ML25108A164
| ML25108A164 | |
| Person / Time | |
|---|---|
| Site: | 07109296 |
| Issue date: | 05/16/2025 |
| From: | Storage and Transportation Licensing Branch |
| To: | |
| Shared Package | |
| ML25108A162 | List: |
| References | |
| EPID L-2024-LLA-0112 | |
| Download: ML25108A164 (1) | |
Text
Enclosure SAFETY EVALUATION REPORT Model No. 880 Series Packages Endorsement to SSR-6 Certificate of Compliance No. 9296 Revision No. 12
SUMMARY
By \
letter dated July 18, 2024 (Agencywide Documents Access and Management System Accession No. ML24261B174), the U.S. Department of Transportation (DOT) requested that the U.S. Nuclear Regulatory Commission (NRC) staff perform a review of a QSA Global application for issuance of a revision to the Competent Authority Certificate No. USA/9296/B(U)-96, for the Model No. 880 Series transport package (hereon referred to as Model 880) to the International Atomic Energy Agency (IAEA) Regulations for the Safe Transport of Radioactive Material, 2018 Edition, No. SSR-6 (hereon referred to as IAEA SSR-6, 2018 Edition (IAEA, 2018a).
EVALUATION 1.0 GENERAL INFORMATION The Model 880 is designed for use as an industrial radiography exposure device and a transport package of special form radioactive material in Type B quantities. The Model 880 has four versions called Delta, Sigma, Elite, and SC respectively. Physical construction of the Delta and the Sigma versions of the package (including construction of the depleted uranium [DU] shield) is identical. However, due to the natural variability in the shield consistency created from the DU pouring/cooling process, the shields can vary in Ir-192 unit capacity from 150 Curies (Ci) for the Delta version to 130 Ci for the Sigma version of the package.
The major components of the package consist of: Welded cylindrical body (hereafter called container), DU shield, rear plate with locking assembly (some models), front plate with shield port (some models), lock assembly plates (Model 880SC), shipping plug assembly (Model 880SC), optional jacket (three versions), containment system (source encapsulation). Except for the shield assembly, fill foam, copper spacers, some of the lock assembly components, lock cover, shield pin, source wire assembly and optional jackets, all material of construction are stainless steels. All Model 880 packages allow for the use of an optional jacket which facilitates use of the package as a radiography device/source changer and transport package.
1.1 Contents No changes were made to the approved contents for this package.
2.0 STRUCTURAL EVALUATION The objective of the structural evaluation is to verify that the structural performance of the Model 880 meets the requirements of the IAEA SSR-6, 2018 Edition (IAEA, 2018a).
The NRC staff previously reviewed the structural performance of the Model 880 and approved Certificate of Compliance No. 9296, Revision 12 (ML21109A117) that conformed to the Title 10 of the Code of Federal Regulations (10 CFR) Part 71 regulations and 2009 edition of IAEA Safety Requirements TS-R-1, Regulations for the Safe Transport of Radioactive Material.
(IAEA, 2009). In accordance with the Memorandum of Understanding between the two
2 agencies, the DOT requested the NRC to review the Model 880 amendment application (DOT, 2024) and provide a recommendation for upgrading the regulatory citation to the IAEA SSR-6, 2018 Edition (IAEA, 2018a) regulations for import and export shipments. This section of the safety evaluation report (SER) documents the staffs reviews, evaluations, and conclusions with respect to structural integrity of the amended transport package.
2.1 Description of the Amendment Affecting Structural Design In this amendment to the package, there is no physical change to the previously approved package or the package contents, and no update to the previously approved safety analysis report (SAR) (QSA, 2020). The applicant states that the majority of changes under IAEA SSR-6, 2018 from the 2012 version of these regulations have no significant impact on compliance of the Model 880 Series packages. In addition, the applicant provides a summary table identifying the following updated requirements from the 2018 edition of IAEA SSR-6 that have implications for the package, including their impact assessments and justifications for conformance of the package to the updated requirements.
