ML25356A496

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Cover Letter and Enclosure - Request for Supplementary Information for 2025 51032-2 Amendment
ML25356A496
Person / Time
Site: 07109252
Issue date: 01/16/2026
From: Nishka Devaser
Storage and Transportation Licensing Branch
To: Travis Tate
Framatome
References
EPID L-2025-LLA-0150
Download: ML25356A496 (0)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Timothy J. Tate, Manager Framatome Inc.

2101 Horn Rapids Road Richland, WA 99354

SUBJECT:

REQUEST FOR SUPPLEMENTAL INFORMATION FOR THE REVIEW OF THE MODEL NO. 51032-2 PACKAGE

Dear Timothy Tate:

By letter dated September 3, 2025 (Agencywide Documents Access and Management System Accession No. ML25246C202), Framatome, Inc. submitted an application for revision of the Model No. 51032-2 package certificate of compliance. The staff performed an acceptance review of your application to determine if it contained sufficient technical information in scope and depth to allow the staff to complete a detailed technical review.

This letter is to advise you that the information needed to continue our review is described as request for supplemental information (RSI) in the enclosure to this letter. Please note that addressing the RSIs does not preclude the staff from issuing further requests for additional information during the course of the detailed technical review of this application.

In order to schedule our technical review, the RSI responses should be provided by February 16, 2026. If the RSI responses are not received by this date, the application may not be accepted for review and the staff may discontinue any further review.

Please reference Docket No. 71-9252 and Enterprise Project Identifier No. L-2025-LLA-0150 in future correspondence related to this request.

Sincerely, Nishka Devaser, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 71-9252 EPID: L-2025-LLA-0150

Enclosure:

Request for Supplemental Information January 16, 2026 Signed by Devaser, Nishka on 01/16/26

ML25356A496 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NAME NDevaser JHuang JSolis DATE 12/23/25 1/6/26 1/8/26 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NAME WWheatley LRegner JPiotter DATE 1/13/26 1/13/26 1/16/26 OFFICE NMSS/DFM NMSS/DFM NAME HYilma for YDiaz-Sanabria NDevaser DATE 1/16/26 1/16/26

Enclosure Request for Supplemental Information and Observation for the Model No. 51032-2 Package Docket No. 71-9252 This request for supplemental information identifies information needed by the staff in connection with its acceptance review of the Framatome Model No. 51032-2 package.

Chapter 3: Thermal Evaluation RSI 3-1.

Provide analysis or test results that show integrity of the packaging materials would be maintained during a regulatory fire test.

The safety analysis report (SAR) section 2.7.3 states that under thermal accident conditions the integrity of all packaging significant to the safety of the container would be maintained. However, the SAR does not provide any analysis or test results to support this statement. The staff needs this information to make a safety determination on the adequacy of the package during hypothetical accident (fire) conditions.

This information is needed to determine compliance with Title 10 of the Code of Federal Regulations 71.73(c)(4).

Chapter 7: Materials Evaluation RSI 7-1.

Describe any national or international codes, standards, programs, and/or procedures that are implemented to ensure that package maintenance activities (including visual inspections, screening and evaluation of visual indications, and corrective actions such as component repairs and replacements) are adequate to manage the effects of aging in metallic package components that would see long-term use, such that the package components are capable of performing their requisite safety functions throughout the period of use.

In the 51032-2, Aging Management Summary, Study No. 1010517, the applicant states that, Effects on the packaging are primarily limited to mechanical loadings applied by the packaging components (e.g., bolt torquing) and general external conditions (e.g., ambient environmental conditions such as moisture and UV exposure, or operational damage from loading/unloading and handling).The study also references SAR section 2.4.4 for an evaluation on corrosion effects.

Per the guidance in International Atomic Energy Agency (IAEA) SSG-26, Paragraph 613A.3, the package should be evaluated during the design phase in the demonstration of compliance with the Transport Regulations. Based on this evaluation, an inspection and maintenance program should be developed.

The program should be structured so that the assumptions (e.g. thickness of containment wall, leak-tightness, neutron absorber effectiveness) used in the demonstration of compliance of the package are confirmed to be valid throughout the lifetime of the packaging The staff requests that this description address the following criteria:

1.

Inspection methods (e.g., bare metal visual exams and/or other types of nondestructive exams such as liquid penetrant exams or ultrasonic exams)

2 for detection, characterization, and sizing of localized aging effects such as cracks, pits, crevice corrosion and the effects of moisture and ultraviolet (UV) exposure on the package.

2.

Inspection equipment and personnel qualification requirements (e.g., lighting and visual acuity requirements for performing visual exams) to ensure reliable inspections that can adequately detect and characterize indications of localized aging effects prior to component failure or loss of safety function.

3.

Acceptance criteria for aging effects such as indications of fatigue and localized corrosion of stainless steel components, such as chloride induced stress corrosion cracking (SCC), pitting, and crevice corrosion. Examples of visual indications that may indicate potential localized corrosion of stainless steel components include the accumulation of atmospheric deposits such as salts, buildup of corrosion products, rust-colored stains or deposits, and surface discontinuities or flaws associated with pitting, crevice corrosion, and/or SCC.

4.

Acceptance criteria for aging effects as a result of moisture and UV exposure on the package (add detail as necessary) 5.

Describe any surface cleaning requirements that are implemented to ensure that bare metal visual inspections of component surfaces can detect surface flaws, and for ensuring adequate removal of atmospheric deposits such as salts or other chemical compounds that may contribute to localized corrosion of stainless steel components.

6.

Describe any flaw evaluation methods (such as flaw sizing and flaw analysis methods) and associated flaw acceptance criteria that may be used to determine whether components containing flaws are acceptable for continued service.

This information is requested to verify compliance with requirements of the 2018 Edition of IAEA SSR-6, Paragraph 613A.

RSI 7-2.

Provide evaluations of abrasion and crack propagation as aging mechanisms for review by the U.S. Nuclear Regulatory Commission staff to verify that the effects of aging will be properly managed.

Per the guidance in IAEA SSG-26, Paragraph 613A.1, The designer of a package should evaluate the potential degradation phenomena over time, such as corrosion, abrasion, fatigue, crack propagation, changes of material compositions or mechanical properties due to thermal loadings or radiation, generation of decomposition gases and the impact of these phenomena on performance of safety functions.

Staff could not locate the description of the approach used to evaluate abrasion and crack propagation in the information submitted by the applicant.

This information is requested to verify compliance with requirements of the 2018 Edition of IAEA SSR-6, Paragraph 613A.

3 RSI 7-3.

Provide an inspection and maintenance program that addresses the effects of aging consistent with the guidance in IAEA SSG-26, Paragraph 613A.3, For packaging intended for repeated use, the effects of aging mechanisms on the package should be evaluated during the design phase in demonstration of compliance with the IAEA SSR-6. Based on this evaluation, an inspection and maintenance program should be developed.

Although the applicant provided Standing Operating Procedure 40072, Standard Operating Procedure: Shipping Container Maintenance and Rework Version 31.0, which describes unacceptable conditions which result in damage to the container, package or components and the rework and/or maintenance suggested for it, acceptance criteria are not specified. Thus, the staff requests the applicant to provide acceptance criteria in their inspection and maintenance program that addresses the effects of aging.

This information is requested to verify compliance with requirements of the 2018 Edition of IAEA SSR-6, Paragraphs 613A.