ML25126A234
| ML25126A234 | |
| Person / Time | |
|---|---|
| Site: | 07109405 |
| Issue date: | 05/29/2025 |
| From: | Stroud H Storage and Transportation Licensing Branch |
| To: | Podolak L QSA Global |
| References | |
| EPID L-2024-NEW-0010, 9405 | |
| Download: ML25126A234 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Lori Podolak, Senior Regulatory Affairs Specialist Regulatory Affairs Department QSA Global 40 North Avenue Burlington, MA 01803
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR REVIEW OF INITIAL APPLICATION FOR MODEL 1100 - ENTERPRISE PROJECT IDENTIFICATION NUMBER L-2024-NEW-0010
Dear Lori Podolak:
By letter dated October 3, 2024 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML24284A277), as supplemented on February 11, 2025 (ML25050A135, non-public), QSA Global has submitted an initial application for the Model 1100 transportation package design to the U.S Nuclear Regulatory Commission (NRC) for review.
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 30 calendar days from the date of this letter.
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.
May 29, 2025
L. Podolak 2
If you have any questions regarding this communication, please contact me at 301-287-3664, or via email to 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.: 71-9405 License/Certificate No.: 9405 EPID No.: L-2024-NEW-0010
Enclosure:
- 1. Request for Additional Information Signed by Stroud, Heath on 05/29/25
ML25126A234 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME HStroud GZhao JBorowsky SFigueroa DATE 5/12/2025 5/14/2025 5/15/2025 5/15/2025 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME TGovan LRegner YDiaz-Sanabria HStroud DATE 5/16/2025 5/23/2025 5/29/2025 5/29/2025
Enclosure UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Request for Additional Information Certificate of Compliance No. 9405 Docket No. 71-9405 Revision No. 0 Model No. 1100 Structural Evaluation RAI 2-1 Provide the reference of how the jacket holes/cut-out features used as a tie-down can withstand the accelerations defined in Title 10 of the Code of Federal Regulations (10 CFR) 71.45(b)(1) in route of transportation.
In section 2.5.2 of the safety analysis report (SAR), the applicant stated that the jacket cutout can withstand 11g force and maintain a factor of safety of 4. In the same section of the SAR, the applicant also stated that the jacket cutout feature can withstand 1.9 times of the package weight. It is not clear to the staff whether the jacket cutout feature can satisfy the stress requirements of 10 CFR 71.45(b)(1), when used as tie down device when subjected to 2g, 5g, 10g forces applied to the center of gravity of the package.
This information is needed to determine compliance with 10 CFR 71.45(b)(1).
RAI 2-2 Provide the justification or references of how the two penetration test locations are the most vulnerable and bound all possible cylinder locations.
In section 2.6.10 of SAR, it states that the penetration tests were performed by dropping the steel bar onto the lock body or lock slide. At the end of the section, it states that the tests at other locations would not result in a condition decreasing the effectiveness of the package; however, the justification for this conclusion is not clear based on the analysis provided.
This information is needed to determine compliance with 10 CFR 71.71(c)(10).
RAI 2-3 Provide the justification of how the two free drop test positions presented in the SAR bound all possible positions which could result in the most vulnerable condition of the package.
In sections 2.6.7 and 2.7.1 of the SAR, the applicant performed the free drop tests by dropping the package to the ground in two orientations: end drop and oblique drop. In section 2.7.1 of the SAR, the applicant stated that the drop orientations were made with the intention of breaching the Model 1100 weldment and/or removing or damaging the lock assembly which could allow aggregate damage during the subsequent puncture and thermal testing. In the Test Plan 237, the applicant stated that neither the side drop, nor the corner drop will create a larger shear
2 force on the attachment screws and damaging the lock assembly compared to the end and oblique drop, therefore the side and corner drop tests were not performed. It is not clear how this conclusion is drawn. There is no explanation why the shear failure of the screw and the lock assemble damage is the most vulnerable condition of the package.
In section 2.7.1.2 of the SAR, the applicant stated that a comparison is performed for Model 880 package and determined that the side drop orientation would result in less damage than the oblique drop. It is not clear what criteria is used to perform this comparison. In addition, there is no comparison of the drop results for the corner drop orientation is performed.
This information is needed to determine compliance with 10 CFR 71.71(c)(7) and 10 CFR 71.73.(c)(1).
Thermal Evaluation RAI 3-1 Clarify the behavior and effectiveness of the packages aluminum components (e.g., lock mount and cover) during the hypothetical accident conditions (HAC) fire.
Section 1.2.1 of the application indicated that many of the aluminum components (e.g., lock mount, cover) are used to ensure the source assembly is retained within the package (i.e.,
source tube) during accident conditions. However, table 3.2.B indicated that the aluminum components maximum service temperature is below the 800°C HAC fire that surrounds the aluminum components. The SAR did not clearly indicate that the components would retain their effectiveness at temperatures reached during the fire HAC.
This information is needed to determine compliance with 10 CFR 71.41(a).
RAI 3-2 Clarify the behavior of the plastic surround during the fire HAC and address its impact on the fires thermal evaluation.
Section 1.2.1.5 of the application mentioned the presence of an optional surround made from polyurethane. However, section 3.5 of the application did not address the behavior of the plastic surround during the fire HAC (e.g., which was partly based on fire tests of the Model 650L package described in section 2.7.4.5). In addition, the evaluation did not provide details of potential combustion effects (i.e., exothermic reactions), such as quantifying its thermal input (e.g., J/kg associated with the 2 kg mass of plastic surround, per table 7.1.A) relative to the thermal input to the package from the 800°C fire and discussing potential impacts on the packages integrity (e.g., melted plastic hindering pressure release).
This information is needed to determine compliance with 10 CFR 71.43(d).