Paragraph 503(e) and 613A - Aging mechanisms considerations Paragraph 728 - Solar insolation considerations during accident condition of transport (ACT) Thermal Test Paragraph 809(j) - Management system Paragraph 809(k) - Gap Analysis Program Paragraph 809(a) & (e) - Package identification labelling The staff reviewed the changes to the regulatory requirements in IAEA SSR-6, 2012 and 2018 editions from the 2009 version of this regulations and finds that the changes in 2012 edition are either not applicable or have no impacts to the structural requirements of the packages.
Furthermore, based on review of the changes in 2018 edition, the staff finds that the Paragraph 613A requirement for considering aging mechanisms in the design of packages intended to be used for multiple shipments may have implications to structural integrity of the affected package components. Other changed requirements in 2018 edition are not applicable or do not affect the structural design of this package and are not considered for the structural evaluation. Therefore, the scope of structural review remains focused on the review of the aging considerations in the package design, especially for the fatigue mechanism, evaluated in the application (QSA, 2024a) and in the supplemental responses (QSA, 2024b) to the request for supplemental information (RSI).
2.2 Structural Evaluation of the Application 2.2.1 Aging Mechanism - Fatigue Paragraph 613A of IAEA SSR-6, 2018 Edition, requires that aging mechanisms be considered in the design of the package. IAEA Specific Safety Guide No. SSG-26 (IAEA, 2018b) provides guidance on how to comply with Paragraph 613A in IAEA SSR-6. The Model 880 series is a Type B(U) package and intended for repeated shipment use. Therefore, in accordance with the guidance provided in Paragraphs 613A.1 and 613A.3 of the IAEA SSG-26, the package needs to be evaluated for the effects of aging mechanisms during the design phase to demonstrate compliance with the Transport Regulations.
The applicant provided detailed aging evaluation in supplemental responses to the RSI (QSA, 2024b), which included an evaluation of fatigue as one of the aging mechanisms. The following
3 documents the staffs review and evaluation with respect to the structural integrity of the package components affected by fatigue. Refer to section 4.0, Materials Evaluation of this SER for additional details on aging evaluations.
The applicant stated that the expected working life for the Model 880 series packages is approximately 10 years, although it can vary depending on its environment. After 10 years, the user needs to arrange for the device to be inspected and assessed by a qualified authority (e.g.,
the manufacturer) to determine whether the working life can be extended or if the package should be removed from service.
Handling (Lifting and Tiedown) Fatigue Cycles Lifting and tiedown attachment points for the Model 880 packages are either via the jacket handle or via the 1 1/4 inches diameter cut-out feature in the container shell lip. The applicant states that if either of these features failed due to handling fatigue, it would not affect the shield assembly or the source wire security located within the container. Under the failure of the attachment points while hoisted or tied down by the jacket handle or by the cut-out feature in the container, in the worst-case scenario, it could allow free fall of the package or unintended movement within a transport vehicle. These scenarios are already bounded by the 30 feet drop tests and the puncture tests of the bounding package with and without the optional jacket.
The staff reviewed the Model 880 safety analysis report (SAR), section 2.7 (QSA, 2020) and notes that the applicants evaluation of the packages to meet the hypothetical accident conditions of 10 CFR Part 71 is based on full-scale tests in all cases, with and without jacket.
Results of these tests demonstrated no significant increase in radiation levels from the test units nor any damage that adversely impacted the package integrity. Therefore, the staff determined that the attachment points failure due to handling fatigue would not affect the shield assembly or the source wire security located within the container.
Service Fatigue and Transport Vibration Fatigue Cycles Cyclic loading within the Model 880 packages is confined to major hardware which holds the Rear Plate and Front Plate assemblies to the body weldment (container). The stainless-steel container which holds the primary shielding does not see significant effects due to cyclical loading as it is a welded steel tube with end plates fully welded on each end. Also, there are no external forces which would cause extensive cyclical loading.
The package hardware, particularly the security screws which hold the front and rear plate, experience two types of cyclical loading, removal and installation during service, and vibration during transport. The following provides the NRC staffs evaluation for these two types of fatigue in the security screws and other fasteners, as applicable.
