ML26044A128

Enclosure 1, Redacted, Safety Evaluation Report, for Model No. NT-XII Package, Certificate of Approval No. J/2007/AF-96, Rev. 0

ML26044A128
Person / Time
Site:	07103104
Issue date:	02/17/2026
From:	Yoira Diaz-Sanabria Division of Fuel Management
To:	US Dept of Transportation (DOT), Office of Hazardous Materials Safety
References
CAC A33010, EPID L-2025-DOT-0001
Download: ML26044A128 (30)

Text

OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION REPORT Docket No. 3104 Model No. NT-XII Package Certificate of Approval No. J/2007/AF-96 Revision 0 Table of Contents Page

SUMMARY

.................................................................................................................................... 1 REGULATORY REQUIREMENTS................................................................................................ 2 REVALIDATION RECOMMENDATION........................................................................................ 2

1.0 DESCRIPTION

OF THE PACKAGE................................................................................. 2 2.0 STRUCTURAL EVALUATION........................................................................................... 3 3.0 MATERIALS EVALUATION............................................................................................. 12 4.0 THERMAL EVALUATION................................................................................................ 21 5.0 CONTAINMENT EVALUATION....................................................................................... 24 6.0 CRITICALITY SAFETY EVALUATION............................................................................ 26 7.0 PACKAGE OPERATIONS............................................................................................... 28 8.0 QUALITY ASSURANCE PROGRAM.............................................................................. 29

9.0 REFERENCES

................................................................................................................ 29 CONCLUSION............................................................................................................................ 30

SUMMARY

By letter dated February 10, 2025 (DOT, 2025a), as supplemented on August 5, 2025 (EDL, 2025), September 10, 2025 (DOT, 2025 b), and November 14, 2025 (DOT, 2025c), the United States (U.S.) Department of Transportation (DOT) requested our assistance in the revalidation review of the Model No. NT-XII package, Japans Certificate of Approval No. J/2007/AF-96, Revision 1, Model No. NT-XII, (ML25148A394). The staff recommends the revalidation of the Japans Certificate of Approval No. J/2007/AF-96, Revision 1, with the proposed conditions to the U.S. DOT certificate for the Model No. NT-XII stated in the section titled Revalidation Recommendation.

This document includes the staffs evaluation of DOTs request.

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OFFICIAL USE ONLY - PROPRIETARY INFORMATION REGULATORY REQUIREMENTS The NRC reviewed the information provided to the DOT by Nuclear Fuel Industries, Ltd. in its application for the Model No. NT-XII package and its supplements against the regulatory requirements of the International Atomic Energy Agency (IAEA) Safety Standard Series No. 6 (SSR-6), Regulations for the Safe Transport of Radioactive Material, 2018 Edition, Revision 1.

REVALIDATION RECOMMENDATION The NRC staff (hereafter the staff) recommends the revalidation of the Competent Authority Certificate No. J/2007/AF-96, Revision 1, (ML25148A394) for transporting the 9x9 BWR fuel assembly within the Model No. NT-XII package described in the safety analysis report (SAR)

(DOT, 2025a). The certificate for the Model No. NT-XII package is for 80 years. The staffs technical findings on the applicants evaluation of ageing mechanisms are limited to 5 years.

The staff recommends adding the following proposed conditions to the U.S DOT certificate for the Model No. NT-XII:

1)

Transport by air is not authorized.

2)

Expiration date 2/28/2031.

3)

A repair and re-inspection of the lifting attachment shall include a visual inspection to ensure that there are no abnormalities or harmful, scratches, cracks, etc., that may affect the safety function of the lifting attachment.

The following sections include the staffs evaluation.

1.0 DESCRIPTION

OF THE PACKAGE Chapter I of the application (DOT, 2025a) includes a general description of the Model No. NT-XII package. The Model No. NT-XII package is a Type A fissile (Type AF) package with a SUS304 steel plate structure designed for the transportation of two unirradiated 9x9 boiling water reactor (BWR) rectangular-shaped fuel receptacles. The package does not include radiation shielding as it is intended for minimal radiation levels. The applicant noted in Section II-G that there are no liquids in the package.

In its response to the NRC observations (DOT, 2025b), the applicant stated that the package will not be transported by air. The staff recommends the addition of a U.S. DOT certificate condition to not allow transport of the Model No. NT-XII package by air.

