ML24312A343
| ML24312A343 | |
| Person / Time | |
|---|---|
| Site: | 07103047 |
| Issue date: | 04/26/2024 |
| From: | Shaw D TN Americas LLC |
| To: | Boyle R Office of Nuclear Material Safety and Safeguards, US Dept of Transportation, Pipeline & Hazardous Materials Safety Admin |
| Shared Package | |
| ML24312A342 | List: |
| References | |
| E-63506, EPID L-2023-DOT-0008 | |
| Download: ML24312A343 (1) | |
Text
Orano TN 7160 Riverwood Drive Suite 200 Columbia, MD 21046 USA Tel: 410-910-6900 Fax: 434-260-8480 April 26, 2024 E-63506 U.S. Department of Transportation Attn: Mr. Richard W. Boyle Pipeline & Hazardous Materials Safety Administration Radioactive Materials Branch 1200 New Jersey Avenue, S.E.
East Building, PHH-20 Washington, DC 20590
Subject:
Additional Information for Review of the Application for Revalidation of French Competent Authority Certificate F/358/AF-96 (Hw) for the Model No. COG-OP30B
Reference:
[1] TN Americas letter E-62147 dated March 21, 2023, from Don Shaw (TN) to Richard Boyle (DOT)
Subject:
Request for Revalidation of French Competent Authority Certificate F/358/AF-96 (Hw) for the Model No. COG-OP-30B.
[2] DOT Letter from Richard W. Boyle (DOT) to DFM Director (NRC) dated March 27, 2023, (ADAMS Accession Number: ML23255A052)
[3] NRC Letter from Nishka Devaser (NRC) to Richard W. Boyle (DOT), dated March 28, 2024,
Subject:
Application for the French Certificate of Competent Authority F/358/AF 96 Revision Hw, Model No. COG-OP-30B Package - Request for Additional Information, Docket No. 71-3047, (EPID No. L-2023-DOT-0008 and ADAMS Accession No: ML24073A363)
[4] TN Americas letter E-63456 dated April 17, 2024 from Don Shaw (TN) to Richard Boyle (DOT),
Subject:
Additional Information for Review of the Application for Revalidation of French Competent Authority Certificate F/358/AF-96 (Hw) for the Model No. COG-OP30B
Dear Mr. Boyle:
TN Americas LLC (TN), on behalf of Orano Nuclear Packages and Services (NPS),
applied in accordance with §173.473 for revalidation of the French Competent Authority Certification [1]. In response to a U.S. Department of Transportation (DOT)
E-63506 U.S. Department of Transportation Page 2 of 2 request for recommendation [2], the U.S. Nuclear Regulatory Commission (NRC) requested additional information to complete the review of the application [3].
The first part of the partial RAI responses was submitted via TN letter [4].
NPS letter, COR-24-003052-001-1.0 (Enclosure 1), provides the remaining responses to the additional information requested.
Should you have any questions or require additional information to support review of this application, please contact 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 cc:
Brigitte Latour, Senior Project Manager, Orano Nuclear Packages and Services Laurence Labbe, Senior Project Manager, TN Americas LLC Nishka Devaser, NRC Project Manager, NMSS/DSFM/SFLB Peter Vescovi, TN Americas LLC
Enclosures:
- 1. Orano NPS Letter COR-24-003052-001-1.0 SHAW Donis Digitally signed by SHAW Donis Date: 2024.04.26 14:42:32 -04'00'
to E-63506 Orano NPS Letter COR-24-003052-001-1.0
www.orano.group 1 / 11 Ref. : COR-24-003052-001-1.0 Montigny-le Bretonneux, Friday, 26 April 2024.
Subject:
RAI - COG-OP-30B Questions Revalidation of French Competent Authority Certificate French Approval Certificate Number F/358/B(U)F-96, Revision Hv French Approval Certificate Number F/358/AF-96, Revision Hw French Approval Certificate Number F/358/IF-96, Revision Hx As part of the application for validation of these French Approval Certificates, please find below a second and final set of answers to the NRC questions.
