ML24337A184
| ML24337A184 | |
| Person / Time | |
|---|---|
| Site: | 07109316 |
| Issue date: | 12/16/2024 |
| From: | Yoira Diaz-Sanabria Storage and Transportation Licensing Branch |
| To: | Hedger T Alpha-Omega Services |
| Shared Package | |
| ML24337A183 | List: |
| References | |
| EPID L-2024-LLA-0029 | |
| Download: ML24337A184 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Troy Hedger, President Alpha-Omega Services, Inc.
9156 Rose Street P.O. Box 789 Bellflower, CA 90706
SUBJECT:
CERTIFICATE OF COMPLIANCE NO. 9316, REVISION NO. 13, FOR THE MODEL NOS. AOS-25A, AOS-50A, AOS-100A, AOS-100B, AND AOS-100A-S PACKAGES
Dear Troy Hedger:
As requested by your application dated September 9, 2024, (Agencywide Documents Access and Management System [ADAMS] Accession No. ML24253A154), enclosed is Certificate of Compliance (CoC) No. 9316, Revision No. 13, for the Model Nos. AOS-25A, AOS-50A, AOS-100A, AOS-100B, and AOS-100A-S packages. Changes made to the enclosed certificate are indicated by vertical lines in the margin. The U.S. Nuclear Regulatory Commission staffs safety evaluation report is also enclosed.
The approval constitutes authority to use the package for shipment of radioactive material and for the package to be shipped in accordance with the provisions of Title 49 of the Code of Federal Regulations (49 CFR) Section 173.471.
If you have any questions regarding this certificate, please contact Martin Ortiz Gonzalez of my staff at (301) 415-3637.
Sincerely, Yoira Diaz-Sanabria, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-9316 EPID - L-2024-LLA-0029
Enclosures:
- 1. CoC No. 9316, Rev. No. 13
- 2. Safety Evaluation Report cc w/encls. 1&2:
R. Boyle, U.S. Department of Transportation J. Shenk, U.S. Department of Energy, c/o L.F. Gelder December 16, 2024 Signed by Diaz-Sanabria, Yoira on 12/16/24
ML24337A183 (PKG), ML24337A184 (LTR/SER),
- via email OFFICE DFM E
DFM DFM DFM DFM NAME MOrtizGonzalez JSolis TGovan SFigueroa YDiaz-Sanabria DATE 12/04/2024 12/04/2024 12/09/2024 12/09/2024 12/16/2024 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION REPORT Model Nos. AOS-025A, AOS-50A, AOS-100A, AOS-100B, and AOS-100A-S Packages Certificate of Compliance No. 9316 Revision No. 13
SUMMARY
By application dated September 9, 2024, (Agencywide Documents Access and Management System [ADAMS] Accession No. ML24253A154), Alpha-Omega Services, Inc. (AOS) submitted an amendment request to clarify the design, use and replacement schedule for the elastomeric and metallic cask lid seals for all the Model Nos. AOS-25A, AOS-50A, AOS-100A, AOS-100B, and AOS-100A-S packages.
The applicant submitted a list of changes to the application and Revision J4 of the safety analysis report (SAR) Radioactive Material Transport Packaging System Safety Analysis Report for Model AOS-025, AOS-050, and AOS-100 Transport Packages AOS-FM9054, dated September 9, 2024. As part of this amendment request, AOS updated the lid seal tolerances on drawings 105E9712G001, 105E9712G002, and 105E9719.
The U.S. Nuclear Regulatory Commission staff reviewed the application using the guidance in NUREG-2216.
Based on the statements and representation in the application and the conditions listed below, the staff concludes that the revised design, use and replacement schedule for cask lid seals do not affect the ability of the package to meet the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 71.
EVALUATION The family of AOS transportation packages consists of the AOS-025A, AOS-050A, AOS-100A, AOS-100B, and AOS-100A-S. The A designation refers to a tungsten shield, and the B designation refers to a carbon steel shield. The S designation on the AOS-100A-S means that the cask is double ended and there is a lid on each end of the cask. All the packages have the same geometric shape, with the AOS-025A and AOS-050A having all dimensions scaled down to 25 percent and 50 percent (respectively) of the dimensions of the AOS-100 package.