1.1 Description of the Packaging The Model No. NT-XII packaging consists of an outer receptacle housing, the fuel receptacle, and a lid constructed of stainless steel. An aluminum honeycomb impact limiter is attached to the inner surface of the outer receptacle. The outer receptacle and the fuel receptacle are described in more detail in Section 2.2.1 of this SER.

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OFFICIAL USE ONLY - PROPRIETARY INFORMATION 1.2 Description of the Package Content Sections I-D, II-D.1 and II-D.2 of the SAR provided content details and stated that the package transports two 9x9 BWR fuel assemblies enriched to less than 5 weight percent of Uranium-235

(% U-235) with a maximum uranium content weight of [Official Use Only (OUO)-Proprietary Information - Information withheld per 10 CFR 2.390]kilograms (kg). Sections II-B.1.1, II-B.3, and II-D.2.1(1) of the SAR noted that the unirradiated commercial fresh1 fuel uranium dioxide fuel pellets consisted of U-232, U-234, U-235, U-236, U-238, and Technetium-99 (Tc-99) radionuclides and provided their individual weight percent composition with a sum total of 100%.

The total activity of [OUO-Proprietary Information - Information withheld per 10 CFR 2.390]

Giga-becquerels (GBq) and the activity of each nuclide was provided in SAR Table II-D-3 of the SAR, which indicated the contents mixture has less than an A2 of activity. Section II-B.1.1 of the SAR also stated that the unirradiated fresh fuel has a decay heat of no more than [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] watts (W). Additional details of the contents and containment boundary, including densities of uranium dioxide pellets and cladding materials, were provided in Section I-D(5). The evaluation of the containment boundary can be found in section 5 of this SER.

1.3 Drawings The application provides general arrangement drawings of the packaging components, including a list of component materials. The packaging enclosures do not form a leak-tight containment boundary since containment of the fuel pellets is provided by the zirconium alloy fuel rod cladding and welded end plugs. However, the packaging includes rubber packings for the receptacle closure surfaces to protect against the intrusion of water into the receptacles.

The staff reviewed the general description of the NT-XII package and the packaging component drawings and verified that the description of the package contents, packaging components, design functions, and materials of construction is sufficient to support the staffs review of materials properties and performance for the NT-XII package. Therefore, the staff finds that the drawings and general description in the package application are acceptable, and the package meets the requirements in Paragraphs 640 and 815 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.0 STRUCTURAL EVALUATION 2.1 Regulatory Requirements The purpose of the structural evaluation is to verify that the structural performance of the package meets the requirements of IAEA SSR-6, 2018 Edition (IAEA, 2018a), Paragraph Nos.

607, 608, 609, 613, 616, 637, 638, 639, 614, 643, 645, 721, 722, 723, 724, 726, 727, and 728. A summary of the staffs structural evaluation is provided below.

2.2 Evaluation 2.2.1 Description of Structural Components The package is composed of two main structural components:

1 Fresh fuel is also known as unirradiated fuel.

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OFFICIAL USE ONLY - PROPRIETARY INFORMATION (1)

Fuel receptacle

i.

The fuel receptacle is a rectangular, double-walled stainless-steel container with a double wall top lid bolted to the side walls through flanges. The space between the outer shell and inner shell is filled with ceramic fiber as insulation material.

ii.

The fuel receptacle is designed to hold two unirradiated BWR fuel assemblies (enrichment up to 5.0 wt.% U-235) placed side by side in a single cavity. Each assembly follows a 9x9 rod lattice configuration with a center water channel.

a)

The rods are pressurized with helium to a maximum of [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] Mega Pascals (MPa) and use Zircaloy-2 as cladding material with both ends sealed with Zircaloy-2 end plugs and welded to the cladding tube.

b)

The cladding serves as the containment boundary for the package.

c)

Since the fuel is fresh and unirradiated, it generates negligible decay heat, making it suitable for dry transport.

d)

Internal support (aluminum honeycomb and polyethylene foam) of the fuel assembly maintains fixed spacing support for the cladding and keeps alignment for the purpose of maintaining the mechanical stability and criticality control.

e)

The receptacle and top lid are sealed with bolts and neoprene rubber gaskets and use a ceramic fiber insulation layer between the walls for thermal protection. Polyethylene foam maintains the position of the fuel assemblies and provides impact protection under HAC.

iii.

