ML25118A052
| ML25118A052 | |
| Person / Time | |
|---|---|
| Site: | 07103034 |
| Issue date: | 05/09/2025 |
| From: | Yoira Diaz-Sanabria Storage and Transportation Licensing Branch |
| To: | Boyle R US Dept of Transportation, Radioactive Materials Branch |
| Shared Package | |
| ML25118A051 | List: |
| References | |
| EPID L-2024-DOT-0002 | |
| Download: ML25118A052 (1) | |
Text
Richard W. Boyle Radioactive Materials Branch U.S. Department of Transportation 1200 New Jersey Avenue SE Washington, D.C. 20590
SUBJECT:
REQUEST FOR REVALIDATION OF FRENCH CERTIFICATE OF APPROVAL F/313/B(U)F FOR THE MODEL NO. TN-BGC-1 PACKAGE, DOCKET NO. 71-3034
Dear Richard Boyle:
By letter dated July 23, 2024 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML24283A024), as supplemented on January 21, 2025 (ML25119A286), TN Americas LLC, on behalf of Orano NPS, requested a U.S. Department of Transportation (DOT) revalidation of the French Approval Certificate F/313/B(U)F (Mbs) for the Model No. TN-BGC-1. In your application you requested that the NRC provide a recommendation to revalidate the Model No. COG-OP-30B package for import and export use.
Based upon our review, the statements and representations contained in the application, and for the reasons stated in the enclosed safety evaluation report, we recommend revalidation of the French Certificate of F/313/B(U)F (Mbs), for the Model No. TN-BGC-1 transport package, with the conditions stated below. The staff notes, however, that the application does not provide any calculation to demonstrate that the package meets the tie-down system design requirement using acceleration factors in the Specific Safety Guide (SSG)-26, table IV.2.
Regarding component fatigue evaluations for tie-down during road transport, a weld inspection (as identified in the Major Maintenance penetrant exam scope in chapter 8 of the TN-BGC-1 Safety Analysis Report) should be performed prior to the first use of each package in the U.S., unless the package is new or has undergone this type of inspection within 5 transports or one year of its first use in the U.S. If a package meeting the description above is then used exclusively in the U.S., resumption of the normal maintenance program is acceptable.
If pyrophoric contents, including metal powders, are transported, inerting of the primary packaging boxes should be performed, internal fitting, and the TN-BGC-1 cavity.
For Content 11, the presence of transuranic elements up to a maximum of 1 gram (g) is permitted.
The mixing of different sub-contents within the same package is prohibited.
The transport period between package closure and opening at the destination facility will not exceed 1 year.
The presence of polyethylene is not authorized for air transport, regardless of the sub-content. In addition, for overland transport, the presence of polyethylene:
o is not authorized in sub-contents No. 11b and 11d, o
is authorized up to 1000 g in sub-contents No. 11a and 11c.
May 9, 2025
R. Boyle 2
The condition in chapter 3 section 2.5.1 (Content 11) and section 2.10.1 (Content 26) stated that the time between closure of the internal fittings at the shipping facility and the opening of the package at the consignee facility must be less than 1 year when polymer materials are present during transport.
A package shipped in a CB9-type overpack is transported under exclusive use.
For Content 11, if polymeric materials are present and if there is no Poral-type device (described in SAR chapter 3) on the lids of the internal fitting, a minimum free volume of 2 liters in the cavity of the internal fitting is required and the storage time of the closed internal fitting does not exceed 20 years.
Based on a review of the package handling and maintenance criteria, the staff recommends the applicant provide DOT with the following:
o Specific provisions for inspection of stainless-steel components to detect and evaluate indications of localized corrosion, stress corrosion cracking, and galvanic corrosion to ensure that components with unacceptable corrosion are repaired or replaced.
o Specific provisions for inspection of aluminum components to detect and evaluate indications of localized corrosion and galvanic corrosion to ensure that components with unacceptable corrosion are repaired or replaced.
o A bounding analysis to show that loss of boron atoms over the 40-year period of use will not result in a loss in effectiveness of the borated resin, or specific provisions to manage loss of neutron attenuation and shielding, such as through radiation monitoring and subcriticality testing, to ensure the borated resins continued effectiveness.
In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, requests for withholding, 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 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.
If you have any questions regarding this matter, please contact me or Nishka Devaser of my staff at 301-415-5196.
Sincerely, Yoira Diaz-Sanabria, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-3034 EPID No. L-2024-DOT-0002
Enclosure:
- 1. Safety Evaluation Report Signed by Diaz-Sanabria, Yoira on 05/09/25
ML25118A051 (pkg), ML25118A052 (ltr), ML25118A053 (encl)
OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME NDevaser SFigueroa ASotomayorRivera JSmith DATE 4/28/25 4/29/25 4/30/25 5/5/25 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME JSmith JBorowsky LHowe DJohnson DATE 5/5/25 5/6/25 5/7/25 5/7/25 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NAME TGovan LRegner YDiaz-Sanabria DATE 5/8/25 5/8/25 5/9/25