CONTAINMENT EVALUATION The objective of the review is to verify that the containment performance of the AOS Radioactive Material Transport Packaging System has been adequately evaluated for the tests specified under both normal conditions of transport (NCT) and hypothetical accident conditions (HAC) of transport and that the package design satisfies the containment requirements of 10
2 CFR Part 71. CoC Revision 13 clarifies the design, use and replacement schedule for the elastomeric and metallic cask lid seals.
The AOS transport package containment boundary consists of the following components: cask cavity shell, containment penetrations or port plug sub-assemblies, and cask lid elastomeric and metallic seals. Revision 13 includes the following seal replacement schedule:
Metallic seal Normal form material - single use only.
Special form material - once every 12 uses or every 12 months, whichever comes first, or if the seal is damaged.
Elastomeric seal - once every 12 uses -or-every 12 months, whichever comes first, or if damaged.
For the shipment of special form material, a new, or previously used, cask lid elastomeric seal or new, or previously used, cask lid metallic seal may be used for the following cases:
When the radioactive contents are certified as special form sources and containment is provided by the sealed source.
After a pre-shipment leak test has been performed in accordance with American National Standards Institute (ANSI) N14.5-2014, American National Standard for Radioactive Materials - Leakage Tests on Packages for Shipment.
The changes included in this amendment request do not affect the previous cask containment evaluation during NCT or HAC. Therefore, the staff finds these changes acceptable.
Based on review of the statements and representations in the application, the NRC staff concludes that the AOS Radioactive Material Transport Packaging System has been adequately described and evaluated to demonstrate that it satisfies the containment requirements of 10 CFR Part 71, and that the package meets the containment criteria of ANSI N14.5.
OPERATING PROCEDURES EVALUATION The applicant made several changes regarding the detailed inspection of the cask and lid seal surfaces. In particular, if the cask lid metallic seal is replaced, prior to the shipment of normal form material, a maintenance test must be performed in accordance with ANSI N14.5. However, for the shipment of special form material, a previously used cask lid elastomeric seal or previously used cask lid metallic seal may be used after a pre-shipment leak test has been performed.
It is to be noted that for shipments of special form materials, a maintenance leak test is not necessary after the replacement of a cask lid elastomeric or metallic seal, if the periodic leak test has been performed on the casks containment system within the past 12 months.
The applicant has explained the different types of pre-shipment leak tests in Section 7.1.3.3 of the application depending on the contents to be shipped and the cask lid seal type.
ACCEPTANCE TESTS AND MAINTENANCE PROGRAMS EVALUATION
3 The applicant clarified that a maintenance leak test is not necessary after replacement of a cask lid elastomeric seal or reused cask lid metallic seal, provided that a periodic leak test has been performed on the casks containment system within the past 12 months and a pre-shipment leak test was performed (Test A1 or A2 for special form content or Test B for normal form contents) in accordance to Section 7.1.3.3 of the SAR.
Changes to Certificate of Compliance The following changes are included in Revision No. 13 to Certificate of Compliance No. 9316:
Item No. 3.b was revised to reference the updated safety analysis report.
Condition No. 5(a)(3) was revised to reference the updated licensing drawings.
Condition No. 10 was revised to state that a new, or previously used, elastomeric cask lid seal or new, or previously used, cask lid metallic seal may be used for shipment of special form material.
Condition No. 15 was revised to authorize the use of the Revision No. 11 of the certificate until December 31, 2025, due to prior scheduling of international shipments with Revision No. 11 as a basis for the U.S. Department of Transportation Certificate of Competent Authority Revision No. 7. Also, the same Condition No. 15 allows for Revision No. 12 to be used until approximately 1 year after issuance of Revision No. 13 of this Certificate.
The expiration date of the certificate was not changed.
The References section of the certificate was updated to identify the most recent application dated September 9, 2024.
CONCLUSION Based on the statements and representations contained in the application, as supplemented, and the conditions listed above, the staff concludes that the design of the Model Nos. AOS-25A, AOS-50A, AOS-100A, AOS-100B, and AOS-100A-S packages has been adequately described and evaluated.
The staff concludes that the changes indicated do not affect the ability of the package to meet the requirements of 10 CFR Part 71.
Issued with Certificate of Compliance No. 9316, Revision No. 13.