Each package is capable of carrying up to two fuel assemblies, with a maximum of [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] packages allowed per shipment.

(2)

Outer receptacle

i.

The outer receptacle is a rectangular stainless-steel enclosure with top lid bolted to the side walls through flanges, equipped with lifting hooks, and mounted on a wooden skid for ease of handling and stability.

ii.

The space between the fuel receptacle and outer receptacle is filled with aluminum honeycomb and polyethylene foam, both of which serve as impact-absorbing materials during transport.

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OFFICIAL USE ONLY - PROPRIETARY INFORMATION The applicant listed the dimensions of the package in Table I-1 and the weights in Table II-A-2 of the SAR. The center of gravity is shown in Figure II-A-1 of the SAR.

Based on the description of the package in Chapter I and the structural analyses documented in the SAR, including lifting component analysis in Section II-A.4.4, pressure analysis in Section II-A.4.6, and vibration analysis in Section II-A.4.7, the staff finds that the package meets the requirements of Paragraph 607 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.2 Design Code The applicant considered the applicable structural requirements in the following IAEA SSR-6, 2018 Edition (IAEA, 2018a), requirements:

(1)

General requirements for all packages (Paragraphs 607-618).

(2)

Requirements for Type A packages (Paragraphs 635-651).

(3)

Requirements for packages containing fissile material (Paragraphs 673-686).

(4)

Test Requirements for packages under normal conditions of transport (NCT) and accident conditions of transport (ACT) (Paragraphs 719-729).

In Section II-A.1.2 and Table II-A-1 of the SAR, the applicant described structural design criteria, design load cases, analysis methods, and design criteria for the package, including the allowable stresses used in the stress analyses. Since this package is classified as a Type package, the ACT do not apply. However, the package is designed to contain more than 15 grams (g) of fissile material and, therefore, the package was tested under ACT specified for transportation of fissile as defined in IAEA SSR-6, 2018 Edition (IAEA, 2018a).

The staff reviewed the structural design criteria and found they are appropriate for demonstrating that the package satisfies the requirements of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.3 Evaluation for General Requirements for All Packages 2.2.3.1 Minimum Package Size The staff reviewed the drawings of the package body in the SAR and found that no overall external dimension of the package is less than ten centimeters (10 cm) therefore the package meets the requirements of Paragraph 636 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.3.2 Tamper-Indicating Features and Positive Closures The applicant described that the packaging is bolted at the flange and provided the bolt details including the tightening torque. In addition, the applicant mentioned in Table II-G in the SAR (DOT, 2025a) that a seal is applied to a zone covering both, the lid and the body, as a tamper-indicating feature. This feature gives a clear indication if the outer receptacle has been opened.

The staff reviewed the data in Table II-A-6 and the drawings with bolting details and found that the bolts could not be opened by mishandling and that the tamper-indicating seal features are effective. Therefore, the staff determined that the package design satisfies the requirements of Paragraphs 637, 641, and 643 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

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OFFICIAL USE ONLY - PROPRIETARY INFORMATION 2.2.3.3 Lifting Device The applicant described the detailed design, structure, and stress analysis of the lifting devices used for both the outer and fuel receptacles in Section II-A.4.4 of the SAR. The outer receptacle utilizes a stainless-steel lip channel steel welded to its underside and hooks on the upper shell for lifting, while the fuel receptacle employs bow shackles, standing hooks, and lifting handles.

In Section II-A.4.4 of the SAR, each lifting component was analyzed for stress considering a lifting load of three times the gross weight. Stress results for the outer receptacle lifting component, the stainless-steel lip channels, stainless-steel hooks, and the welds connecting them to the packaging are provided in Section II-A.4.4.1 of the SAR and compared with the stress criteria in Section II-A1.2. Stress results for the fuel receptacle, bow shackles, standing hooks, lifting handles for the upper lid, and the weld connecting them to the packages are provided in Section II-A.4.4.2 of the SAR and compared with the stress criteria in Section II-A1.2. The applicant performed manual calculations for lifting components using finite element analysis (FEA) for complex parts like the upper lid hooks. The calculation included simplified assumptions such as reduced sling contact widths and increased lift frequencies. The applicant performed fatigue analyses in Section II-A.4.4.3 showing that under double usage scenarios, the stress amplitudes based on the maximum stress results in Sections II-A.4.4.1 and II-A.4.4.2 of the SAR remain within safe limits for the service life of the package.