Important note:
The Drawing, Standards and more generally all the written documents transmitted as well as all the attached documents and information shared are proprietary information and must not be made public or transmitted to a third party.
Additionally, regarding transmitted standards, only one copy is permitted for the U.S. Nuclear Regulatory Commission (NRC).
Yours faithfully, T. LE MEUR Design Engineer Orano NPS Orano Nuclear Packages and Services Sige Social 9
Orano NPS 23 Place Wicklow F-78180 Montigny-Le-Bretonneux Tél. : +33 (0)1 34 96 50 00 Fax : +33 (0)1 34 96 54 50 RCS Versailles SIRET 602 039 299 00063 PALOVA
Établissement Nord-Ouest Orano NPS ZA dArmanville Rue des Entrepreneurs F-50700 Valognes Tél. : +33 (0) 2 33 88 69 88 Fax : +33 (0) 2 33 88 69 99 RCS Cherbourg SIRET 602 039 299 00105 PALOMA
Établissement Sud-Est Orano NPS CD 138B CODOLET BP 64182 F-30204 Bagnols-sur-Cze Cedex Tél. : +33 (0) 4 66 90 33 00 Fax : +33 (0) 4 66 90 32 03 RCS Nmes SIRET 602 039 299 00097 LE MEUR Thomas Nom unique :o=ORANO, ou=0002 330956871, 2.5.4.97=NTRFR-330956871, 2.5.4.45=3BFE52C6177114A7534 7F79, cn=LE MEUR Thomas Date : 2024.04.26 14:15:12
+02'00'
A www.orano.group 2 / 11 Structural Review Question RAI St-1 Provide evaluation of the overpack (OP) inner shell portion between the upper stacking supports part #1-15 and the lower stacking supports part # 2-15 under the compression test.
The Safety Analysis Report (SAR) Chapter 1, Section 5.1.4 evaluates OP support plates (Part # 1-15, 2-15) for buckling under the stacking compression load. However, the most critical element for buckling is the unstiffened portion of the OP inner shell between the parts # 1-15 and 2-15. This portion of the OP inner shell is not evaluated for buckling under the compression test. In general, all structural elements that are in the path of a load transfer from the top to the bottom should be evaluated or addressed as appropriate.
This information is needed to verify compliance with IAEA SSR-6, paragraphs 648 and 723.
Answer In accordance with the Instructions for the use of the packaging, loaded packages can be stacked up to 3 levels (see SAR Chapter 6A, DOS-20-034609-009 (English translation: DOS-22-010635-009), Section 9).
In compliance with IAEA SSG-26 (2012 Edition), paragraph 723.3, tests have been conducted on specimens in order to simulate stacking on 3 levels of empty and then loaded overpacks.
1-Configuration: empty overpacks The purpose of this test is to justify the stacking of empty overpacks.
For this test, a current stacking of empty overpacks stored for several months has been used, as shown in the picture below. The overpack at the lower level (COG-OP-30B-0033) has been controlled.
www.orano.group COR-24-003052-001-1.0 3 / 11 This overpack has been opened, and in particular the upper and lower half-shells have been inspected.
The photos below show the internal state of this overpack after stacking.
COG-OP-30B-0033 Lower half-shell COG-OP-30B-0033 Upper half-shell No deformation of the upper or lower half-overpack have been observed.
2-Configuration: overpacks loaded with full 30B cylinders For this test, the following equipment has been used:
An overpack: COG-OP-30B-0031 (arbitrarily selected).
