ML24353A264
| ML24353A264 | |
| Person / Time | |
|---|---|
| Site: | 07105797 |
| Issue date: | 01/13/2025 |
| From: | Stroud H Storage and Transportation Licensing Branch |
| To: | Shenk J US Dept of Energy, Office of Packaging and Transportation |
| References | |
| EPID L-2023-LLA-0156 | |
| Download: ML24353A264 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Julia Shenk, Certifying Official Director U.S. Department of Energy Office of Packaging and Transportation 19901 Germantown Road - Room D115 Germantown, MD 20874
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR REVIEW OF THE INNER HIGH FLUX ISOTOPE REACTOR UNIRRADIATED FUEL ELEMENT SHIPPING CONTAINER, AND OUTER HIGH FLUX ISOTOPE REACTOR UNIRRADIATED FUEL ELEMENT SHIPPING CONTAINER
Dear Julia Shenk:
By letter dated July 20, 2024 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML24229A121), as supplemented on November 13, 2024 (ML24338A187), you submitted an application to the U.S. Nuclear Regulatory Commission (NRC) for a -96 certification of the Model Inner High Flux Isotope Reactor (HFIR) Unirradiated Fuel Element Shipping Container, and Outer HFIR Unirradiated Fuel Element Shipping Container.
In connection with our review, we need the information identified in the enclosure to this letter.
To assist us in scheduling the NRC staffs review of your response, we request that you provide this information 60 calendar days from the date of this letter. If you are unable to provide a response by February 28, 2025, our review may be delayed.
In accordance with Title 10 of the Code of Federal Regulations Part 2, Agency Rules of Practice and Procedure, 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.
January 13, 2025
J. Shenk 2
If you have any questions regarding this review, you may contact me at 301-287-3664 or heath.stroud@nrc.gov.
Sincerely, Heath Stroud, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-5797 EPID: L-2023-LLA-0156
Enclosure:
Request for Additional Information cc w/ encl. 1: L. Gelder, DOE Signed by Stroud, Heath on 01/13/25
ML24353A264 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME HStroud YKim JSolis TBoyce DATE 12/20/2024 01/02/2025 01/02/2025 01/06/2025 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME TGovan SFigueroa YDiaz-Sanabria HStroud DATE 01/06/2025 01/06/2025 01/12/2025 01/13/2025
Enclosure UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Request for Additional Information Certificate of Compliance No. 5797 Docket No. 71-5797 Revision No. 24 Model No. Inner High Flux Isotope Reactor Unirradiated Fuel Element Shipping Container, Outer High Flux Isotope Reactor Unirradiated Fuel Element Shipping Container Structural Evaluation
RAI-1
Provide the location and magnitude of the maximum deformation of the package measured from the model tests and calculated by the finite element (FE) structural analyses for the vertical end, horizonal side and center-of-gravity-over-top corner drops under the normal conditions of transport (NCT). If the results of the FE structural analyses do not bound the results of the model tests, justify how the results of the FE structural analyses are accurate and conservative.
Additionally, provide a deformation contour view of the FE analyses and model test results of each drop orientation in the vicinity of impact for a comparison.
In 1991, the applicant performed structural analyses of the package under NCT using the DYNA FE codes (DYNA2D and DYNA3D) and submitted safety evaluations based on the results of the structural analyses from Inner HFIR Unirradiated Fuel Element Shipping Container and Outer HFIR Unirradiated Fuel Element Shipping Container Certificate of Compliance No. 5797 Revision No. 9, dated May 30, 1991. The staff reviewed the applicants safety analysis report (SAR) and issued SAFETY EVALUATION REPORT: Inner HFIR Unirradiated Fuel Element Shipping Container and Outer HFIR Unirradiated Fuel Element Shipping Container Certificate of Compliance No. 5797, Revision No. 9, dated July 13, 1992. In 2023, the applicant performed the full-scale model tests of the package to demonstrate compliance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 71. The applicant performed external visual and dimensional inspections on each package prior to and following the model tests. The visual inspection provided limited data (i.e., measured deformation) that could be used for qualitative safety evaluations. However, the applicant made quantitative safety evaluations (i.e.,
calculated stress vs. yield stress) based on the results of the FE structural analyses performed in 1991. The staff needs to assess the impacts of the results of the model tests on the structural analyses, evaluate the relationship between them, and determine the accuracy and acceptability of the quantitative results.