Service Fatigue cycles The applicant states that the endplate screws are torqued to 75-80 percent of their minimum yield strength, which is defined by a strain of 0.2 percent. Per NUREG/CR-6909, austenitic stainless steel tested in air at 0.2 percent strain amplitude have an expected service life of 105 cycles. During the 10 years service life, the endplate screws will see roughly 40 removals and installations based on the recommended service requirements. Further, the applicant concludes that even in an over-loaded condition with cycles to no strain, this is 4 orders of magnitude too low to constitute a realistic failure mode.
4 The staffs independent fatigue assessment of the security screws considered the fatigue strength reduction factor and design fatigue curve in figure I-9.2 of American Society of Mechanical Engineers Boiler & Pressure Vessel Code, section III, Mandatory appendix I for the stainless steel material and noted that the estimated 40 service cycles are much lower than the approximately 3000 allowable number of stress cycles. Therefore, the fatigue assessment is acceptable.
Transport Vibration Fatigue Cycles The applicant states that the only parts that could loosen from vibration during transport are the security screws used to secure the endplates to the package weldment. This type of screw has been used on the Model 880 series packages and other similar devices over the past 35 years.
Field use of these screws has shown they have never loosened as a result of vibration. Further, the applicant states that the endplate security screws do not experience much strain variation in transit as they are consistently under tension between service events. Per Electric Power Research Institute Presentation (ML16183A084), vibration fatigue failure resides in the 106 to 1011 cycle count range, and it typically manifests as a sudden brittle failure. Given the extreme variability of this failure mode, it is unlikely that a full set of four screws would fail concurrently.
The staff reviewed the applicants assessment and notes that the packages are compact in size and light weight which ensures a limited effect from transport vibrations and acceleration to critical components. The lock attachment screws and end plate screws are tightened to a prescribed torque to prevent unintentional release even after repeated use. This torque is reapplied at least annually during annual inspection and maintenance of the package.
Furthermore, identical lock attachment screws have been used in other transport packages for years without incident caused by vibration. The shield is attached to the brackets by titanium pins. These pins are secured by stainless steel cotter pins, which are routinely used in high vibration situations and can easily withstand vibration incidents to transport. Therefore, the staff concludes that the packages will withstand vibration normally incident to transport without any adverse consequences to structural integrity of critical package components.
Furthermore, the staff concludes that the combined effects on the security fasteners and lock fasteners from the service fatigue cycles and transport vibration cycles are acceptable based on the low estimated service fatigue cycles and low repetitive stresses due to transport vibration.
Thermal Stress Fatigue Cycles Thermal stresses in the package containers, including thermal expansion, are evaluated in the SAR section 2.6.1 for the normal condition of transport (NCT). The stresses calculated are negligible and well below the allowable stresses for the materials of construction. As documented in the SAR table 3.1.A and sections 3.4.1.1 and 3.4.1.2, the highest package temperature under the NCT is 65.4 degrees Celsius (°C) (149.7 degrees Fahrenheit [°F]). The applicant states that thermal cycling is generally not a significant concern at temperatures below 65°C (150°F) for stainless steel structural components. At these lower temperatures, the thermal expansion and contraction of stainless steel are minor, and the stresses remain well within the materials elastic range, meaning they will not cause fatigue or significant structural changes that could adversely affect structural integrity of the package.
The applicant states that the source capsule has a significantly shorter service-life span (6-12 months) versus the overall package recommended service life of 10+ years. The heat
5 generated by decay also drops significantly such that after 1 year it is roughly 4 percent of its original value. The applicant further notes that the source capsules are used in the Model 880 packages for decades without any observed failures due to thermal or pressure expansion/contraction. These source capsules are tested every 6 months for any signs of leakage that could result from a breach of the capsule welds or base material. There were no failures of the source encapsulations when the source and the Model 880 packages in which they are used, were maintained as described in the applicants service bulletin SB-23 (QSA, 2024b).
Based on the review of the applicants assessment and the SAR relevant sections, the staff finds that the thermal stresses and thermal expansions are negligible under the normal condition due to thermal cycle. Therefore, the staff concludes that the thermal stress fatigue cycle is not a concern for the structural integrity of the packages and the source encapsulations for their respective expected service-life.