A concrete-filled 30B cylinder: SET169B (specifically designed for test purposes). Its mass is 2,937 kg. It should be noted that the nominal mass of the 30B cylinder is 635 kg, with a maximum mass of content of 2,277 kg (see SAR Chapter 0, DOS-20-034609-007 (English translation:
DOS-22-010635-007), Section 4), totaling 2,912 kg. The mass used for this test is indeed penalizing.
www.orano.group COR-24-003052-001-1.0 4 / 11 16 identical plates (see pictures below) with a unit mass of 540 kg, totalling 8,640 kg. These plates are used to represent a weight twice that of the package, as proposed in SSG-26, paragraph 723.3. It should be noted that the maximum package mass is 4,232 kg (see SAR Chapter 0, DOS-20-034609-007, Table 0.2), totaling 8,464 kg for 2 packages. The mass used for this test is indeed penalizing.
Wooden blocks have also been used to evenly distribute the weight of the plates on the overpack supports. Their mass is neglected here.
The 30B cylinder SET169 has been placed within the overpack COG-OP-30B-0031.
The loading of plates has been performed on April 12th, at 8:30 am.
www.orano.group COR-24-003052-001-1.0 5 / 11 The unloading of plates has been performed on April 15th, at 8:00 am, resulting in a test duration of approximately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This test duration covers the period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> specified in IAEA SSR-6, paragraph 723.
After the removal of the plates, no deformation is observed on the overpack outside, as shown in the pictures below.
COG-OP-30B-0031 foot (after test)
COG-OP-30B-0031 top (after test)
Then, the overpack has been opened, and the 30B cylinder removed to verify the integrity of the overpack inside.
No deformation is observed on the overpack inner shell.
www.orano.group COR-24-003052-001-1.0 6 / 11 COG-OP-30B-0031 Upper half-shell (before test)
COG-OP-30B-0031 Upper half-shell (after test)
COG-OP-30B-0031 Lower half-shell (before test)
COG-OP-30B-0031 Lower half-shell (after test)
www.orano.group COR-24-003052-001-1.0 7 / 11 The pads have also been removed to verify the integrity of the zones underneath.
In conclusion, regarding the stacking of loaded or empty packages, these different tests show that packages at the bottom, stacked on at most 3 levels, do not present any deformations of the overpack, and in particular of the inner shell.
www.orano.group COR-24-003052-001-1.0 8 / 11 Question RAI St-2 a) Provide clarification and if required revise analysis for the tie-down that is consistent with the system provided (i.e., strapped to and supported by the transport cradles) and described in the SAR, Chapter 1-4, Section 3 and depicted in figure 1.4.1.
In the SAR Chapter 1-4, Section 3.2, the applicant evaluates shear force resistance in longitudinal direction by overpack supports (parts 2-15, 2-17 and 2-19) and by the closure belts (part 2-14) shown on the drawing in chapter 0-1. The overpack is placed on the cradles of the transport frame and secured using two straps. However, it seems that the OP at the base is neither choked in the longitudinal direction nor bolted to the transport frame. Also, it is not clear how and where the longitudinal force is transferred from the closure belt to the transport frame. In general, the OP members/welds only at the restrained members (i.e., if choked in both +/- directions or somehow restrained in those directions) should be considered effective in resisting the applied forces. Therefore, the tiedown system needs to be clarified and evaluated appropriately considering where restraints are provided and act concurrently.
Answer The overpack is not bolted to the transport frame.
In order to strengthen the tie-down analysis, we perform in the following a more conservative demonstration.
For option 1 (with fork pockets): In case of acceleration in the package longitudinal axis, the fork pocket (part 2-24) comes directly into contact with the transport cradle, which allows to restrain the overpack in this direction. Due to the geometry of the overpack supports, a stress resulting from the longitudinal force applied to the fork pocket (part 2-24) is transmitted to the overpack supports (parts 2-15, 2-17 and 2-19).
www.orano.group COR-24-003052-001-1.0 9 / 11 In case of contact, it is considered, in a conservative way, that the load is directly transferred to the less resistant part of the overpack foot i.e. the reinforcement base (part 2-15). The reinforcement support (part 2-19) is conservatively not taken into account here.
The shearing surface by side is:
= 120 x 5 = 600 ² These dimensions are taken from the COG-OP-30B overpack design drawing (SAR Chapter 0-1, 5188-05E rev. J).