The staff reviewed the lifting analyses and found that a loading factor of three is sufficient to account for snatch lifting. The manual calculation and FEA results presented in Sections II-A.4.4.1 and II-A.4.4.2 of the SAR demonstrated that tensile, shear, or bending stresses remain below the yield strength of SUS 304 stainless-steel per design criteria in Section II-A.1.2 of the SAR. Therefore, the staff determined that the package design satisfies the requirements of Paragraphs 608 and 609 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.3.4 Tie-down The applicant provided a tie down system for a total of four packages arranged in two by two (2 x 2) on a 20 feet (ft.) standard truck container. These four packages are secured with carbon steel wire ropes and wooden blocks to the container. The impact accelerations used in the tie down analysis are 2g in all three perpendicular directions. The stress introduced by the impact accelerations to the package below the yield stress criterion.

The staff reviewed the analysis and found the tie-down configuration provides the intended function and the accelerations used in the analysis are more than the acceleration defined in Table IV.2 of IAEA Specific Safety Guide No. 26 (SSG-26) (IAEA, 2018b). Therefore, the staff determined that the package design satisfies the requirements of Paragraph 638 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.3.5 Pressure In Section II-A.4.6 of the SAR, the applicant evaluated the structural integrity of the fuel rods under pressure conditions during transport. The fuel rods, initially packed at 0 degrees Celsius

(°C), were heated to the maximum temperature of [OUO-Proprietary Information -

Information withheld per 10 CFR 2.390]°C calculated in Section II-B.4.2 of the SAR, causing increased internal pressure. Simultaneously, the ambient pressure was dropped to 60 kilo Pascals (kPa), resulting in a pressure differential acting on the cladding tubes. The analysis in the SAR calculated both circumferential and axial stresses on the zircaloy-2 cladding and

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OFFICIAL USE ONLY - PROPRIETARY INFORMATION checked these against the material yielding stress separately. Both show that the resulting stress from the pressure reduction is below the maximum stress criteria defined in Section II-A.1.2. Additional data provided by the applicant showed that the stress results remained below the maximum stress criteria for an increase in external temperature to 70°C per Paragraph 639 of IAEA SSR-6, 2018 Edition (IAEA, 2018A).

The staff reviewed the pressure reduction section and found that the stress calculation is sufficient to account for the pressure reduction specified in the IAEA SSR-6, 2018 Edition (IAEA, 2018a) and the differential pressure introduced by the maximum temperature for NCT.

The stainless-steel stress results satisfy the design criteria in Section II-A.1.2 of the SAR.

Therefore, the staff determined that the package design satisfies the requirements of Paragraphs 639 and 645 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.3.6 Vibration In Section II-A.4.7 of the SAR, the applicant evaluated the packages structural response to vibration during routine transport. Appendix II-A.5 of the SAR includes the analysis performed by the applicant to derive the packages natural frequency. This analysis used a finite element model built with simplified geometry of the package using a pinned support condition. The model analysis resulted in a natural frequency of [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] hertz (Hz), which is higher than the typical excitation frequencies generated by trucks and trailers (less than [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] Hz). The shear stress on the bolts securing the outer receptacle and the fuel receptacle is both below the allowable stress limit for SUS 304J3 stainless-steel.

The analysis also considers the worst-case scenario of horizontal displacement between bolted components and confirms that the bolts will not fail or loosen. Additionally, the applicant references stacking evaluations conducted under NCT in Section II-A.5.4 of the SAR, where the package endures loads up to five times its weight without deformation.

The staff reviewed the analysis model and found that the geometry and mass are captured through the element density. The staff noted that the model constraints are set up at the bottom of the model without considering the tie down constraint. This results in a higher frequency which drives the package natural frequency farther from the vibration frequency (more conservative). Therefore, the staff determined that the frequency separation between the packages natural frequency and the vibration frequency from the transportation vehicle confirms that resonance is unlikely. In addition, based on the review of the vibration analysis, the staff found that the NT-XII package has a sufficient safety margin and will maintain structural integrity and containment performance throughout its transport lifecycle. Therefore, staff determined that the package design satisfies the requirements of Paragraph 613 of the IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.4 Normal Conditions of Transport (NCT) 2.2.4.1 Thermal Test In Section II-A.5.1 of the SAR, the applicant evaluated the packages structural integrity under normal thermal test conditions. Sections II-B.4.2 and II-B4.3 of the SAR include the discussion of the thermal condition under NCT for Model No. NT-XII. The applicant stated that the thermal expansion of the package is minimal due to the metallic construction and good thermal conductivity of the materials. Because the outer receptacle is not sealed, no pressure differences are generated due to temperature changes, and therefore no pressure stress is