This information is needed by the staff to determine compliance with 10 CFR 71.71(c)(7).
RAI-2
Provide detailed technical justifications for not performing the model tests of the package under the hypothetical accident conditions (HAC).
The applicant stated that the purpose of the safety evaluations of the package submitted in this
2 application is to demonstrate compliance with the NCT and HAC requirements of 10 CFR Part 71 by performing a series of the full-scale model tests. The applicant performed the model tests for the end and side drop orientations under NCT. However, the applicant did not perform the model tests for the end and side drop orientations under HAC. The end and side drop model tests under HAC are important model tests to understand the behavior of the package under the 30-ft. accident drop and to demonstrate compliance with the requirements of 10 CFR 71.73(c)(1).
In section 2.7 of the SAR, Safety Analysis Report for the HFIR Unirradiated Fuel Element Shipping Package, ORNL/RRD/INT-180, Rev. 0, dated July 30, 2024, the applicant briefly provided its general qualitative engineering assumptions/judgements for not performing the HAC model tests. The applicant stated that the end drop test was not performed under HAC because damage from a 30-ft. vertical end drop will not challenge the package, with typical damage being a slight reduction in the overall height of the package from drum side wall buckling. The localized buckling would not be greater than the axial spacing above and below the fuel element. The applicant also stated that the side drop test was not performed under HAC because damage from a 30-ft. horizontal side drop does not challenge the package based on other similar packages (i.e., DT-20 and DT-23 packages). However, 10 CFR 71.73(c)(1) requires that a package needs to be demonstrated for structural adequacy by a free drop through a distance of 30 ft. onto a flat, unyielding, horizontal surface in a position for which maximum damage is expected. The structural responses of a package under HAC, including interactions among the components in the package, are quite complex and involve non-linear plasticity. Therefore, the applicant is requested to provide more detailed quantitative technical information to demonstrate compliance with the HAC requirements of 10 CFR Part 71.
This information is needed by the staff to determine compliance with 10 CFR 71.73(c)(1).
RAI-3
Justify the use of the energy balance (EB) method over the FE method to analyze the performance of the package for the side drop under NCT and HAC, while the FE method was used to analyze the package for end drop under NCT and HAC.
In sections 2.6 and 2.7 of the SAR, Safety Analysis Report for the HFIR Unirradiated Fuel Element Shipping Package, ORNL/RRD/INT-180, Rev. 0, dated July 30, 2024, the applicant indicated that the EB method was used to analyze the performance of the package for the side drop under NCT and HAC. However, the applicant indicated that the FE method was used to analyze the package for end drop under NCT and HAC. The applicant is requested to justify the use of the EB method over the FE method to analyze the performance of the package for the side drop under NCT and HAC and explain how the EB method accurately analyzes the component interactions and nonlinear behavior of the components during the 30-ft. drop dynamic impacts.
This information is needed by the staff to determine compliance with 10 CFR 71.71(c)(7) and 71.73(c)(1).
Thermal Evaluation
RAI-4
Clarify how assumed material emissivity values used to perform the thermal analysis of the
3 HFIR shipping package would result in realistic or conservative results.
Table 3.3 of the SAR provides material properties used in the thermal analysis. It is stated in this table that all emissivity values are assumed. The staff needs to have assurance the assumed values are realistic or conservative to make a determination of the adequacy of the analysis results.
This information is necessary to determine compliance with 10 CFR 71.71 and 71.73.
RAI-5
Justify the heat transfer coefficient value used to perform the analysis of the 30-minute regulatory fire test.
SAR section 3.4.2 states that for the convective boundary condition during a fire, a forced convection coefficient value of about 1.8 BTU/hr-ft2-°F can be used, based on M. H. Burgess, Heat Transfer Boundary Conditions in Pool Fires, IAEA-SM-286/75P, Proceedings of PATRAM 86, International Atomic Energy Agency, Vienna, 1987. During the 30-minute fire regulatory test, the U.S Nuclear Regulatory Commission staff have accepted values provided in Gregory, J.J., R. Mata, and N.R. Keltner, Thermal Measurements in a Series of Large Pool Fires, SAND85-0196, TTC-0659, UC-71, Sandia National Laboratories, Albuquerque, New Mexico, August 1987. The values provided in this reference for the fire test conditions are more than twice the value used by the applicant for performing the fire thermal analysis.
This information is necessary to determine compliance with 10 CFR 71.73(c)4.