteria for verifying the different critical characteristics (physical properties) of O-rings to ensure when fabricated they will provide positive sealing function.

This information is required to determine compliance with 10 CFR 71.51(a)(1) and (a)(2).

RAI-AM-4P Describe/provide the acceptance standards and tolerance for verifying specific heat and thermal conductivity for ceramic paper.

The applicant listed in SAR section 1.3.3 the ceramic paper material to be [Information Withheld Pursuant 10 CFR 2.390] ceramic fiber paper. Further, in tables 3.5-1 and 3.5-4 the applicant lists the temperature independent and temperature dependent material properties of the ceramic paper. However, the applicant has not specified the test methods, the test standards to be used and the acceptance criteria in SAR Chapter 8 or other parts of the application for the user to follow.

This information is needed to meet the requirements of 10 CFR 71.51 and 71.123.

13 RAI-AM-5 Provide the acceptance test mechanical and chemical properties of the different stainless-steel materials for shells, forgings, fasteners or provide a link to specific sections of the SAR for the test personnel to follow.

The applicant stated in SAR section 8.1.5.5 that all steel materials used for the RT-200 shells, forgings, lid, cover plates, trunnions, and bolts shall conform to the respective ASME or ISO standard selected for each component. However, the applicant does not provide detail mechanical and chemical properties of individual type of components and the acceptance criteria for the test personnel to follow.

This information is needed to meet the requirements of 10 CFR 71.123.

RAI-AM-6 Confirm that detailed procedures, that would provide guidance to convert pressure rise test data to leakage rates, are available to package users.

Section 8.2.2.2 does not provide guidance for determining the leakage rate from pressure rise data. It is the leakage rate, however, that must be compared to the acceptance criteria in Table 8.3-1. The equation to determine the leakage rate from pressure rise data should be provided in Chapter 8 or in detailed procedures that are available to package users.

This information is required by the staff to determine compliance with 10 CFR 71.87.

RAI-AM-7 Provide reasonable justification for limiting the use of COFREND standard for certifying personnel for leakage testing of the RT-200 in Section 8.1.4 instead of American Society for Nondestructive Testing (ASNT) or revise the section of the SAR.

The applicant stated in SAR section 2.6.7.1 that the RT-200 is designed in accordance with the ASME Boiler and Pressure Vessel (B&PV) Code Section III, Division 1, and Regulatory Guide (RG) 7.6. The codes and standards used in the design of the RT-200 cask are selected based on guidance provided in the ASME Code [Ref. 13], RG 7.6 [Ref. 14] and NUREG/CR-3854 [Ref.

17] for packages transporting Category II contents.

RG 7.6 endorses the use of ASME B&PV Code Section III. ASME B&PV Code Section III, Division 1, Class 3, Subsection ND-5520 specifies personnel performing nondestructive examinations shall be qualified in accordance with the recommended guidelines of ASNT SNT-TC-1A, Recommended Practice for Nondestructive Testing. The endorsement of ASME Code Section III allows the applicants for and Certificate of Compliance holders to use ASNT SNT-TC-1A referenced in the ASME Code for qualifying personnel performing nondestructive testing including leakage testing. COFREND standard has not been evaluated and approved by the Nuclear Regulatory Commission for U.S. commercial use.

This information is needed to meet the requirements of 10 CFR 71.87.