Pressurization Fatigue Cycle:
The Model 880 series packages are open to the atmosphere and contain no components which could create a differential pressure relative to atmospheric conditions. However, the authorized contents are special form capsules that meet a minimum American National Standards Institute N43.6-2007 pressure classification of 3, which demonstrates the capsule can retain its structural integrity under varied external pressure conditions from 25 kN/m2 (3.6 pounds per square inch
[psi]) to 2 MN/m2 (290 psi). This classification is more than sufficient to comply with the pressure requirements in 10 CFR Part 71, 49 CFR, and IAEA SSR-6, 2018 Edition (IAEA, 2018a).
Thermal cycling is not a significant concern unless there is uneven expansion. The source capsules are small and thermally conductive, which are welded without the use of filler material.
Since there is no filler metal, there is no differential expansion between different alloys.
Therefore, thermal stresses pose no significant concern of cyclic internal stress to the capsule integrity.
The staff reviewed the applicants assessment and the SAR relevant sections and concurs that pressurization stress cycle fatigue is not a concern for the structural integrity of the packages or source encapsulations for their respective expected service-life.
Based on the above assessments, the staff does not expect any adverse impact on structural adequacy of the reusable package components due to the combined effects from handling, pressurization, thermal, service and vibration fatigue cycles.
2.2.2 Structural Evaluation Under the Normal Condition of Transport and Accident Condition of Transport The applicants previously reviewed evaluation for the NCT and the ACT are bounding or unaffected by the addition of the aging considerations in this package amendment.
2.3 Evaluation Findings Based on the staffs review of the structural evaluations and related sections of the application, the staff concludes that the Model 880, with the addition of the aging considerations, is structurally adequate to meet the requirements of IAEA SSR-6, 2018 Edition (IAEA, 2018a).
6 3.0 THERMAL EVALUATION The purpose of the thermal review is to revalidate that the Model 880 satisfies the thermal safety requirements of the IAEA SSR-6, 2018 Edition (IAEA, 2018a).
3.1 Description of Thermal Design Model 880 package is categorized as a Type B(U) package to meet the IAEA requirements for NCT and ACT, as described in the thermal requirements of IAEA SSR-6 (IAEA, 2018a).
Section 728, Solar Insolation Considerations During ACT Thermal Test, of the IAEA SSR-6 (IAEA, 2018a) requires that test specimen be in thermal equilibrium under conditions of an ambient temperature of 38°C, subject to the solar insolation conditions specified in table 12 of the IAEA SSR-6 (IAEA, 2018a) and the design maximum rate of internal heat generation within the package from the radioactive contents. When the unit was changed from g-cal/cm2 (e.g.,
800 g-cal/cm2) to W/m² (e.g., 800 W/m2), IAEA kept the same table values which resulted in an approximate 3 percent increase in the solar heat load to the packages.
The applicant performed the thermal analysis in chapter 3 of the SAR, based on solar insolation units of W/m2 (e.g., 800 W/m2), and showed that the maximum package surface temperature is increased by 18.4°C from 47.0°C with zero insolation (0 percent insolation) to 65.4°C in full sun with insolation (100 percent insolation). The applicant stated, in the Model 880 DOTs Amendment for SSR-6 2018 Endorsement (QSA, 2024a), that the added 3 percent increase in solar insolation applied prior to the ACT thermal test will have no significant impact on the ability of the package design to comply with the ACT thermal test requirements.
The staff reviewed table 3.2.A, Thermal Properties of Principal Transport Package Materials, of the SAR, and accepts that an increase of 3 percent in solar insolation will be insufficient to adversely impact the package integrity or result in package failure since the melting/combustion temperatures of all safety critical components are well above the maximum surface temperature of 65.4°C.
3.2 Evaluation Findings The staff confirmed that the thermal analysis, presented in the SAR, is already performed based on the solar insolation units of W/m2 (e.g., 800 W/m2 rather than 800 g-cal/cm2), and an increase of 3 percent in the solar insolation unit (e.g., from 800 g-cal/cm2 to 800 W/m2) will not adversely change the ACT thermal test results. Therefore, the staff confirmed that the QSA Model 880 package design will meet the requirements of the IAEA SSR-6 (IAEA, 2018a) section 728 for the ACT thermal test.
