ML24303A160
| ML24303A160 | |
| Person / Time | |
|---|---|
| Site: | 07109796 |
| Issue date: | 11/15/2024 |
| From: | Nishka Devaser Storage and Transportation Licensing Branch |
| To: | Plate N US Dept of the Navy, Naval Sea Systems Command |
| References | |
| EPID L-2024-LLA-0030 | |
| Download: ML24303A160 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Nicholas Plate, Group Head NAVSEA 08G Naval Sea Systems Command 1240 Issac Hull Ave. SE Stop 8021 Washington Navy Yard, DC 20376-8021
SUBJECT:
APPLICATION FOR THE CERTIFICATE OF COMPLIANCE NO. 9796, REV.
NO. 3, FOR THE MODEL NO. M-290 PACKAGE, REQUEST FOR ADDITIONAL INFORMATION
Dear Nicholas Plate:
By letter dated February 8, 2024 (Agencywide Documents Access and Management System Accession [ADAMS] No. ML24239A812), as supplemented on May 31, 2024 (ML24233A236),
the U.S. Department of Energy, Division of Naval Reactors, (DOE-NR or the applicant) requested renewal and amendment to Certificate of Compliance No. 9796 for the Model No. M-290 package.
In connection with our review, this letter is to advise you that the information needed to continue our review, described as a request for additional information, is in the enclosure to this letter.
Addressing the request for additional information does not preclude the staff from issuing further requests for additional information during the detailed technical review of this application.
In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, requests for withholding, 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 website 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.
November 15, 2024
N. Plate 2
In order to complete our technical review on schedule, your response should be provided within 30 days of the date of this letter. If you have any questions regarding this matter, I may be contacted at 301-415-5196 or at Nishka.Devaser@nrc.gov.
Sincerely, Nishka Devaser, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-9796 EPID No. L-2024-LLA-0030
Enclosure:
Request for Additional Information Signed by Devaser, Nishka on 11/15/24
ML24303A160 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME NDevaser DForsyth SFigueroa CStanko GZhao DATE 10/29/24 10/29/24 10/30/24 11/4/24 11/4/24 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME TBoyce DJohnson TGovan YDiaz-Sanabria NDevaser DATE 11/4/24 11/4/24 11/6/24 11/14/24 11/15/24
Enclosure UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Request for Additional Information Docket No. 71-9796 Model M-290 Certificate of Compliance No. 9796 Revision No. 3 By letter dated February 8, 2024 (Agencywide Documents Access and Management System Accession No. ML24239A812), as supplemented on May 31, 2024 (ML24233A236), the U.S.
Department of Energy, Division of Naval Reactors, (DOE-NR or the applicant) requested renewal and amendment to Certificate of Compliance No. 9796 for the Model No. M-290 package.
This request for additional information identifies information needed by the U.S. Nuclear Regulatory Commission staff (NRC or the staff) in connection with its review of the Safety Analysis Report for Packaging (SARP or the application). The staff used guidance provided in NUREG-2216, "Standard Review Plan for Transportation Packages for Spent Fuel and Radioactive Material, in its review of the application and during preparation of a safety evaluation report (SER) documenting this review. The staff is reviewing the application in accordance with Title 10 of the Code of Federal Regulations (10 CFR).
The questions below describe information needed by the staff for it to complete its review of the application and to determine whether the applicant has demonstrated compliance with regulatory requirements.
Structural Evaluation RAI 2-1.
Regarding the component analysis described in SARP section 2.12.2.6.7.2, provide the details of how the subject component will continue to function when the component is fractured into pieces.
The component is subject to lateral loads and bending that could result in component failure. The component analysis concedes that fracture could occur and results in several fractured component pieces but states the pieces would not translate past each other and still have the ability carry axial compression loads. The ability for the fractured component pieces to carry axial compression loads and prevent motion of connected components is relied upon to conclude the bounding configuration of package used for other analyses in the SARP. It is unclear, based on the description and analysis in SARP section 2.12.2.6.7.2, how fractured component pieces would not translate past each other and retain the ability to carry axial compression loads.
This information is needed to determine compliance with 10 CFR Sections 71.71(c)(7) and 71.73(c)(1).
2 Thermal Evaluation RAI 3-1.
Provide the most up-to-date consolidated spent fuel performance document to confirm that the margin for [REDACTED] is sufficient to meet the regulatory requirements in 10 CFR Part 71.
Naval Reactors states in five separate instances (pages 3-1, 3.2-3, 3.3-12, 3.3-13, and 3.4-4) in the SARP provided that significant margin to [REDACTED]
exists in the package contents after completion of testing for both normal conditions of transport and hypothetical accident conditions. The NRC has copies of the supporting data for this statement up to date as of 2017.
However, with the proposed Revision 2, NRC staff have determined that there is a need for the most up-to-date margin information to support the review process and complete the SER. The staff is requesting the most up-to-date spent fuel performance data and calculations supporting the request for review.
This information is needed for the staff to confirm compliance with 10 CFR 71.71 and 71.73.
Shielding Evaluation RAI 5-1.
Provide SARP figures 5.4-1 through 5.4-6 and any necessary explanation of those figures to support the conclusion that the proposed changes have negligible impact on dose rates.
The Division of Naval Reactors (NR) evaluated the dose rates with the changed configuration and compared it to the previous bounding configuration. NR states the results that show negligible effect on dose rates are presented in SARP figures 5.4-1 through 5.4-6 of the application. SARP section 5.4 and its figures, including the ones referenced in SARP section 5.3.1, are absent from the application.
This information is necessary to determine compliance with 10 CFR 71.47.