ML24312A345
| ML24312A345 | |
| Person / Time | |
|---|---|
| Site: | 07103047 |
| Issue date: | 04/17/2024 |
| 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-63456, EPID L-2023-DOT-0008 | |
| Download: ML24312A345 (1) | |
Text
Orano TN 7160 Riverwood Drive Suite 200 Columbia, MD 21046 USA Tel: 410-910-6900 Fax: 434-260-8480 Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.
April 17, 2024 E-63456 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,
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)
Dear Mr. Boyle:
TN Americas LLC, 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) request for recommendation [2], the U.S. Nuclear Regulatory Commission (NRC) requested additional information to complete the review of the application [3].
Orano NPS letter, COR-24-0030552-000-1.0 (Enclosure 1), provides responses to part of the additional information requested. Enclosures 2 and 3 provide the documents requested. Enclosure 4 is a statement of proprietary information pursuant to 49 CFR 7.14, 49 CFR 105.30, and 10 CFR 2.390 for the additional information provided in Enclosures 2 and 3.
E-63456 U.S. Department of Transportation Page 2 of 2 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-24-003052-000-1.0
- 2. MHI Report - Plug compression test in lateral and inclination direction - TPN-15-028-Appendix A - December 2015 (Proprietary)
- 3. Calculation Note - Mechanical Resistance of the 30B Cylinder Under Accident Conditions
- 5188-B-1 Rev. 0 (English translation) (Proprietary)
- 4. Statement of Proprietary Information SHAW Donis Digitally signed by SHAW Donis Date: 2024.04.17 17:10:54
-04'00'
to E-63456 Orano NPS Letter COR-24-003052-000-1.0
www.orano.group 1 / 4 Ref. : COR-24-003052-000-1.0 Montigny-le Bretonneux, Wednesday, 10 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 first 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).
Enclosures:
English translation of Transnucléaire report reference 5188-B-1 Rev. 0
- Mechanical resistance of the 30B cylinder under accident conditions MHI Report - Plug compression test in lateral and inclination direction
- TPN-15-028-Appendix A - December 2015 - Proprietary document.
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=3BFE52C6177114A75347F 79, cn=LE MEUR Thomas Date : 2024.04.10 15:50:41 +02'00'
A www.orano.group 2 / 4 Structural Review Question RAI St-3 Provide Reference No. <2> and <5> used in the SAR Chapter 1-7 for determining the maximum acceleration limits for the 30B cylinder, and limiting impact force on the 30B cylinder plug, respectively.
Reference <2>, Transnucléaire report reference 5188-B-1 Rev. 0, Mechanical resistance of the 30B cylinder under accident conditions is used to assess increased acceleration levels for the package during a drop under minimum ambient temperature condition. Reference <5>, MHI Report - Plug compression test in lateral and inclination direction -TPN-15-028-Appendix A -
December 2015 is used to determine the limiting impact force on the 30B cylinder plug. This information is requested to confirm the 30B cylinder acceleration level limits under accident conditions, and to ensure that the model of the contact case on the plug is a conservative model with regards to the plug compression test in Reference <5> document.
This information is needed to ensure that the package meets the safety requirements of SSR-6, Para 632.
Answer Please find attached the required Reference No. <2> and <5> used in the SAR Chapter 1-7:
An english translation of Transnucléaire report reference 5188-B-1 Rev.
0: Mechanical resistance of the 30B cylinder under accident conditions MHI Report - Plug compression test in lateral and inclination direction
- TPN-15-028-Appendix A - December 2015 - Proprietary document.
www.orano.group COR-24-003052-000-1.0 3 / 4 Material Review Question RAI M-1 Regarding changes to tensile properties for stainless subcomponents of the COG-OP-30B overpack, explain the reason for the changes in the minimum yield strength and minimum tensile strength of the stainless steel structural material used for fabrication of the specific overpack subcomponents listed in the first five lines of Table 0.3 in Chapter 0 of the application and also listed in the first five lines of the first table located in Section 2.2, Materials in Chapter 1 of the application.
The staff noted that the minimum yield strength and minimum tensile strength of the stainless steel structural material used for fabrication of the specific overpack subcomponents listed in the first five lines the above-cited tables have changed from the corresponding properties that were reported in the older version of the application that was previously revalidated by the U.S. DOT.
However, the NRC staff could not determine the technical reason for the change in these properties based on review of the information provided in the application. The staff is requesting this information to confirm the validity of the updated material properties for the packaging components.
This information is requested to ensure compliance with the requirements of Paragraphs 616, 639, 640, and 648 of IAEA SSR-6, 2012 Edition.
Answer Following a request from the French Competent Authority (ASN), the aim of this change was to strengthen the analysis of representativeness of the prototypes used for testing, presented in SAR Chapter 1-1 (DOS-22-010635-005). This Chapter has been updated and the analysis of impact of differences between the prototype and the package model in Section 3 has been completed accordingly, based on these updated minimum tensile properties.