4.0 MATERIALS EVALUATION The staff reviewed the information provided to DOT by the applicant. In its application (QSA, 2024a) and its supplements, including SB-23 (QSA, 2024b), which provides detailed package inspection and maintenance requirements, against the regulatory requirements of IAEA SSR-6, 2018 Edition (IAEA, 2018a). The staff also reviewed the proposed changes to the package described below.
7 4.1 Description of Application: IAEA SSR-6, 2018 Conformance The applicant submitted an amendment request for endorsement of the Model 880 Type B(U) containers. This amendment request is for endorsement of these packages to the IAEA SSR-6, 2018 Edition (IAEA, 2018a). Compliance with this version of the IAEA regulations is required for international transport of these packages in ADR countries after December 2025.
The applicant stated that the package conformance after storage and prior to use for Type B shipments is ensured by the inspection and maintenance requirements specified in sections 7 and 8 of the SAR. The applicants SAR stated that the materials used in the Model 880 are not vulnerable to degradation due to irradiation over time and there are no chemical/galvanic material interactions between package materials. Prior to loading, the applicant inspects the package components for any degradation due to non-use or storage. If degradation is identified, service or repair of the package will be conducted prior to further use.
Additionally, the applicant specified that, as part of the inspection, any degradation of the package internal construction due to storage empty or loaded will be corrected prior to shipment. Further, any degradation on externally assessable components, which could adversely impact the package integrity after storage, will be identified by the inspections and tests specified in sections 7 & 8 of the SAR. Compliance with these requirements will ensure that the container meets the specifications on the certificate of conformance and authority and is fit for use in a Type B shipment.
The applicant stated that there is a procedure in place which requires the review and evaluation of regulatory changes on existing products and internal programs used to obtain product approvals. The results of these reviews are then used to update existing products including distribution of products and internal programs as necessary to maintain compliance with applicable regulatory requirements.
4.2 Review Criteria The staff conducted a review to assess the Model 880 transport package conformance with IAEA SSR-6, 2018 Edition (IAEA, 2018a). The pertinent IAEA SSR-6 requirements are listed below:
503(e): For packages intended to be used for shipment after storage, it shall be ensured that all packaging components and radioactive contents have been maintained during storage in a manner such that all the requirements specified in the relevant provisions of these Regulations and in the applicable certificates of approval have been fulfilled.
613A: The design of the package shall take into account aging mechanisms.
809(k): An application for approval shall include, for packages which are to be used for shipment after storage, a gap analysis program describing a systematic procedure for a periodic evaluation of changes of regulations, changes in technical knowledge and changes of the state of the package design during storage.
8 4.3 Evaluation The staff reviewed the adequacy of the package materials of the Model 880 against the IAEA SSR-6, 2018 Edition (IAEA, 2018a) requirements and the ability of the package design to meet such requirements.
IAEA SSR-6, Paragraph 503(e)
The applicant provided supplemental information that addressed materials selection with respect to aging mechanisms and maintenance requirements. The applicant addressed stainless steel (corrosion resistance, similar thermal expansion coefficients limits fatigue, microstructural stability at typical temperatures (stainless steel have max operating temperature of 600 to 800°F depending on the alloy)), bolt selection, sealed source that has service life of 2 years or less before replacement.
The applicant stated that the package weldment and fasteners are stainless steel and naturally corrosion resistant. As all structural components are austenitic stainless steel, the thermal expansion coefficients have a small amount of variability. Concerning microstructural stability, the temperature range is low, such that phase changes or chromium carbide precipitation is limited. The applicant stated that bolts are selected appropriately for the intended load and by following torque specifications in preload and installation and maintenance ensure that they do not experience stress that could lead to fatigue. The applicant stated that Ir-192 and Se-75 source capsules in the source assemblies have decades of operating experience with no observed failures from thermal or pressure expansion/contraction.