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OFFICIAL USE ONLY - PROPRIETARY INFORMATION considered in the NCT thermal condition for the outer receptacles. The applicant evaluated the stress of the fuel receptacle shell, fuel receptacle bolts, and fuel rods due to temperature induced differential pressure based on the design criteria in Section II-A.1.2 of the SAR. A fatigue and repetitive stress impact study is presented in Section II-A.5.1.5. Considering the number of conservatively estimated stress cycles, the fatigue curves for stainless-steel and chrome molybdenum steel in Figures II-A-16 and II-A-21 show that the stress amplitudes are within limits.

Based on the staffs review of Sections II-A.5.1, II-B.4.2, II-B.4.3, II-A.1.2, and II-A.5.1.5 of the SAR, the staff finds that the package components subjected to the pressure difference are properly evaluated, including the fatigue impact, to satisfy the requirements of Paragraph 616, 639, and 728 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.4.2 Water Spray Test In Section II-A.5.2 of the SAR, the applicant evaluated the packages performance under the water spray test condition. Because parts of the packaging are covered with stainless-steel plates that have high corrosion resistance, and the joints are welded continuously, deterioration of the external surface material due to water spray does not occur. The applicant concluded that the water spray test will not impair the structural performance of the package.

The staff reviewed the water spray section and found that the applicants assessment is consistent with the IAEA SSG-26 (IAEA, 2018b). Because the package passed the water spray test, the staff determines that the package meets the requirements of Paragraph 721 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.4.3 Free Drop Test In Section II-A.5.3 of the SAR, the applicant evaluated the free drop test for NCT. The applicant evaluated the package for a 0.3-meter (0.3-m) drop onto a rigid surface using a prototype for the drop tests.

The prototype tests described in Section II-A.5.3(b) of the SAR assessed the structural integrity of the package by conducting 1.2-m free drops in three orientations; horizontal, vertical, and corner. These tests used a full-scale prototype filled with simulated fuel assemblies to replicate real transport conditions.

The staff reviewed the drop test provided by the applicant. The tests in Appendix II-A.3 properly evaluated various drop orientations, including the most severe damaging drop orientation, which was used in final qualification testing for the package. The staff found that the orientations utilized by the applicant in the final qualification tests were properly set up as required by Paragraph 722 of the IAEA SSR-6, 2018 Edition (IAEA, 2018a). Table 1 includes a summary of the results of these tests related to the deformation of the package.

Table 1. Model No. NT-XII Full-Scale Prototype Free Drop Tests Orientations and Brief Description of Results Free Drop Orientation Brief Description of the Test Result Horizontal drop outer receptacle showed minor shrinkage (up to [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] millimeter (mm)), but no significant damage.

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OFFICIAL USE ONLY - PROPRIETARY INFORMATION Vertical drop Caused less than [OUO-Proprietary Information -

Information withheld per 10 CFR 2.390] mm of lengthwise deformation, with no flange or bolt failures.

Corner drop Resulted in localized deformationup to [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] mm in length and [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] mm in heightmainly absorbed by the corner reinforcements.

The staff reviewed the test and results and found that the main body of the packaging retained its shape, and no breakage or leakage from the fuel receptacle occurred. The maximum internal volume reduction across all tests was [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] for all three drop orientations which confirms that the packaging can withstand the NCT free drop test. Thus, the staff determines that the package meets the requirements of Paragraph 722 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.4.4 Stacking Test The applicant described the evaluation of the stacking test in Section II-A.5.4 of the SAR. In this test, a load equivalent to five times the packages weight was applied evenly to the top and bottom surfaces of the prototype packaging for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The results showed no visible deformation or significant dimensional changes in the packaging.