The stress is taken by both sides. Considering that part 2-15 can be stressed up to its ultimate tensile strength, the maximum acceleration that the tie-down system can withstand is:
= 2 x x x 3
= 6.8 With:
- Su: ultimate tensile strength of part 2-15 = 410 MPa at 100°C in a conservative way (under NCT, the maximum temperature of the outer surface of the package is 54.6°C see SAR Chapter 2,
DOS-22-010635-011, Section 3) according to NF EN 10028-7 standard for 1.4306 stainless steel (equivalent to Z3 CN18.10 stainless steel required in the SAR Chapter 0)
- m: maximum package mass = 4,232 kg For option 2 (with supporting surfaces replacing the fork pockets): The previous demonstration remains valid, given that here, in case of acceleration in the package longitudinal axis, the reinforcement base (part 2-15) comes directly into contact with the transport cradle.
Therefore, the tie-down system can withstand a maximum acceleration of 6.8 g in the package longitudinal axis without damaging the mechanical and thermal package protection.
www.orano.group COR-24-003052-001-1.0 10 / 11 b) Clarify vertical support configuration of the package on the transport frame depicted in figure 1.4.1 of the SAR Chapter 1-4, and provide necessary information to clarify the package restraints in three directions by the transport frame.
The schematic configuration of the package strapped to the transport cradle is depicted in chapter 1-4, figure 1.4.1 without any dimensions or other details. It is not clear where the weight of the package is supported on the transport frame, i.e., It is unclear whether the package weight is supported at the cradles or at the overpack base supports directly resting on the transport frame. Also, it is unclear what are the restraint on the transport frame that interact with package components to restraint/transfer load in the longitudinal directions.
Answer During transport, the package weight is supported by the cradles as there is no contact between the overpack base supports and the transport frame (see on the previous picture).
In case of acceleration in the longitudinal axis of the package, the restraint on the transport frame is ensured by the cradles (in red in the figure below), which interacts with the overpack supports (in green in the figure below).
The restraints in lateral and vertical directions of the package are ensured by the cradles and the straps.
www.orano.group COR-24-003052-001-1.0 11 / 11 c) Provide margin of stresses in the overpack components for the strength analysis of the tie-down system using acceleration factors recommended for transport in the U.S. for the package design.
The SAR Chapter 1-4, Section 3, provides analysis for the tie-down attachment and available margin using acceleration factors of +/- 2g in longitudinal, lateral, and +2g/-3g in vertical directions. The factors provided in the application are not consistent with the minimum recommendations for transport in the U.S., as described in Safety Guide No. SSG-26, R0, Advisory Material for the IAEA Regulations for the Safe Transport of Radioactive Material (2012 Edition), Appendix IV, Package Stowage and Retention During Transport, Para IV.12 and Table IV.2.
This information is needed to verify compliance with SSR-6, paragraphs 564 and 638.
Answer The differences between the accelerations to consider for the tie-down analysis are presented in the table below:
SAR Chapter 1-4 Table IV.2 - USA case SSG-26 (2012 Edition)
Longitudinal 2 g 10 g Lateral 2 g 5 g Vertical 2 g1 2 g Acceleration in the longitudinal axis of the package In road and rail configurations, the package is transported on its flat, its longitudinal axis being perpendicular to the road. In this case, the applicable US acceleration is 5 g.
It is shown in point a) that the package can withstand an acceleration of 6.8 g in this configuration without damage.
Acceleration in the lateral axis of the package It is demonstrated in Section 3.3 of the SAR Chapter 1-4 that in this configuration the loads are taken by compression of the gussets (parts 2-5). The maximum allowable acceleration is 15 g, which covers the US accelerations.
There is no risk of overpack deformation, nor risk of gusset buckling.
Vertical acceleration The demonstration in Sections 3.4 and 3.5 of the SAR chapter 1.4 is done for an acceleration which covers the US requirements (see table above).
1 3 g vertical downwards (weight of package taken into account)