The staff finds that the applicant has addressed corrosion by selecting stainless steel package weldment and fasteners that are corrosion resistant due to the high chromium and nickel content. The staff finds that the structural components having similar thermal coefficients limits internal stresses generated at the junctions. The staff finds that the package microstructural stability to be within the material range and corrosion resistance will be stable due to the low temperature range. The staff finds that the applicants method for material selection and inspection and maintenance of bolts acceptable in meeting Paragraph 503(e) by preventing excessive stress to the bolts. The staff review finds the source capsules in accordance with Paragraph 503(e) through regular leak testing combined with the operating experience showing successful operation without failure.
IAEA SSR-6, Paragraph 613A The applicant provided supplemental information that detailed inspections conducted at regular intervals as identified in the SAR (QSA, 2020) and in Service Bulletin (SB)-23 (QSA, 2024b).
SAR (QSA, 2020) section 7 described the package loading and unloading process. This includes packaging maintenance and inspections prior to loading, the loading process, preparation for transport, unloading of the package, and preparation of empty package for transport. SAR (QSA, 2020) section 8 described the acceptance and maintenance program for the package, including visual inspections, weld examinations, structural and pressure tests, leakage tests, thermal tests, material tests, and shielding tests.
SB-23 described detailed package inspection and maintenance requirements. These included procedures for packaging maintenance and inspection prior to shipment, packaging quarterly maintenance and inspection, and packaging annual maintenance and inspection. Specifically, SB-23 included instructions for disassembly and inspections for wear, corrosion, damage with
9 defined acceptance criteria of long life components of the packaging. This includes specific inspection of hardware for damage and requirement to replace damaged fasteners. It also prescribes periodic replacement of hardware. Reassembly and functional testing are then performed to verify operation.
The applicant stated that components affected by wear, the screwed fittings and lock assembly components are inspected for damage/deterioration on an annual basis and the fasteners are visually examined prior to transport for any damage. The source assembly capsule and shield source tube can experience wear due to cycling in and out of the package during industrial radiography. The source assemblies are tested every 6 months for potential leaking by physical testing, the source tubes are tested annually for leakage. If leakage is indicated over 0.005 micro curies, the source assembly and package are removed from service. Concerning corrosion, the applicant stated that the package weldment is inspected at least annually and if any degradation or deterioration is noted on the weldment or any other components important to safety, they are replaced or repaired prior to continued package transport. The applicant addressed damage with defined acceptance criteria of long life components of the packaging including fasteners, springs in the endplate assemblies. For fasteners, the applicant performed analysis that demonstrated that over 10 years the cycles are many orders of magnitude below failure mode due to fatigue. For the springs in the endplate assemblies, they are replaced during annual service. The lock slide, selector ring, and other components with running/sliding surfaces may show signs of wear during the annual service, where any indication of sticking or binding would lead to replacement of that component during the annual service. In addition, the annual maintenance and inspection includes complete disassembly, reassembly and functional testing to confirm proper operation.
The staff reviewed the applicants process for addressing wear of components and finds that the applicant has properly addressed wear through inspection frequency and visual examinations.
The staff reviewed the applicants process for addressing corrosion of components including the inspection process described in SB-23 and found that it included the proper criteria and frequency. The staff reviewed the applicants acceptance criteria for replacement of components susceptible to fatigue, wear, or other aging mechanisms during the service.
The staff reviewed the applicants inspection and maintenance procedures described in SAR sections 7 and 8 and Service Bulletin (SB-23) (QSA, 2024b). The staff also reviewed section 2 which (QSA, 2020) describes the chemical, galvanic or other reactions between the package materials, the effects of radiation on materials, and package performance in NCT. The staff determined that the routine inspections and maintenance procedures described in SAR (QSA, 2020) section 7 and 8 and the detailed procedures and requirements in SB-23 (QSA, 2024b) adequately addressed aging mechanisms as required by IAEA SSR-6, 2018 Edition (IAEA, 2018a). The NRC staff finds that the inspection and maintenance procedures described in SAR (QSA, 2020) section 7 and 8 and SB-23 (QSA, 2024b) is in conformance with IAEA SSR-6, 2018 Edition (IAEA, 2018a), Paragraphs 503(e) and 613A requirements. Additionally, the NRC staff ensured that all packaging components and radioactive contents have been maintained and adequately take into account aging mechanisms.