It has also been checked that the as-built mechanical properties of all these stainless steel subcomponents (Inner bottom, Central lower inner half-shell, Reinforcement plate, Reinforced upper inner half-shell, Spacer) in the fleet still meet these updated minimum tensile properties.
www.orano.group COR-24-003052-000-1.0 4 / 4 Clarification Questions Question CQ 1 In document DOS-22-010635-017, Version 1.0, a missing - (minus) sign is missing in the exponential expression of the maximum leak rate.
It should be 10-4.
Answer We confirm that there is indeed a mistake in the translation of the SAR Chapter 3A (DOS-22-010635-017, Version 1.0). In Section 5.2, the correct sentence is :
Consequently, if we assume, for the Type B package, a maximum leak rate of 2 x 10-4 Pa m3 s-1 (SLR), it can be verified that the radioactivity released under accident conditions of transport is less than a total of 1 A2 over one week., and not 2 x 104 Pa m3 s-1 (SLR).
This mistake will be corrected for the next application.
Question CQ 2 The applicant refers to the following standard throughout their SAR:
International Standards Organization, ISO 7195:2020, Packagings for the transport of uranium hexafluoride (UF6).
In document DOS-22-010635-005, Version 1.0, staff found reference to the 2005 version of ISO 7195. The applicant should double check all references to be sure that the correctly dated references are captured.
Answer We confirm that there is an inconsistency in the version date of the standards indicated in SAR Chapter 1-1 (DOS-22-010635-017, Version 1.0). 2020 version of ISO 7195 and 2019 version of ANSI N14.1 should have been considered.
This will be corrected for the next application.
It should be noted that a similar inconsistency is present in SAR Chapter 0. In Section 4, it is indicated ANSI N14.1-2012, instead of simply ANSI N14.1.
This will also be corrected for the next application.
to E-63456 MHI Report - Plug compression test in lateral and inclination direction - TPN-15-028-Appendix A -
December 2015 (Proprietary)
Withheld in accordance with 49 CFR 7.14, 49 CFR 105.30, and 10 CFR 2.390
to E-63456 Calculation Note - Mechanical Resistance of the 30B Cylinder Under Accident Conditions - 5188-B-1 Rev. 0 (English translation)
(Proprietary)
Withheld in accordance with 49 CFR 7.14, 49 CFR 105.30, and 10 CFR 2.390 to E-63456 ORANO NPS STATEMENT OF PROPRIETARY INFORMATION PURSUANT TO 49 CFR 7.14, 49 CFR 105.30, AND 10 CFR 2.390 I, Jessica Boutteau, depose and say that I am the Director Transport Operations & Business of Orano Nuclear Packages and Services (NPS), duly authorized to execute this statement of proprietary information and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. TN Americas LLC on behalf of Orano NPS, is submitting this statement of proprietary information in conformance with the provisions of 49 CFR 7.14 and 49 CFR 105.30 of the U. S.
Department of Transportations (U.S. DOT) regulations, and with the provisions of 10 CFR 2.390 of the Nuclear Regulatory Commissions (NRC) regulations. This information is exempt from public disclosure under the Freedom of Information Act, 5 U.S.C. 552, as amended, for withholding this information.
The information for which proprietary treatment is sought is listed below:
x - MHI Report - Plug compression test in lateral and inclination direction
- TPN-15-028-Appendix A - December 2015 - Proprietary document x - Calculation Note - Mechanical Resistance of the 30B Cylinder Under Accident Conditions - 5188-B-1 Rev. 0 (English translation)
This document has been appropriately designated as proprietary.
Pursuant to the provisions of paragraph 7.14 of Part 7 and paragraph (a) (3) of Part 105 of the U.S.DOT regulations, and the provisions of paragraph (b) (4) of Section 2.390 of the NRC regulations the following is furnished for consideration by the U.S.DOT and by the NRC in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.
- 1) The information sought to be withheld involves the responses to request for additional information (RAI) for Model COG-OP-30B Packaging. The information in the response to RAI is owned and has been held in confidence by Orano NPS.
- 2) The information is of a type customarily held in confidence by Orano NPS and not customarily disclosed to the public. Orano NPS has a rational basis for determining the types of information that is customarily held in confidence by it.
- 3) Public disclosure of the information is likely to cause substantial harm to the competitive position of Orano NPS because the information consists of descriptions of the design and analysis of the COG-OP-30B Packaging, as well as company business sensitive information, the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with Orano NPS, take marketing or other actions to improve their products position or impair the position of Orano NPSs product, and avoid developing similar data and analyses in support of their processes, methods, or apparatus.
Further the deponent sayeth not.
P.O______________________________
Jessica Boutteau Director Transport Operations & Business Orano Nuclear Packages and Services Witnessed by Brigitte Latour Project Manager Orano Nuclear Packages and Services Signé numériquement par : SORDELET Philippe Nom DN : CN = SORDELET Philippe O =
ORANO OU = 0002 330956871 Date : 2024.04.17 18:29:32 +02'00' SORDELET Philippe LATOUR Brigitte 2024.04.17 18:37:45
+02'00'