IAEA SSR-6, Paragraph 809(k)
The applicant described their process for reviewing and evaluating the impact of regulatory changes on pre-existing product and internal programs used to obtain product approvals. The applicants procedure included a gap analysis assessment that is subsequently used as input to update existing products and programs.
10 The staff reviewed the information provided by the applicant and the requirements of the 2018 Edition of IAEA SSR-6 (IAEA, 2018a), Paragraph 809(k). The staff determined that the information provided by the applicant was intended to show compliance with regulatory requirements of SSR-6 (IAEA, 2018a) Paragraph 809(k); however, the regulatory requirements of SSR-6 Paragraph 809(k) are not applicable to the Model 880. The Model 880 is a transportation package for special form gamma sources and is neither designed nor licensed for storage under the NRC regulations in 10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste, or the IAEA regulations in SSR-4, Safety of Nuclear Fuel Cycle Facilities. Therefore, the staff determined that the applicant does not have to meet the regulatory requirements of IAEA SSR-6, 2018 Edition (IAEA, 2018a) Paragraph 809(k).
4.4 Evaluation Findings Based on the NRC staffs review of the application, the staff concludes that the materials evaluations have been adequately described, and the Model 880 transport package has adequate materials performance to meet the requirements of the IAEA SSR-6, 2018 Edition (IAEA, 2018a).
5.0 QUALITY ASSURANCE EVALUATION The purpose of the quality assurance (QA) is to verify that the proposed package design meets the requirements of the IAEA SS-6, 2018 Edition (IAEA, 2018a). The staff reviewed the description of the QA program for the Model 880 against the standards in IAEA SSR-6, 2018 Edition (IAEA, 2018a).
5.1 Quality Assurance Review The applicant described a QA program for inspection and maintenance of the Model 880, provided in SAR (QSA, 2020) sections 7 and 8, and in SB-23 (QSA, 2024b). Specifically, the Service Bulletin requires inspection and maintenance prior to shipment, quarterly and annually.
Refer to section 4.0 of this SER for more detailed information regarding inspection and maintenance for the Model 880.
5.2 Evaluation Findings Based on review of the statements and representations in SAR (QSA, 2020) sections 7 and 8, SB-23 (QSA, 2024) and as discussed in this SER section, the staff has reasonable assurance that the Model 880 meets the requirements in IAEA SSR-6, 2018 Edition (IAEA, 2018a).
REFERENCES (IAEA, 2009)
International Atomic Energy Agency, IAEA TS-R-1, Regulations for the Safe Transport of Radioactive Material, 2009 Edition.
(IAEA, 2012)
International Atomic Energy Agency, IAEA SSR-6, Regulations for the Safe Transport of Radioactive Material, 2012 Edition.
(IAEA, 2018a)
International Atomic Energy Agency, IAEA SSR-6, Regulations for the Safe Transport of Radioactive Material, 2018 Edition.
11 (IAEA, 2018b)
International Atomic Energy Agency, IAEA SSG-26, Revision 1, Advisory Material for the IAEA Regulations for the Safe Transport of Radioactive Material (2018 Edition).
(DOT, 2024)
Richard W. Boyle, U.S. Department of Transportation (DOT), letter to Director, Division of Fuel Management, U.S. Nuclear Regulatory Commission (NRC), July 18, 2024, ML24261B174.
(QSA, 2020)
Lori Podolak, QSA Global, Inc., letter to John McKirgan, U.S. Nuclear Regulatory Commission, November 6, 2020, ML20322A173, non-public.
(QSA, 2024a)
Lori Podolak, QSA Global, Inc., letter to Rick Boyle, U.S. Department of Transportation (DOT), May 6, 2024, ML24261B172.
(QSA, 2024b)
Lori Podolak, QSA Global, Inc., letter to Rick Boyle, U.S. Department of Transportation (DOT), November 7, 2024, ML24331A246.
CONCLUSION The staff recommends the issuing a certificate for the Model 880. Based on the statements and representations contained in the documents referenced above, the staff concludes that the Model 880 meets the requirements of IAEA SSR-6, 2018 Edition (IAEA, 2018).
Issued with letter to R. Boyle, DOT.