Based on the staffs review of Section II-A.5.4, Appendix II-4.1.3, and Appendix II-5.1.3 of the SAR, the staff finds that the package satisfies the requirements of Paragraph 723 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.4.5 Penetration Test The applicant described the evaluation of the penetration test in Section II-A.5.5 of the SAR.

The applicant considered the thinnest part of the external plate of the package as the bounding location for penetration. The result showed that the steel bar did not penetrate the outer receptacle. The impact caused a minor dent of about [OUO-Proprietary Information -

Information withheld per 10 CFR 2.390] mm.

The staff reviewed the NCT penetration test in the SAR and found that the test considered the most critical location on the package external shell. The staff reviewed the test setup in Appendix II-4.1.4 and the results in Appendix II-5.1.4 considering the requirements of Paragraphs 724(a) and 724(b) of IAEA SSR-6, 2018 Edition (IAEA, 2018a). Since the package showed minimal deformation after the test, the staff finds that the package satisfies the penetration test criteria.

2.2.5 Accident Conditions of Transport (ACT) 2.2.5.1 Drop Test The applicant described the evaluation of the package subject to ACT 9-m free drop test in Section II-A.9.2.1 of the SAR. The applicant evaluated the package body for the drop I mechanical test in the following four orientations:

i.

top-down vertical drop,

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 10 OFFICIAL USE ONLY - PROPRIETARY INFORMATION ii.

horizontal side down drop, iii.

inclined orientation with corner facing downward drop, and iv.

inclined.

The test was conducted using a full-scale prototype package that replicated the actual structure and dimensions, and it contained a simulated fuel assembly with equivalent weight and geometry.

The applicant listed the maximum resulting deformation of the outer receptacle and fuel rods for all drop orientations in Section II-A.9.2.1.5. The applicant performed a helium leak test of the fuel rods before and after each drop test and confirmed that there were no helium leaks. From these results, the applicant concluded that the package body maintained structural integrity during the free drops.

Based on the staffs review of Section II-A.9.2.1, Appendix II-A.2.4.2.1, and Appendix II-A.2.5.2.1 of the SAR and the ACT drop tests did not result in helium leaks, the staff finds that the package satisfies the requirements of Paragraph 727(a) of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.5.2 Puncture Test The applicant described the evaluation of the package subject to ACT puncture test in Section II-A.9.2.2 of the SAR. In this test, the package was dropped from a height of 1 m onto a steel bar with a diameter of 150 mm and a rounded edge. The applicant evaluated the package body for the drop II mechanical test in the following three orientations:

i.

a horizontal drop with the side facing down, ii.

a horizontal drop with the upper lid facing down, and iii.

a vertical drop with the top side facing down.

Among these, the horizontal drop with the side facing downward produced the deepest dent and was selected for the final test. The dent was measured and no penetration was observed. From these results, the applicant concluded that the package body maintained structural integrity after the puncture test.

Based on the staffs review of Section II-A.9.2.2, Appendix II-A.2.4.2.2, and Appendix II-A.2.5.2.2 the staff finds that the package satisfies the requirements of Paragraph 727(b) of IAEA SSR-6, 2018 Edition (IAEA, 2018a) because the package maintained structural integrity following the worst-case ACT puncture test.

2.2.5.3 Thermal Test The applicant described the evaluation of the package subject to the ACT thermal test in Section II-A.9.2.3 of the SAR. Following the mechanical tests, the package was subjected to a thermal test to simulate fire exposure. The maximum outer surface and the fuel rod surface

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 11 OFFICIAL USE ONLY - PROPRIETARY INFORMATION temperature and duration were recorded. The integrity of the packages body shape was maintained, and no bolt failures occurred.

Based on the staffs review and the satisfactory results of the thermal test in Section II-A.9.2.3 of the SAR, the staff finds that the package satisfies the requirements of Paragraph 728 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.5.4 Fuel Rod Evaluation The applicant combined the temperature difference during the NCT and recorded the fuel rod temperature and performed an analysis to derive the circumferential stress. The applicant compared the results with the stress criteria and determined that the fuel rods were not impaired. The applicant also considered that, after the drop test, the stress on a fuel rod is negligibly small due to the small bending angle observed after the test.

The staff reviewed the fuel rod evaluation and disagreed with the applicants explanation that the fuel rod stress due to the drop test is negligibly small. Given the displacement of [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] mm on the lowest fuel rod span of [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] mm, and following the Euler-Bernoulli beam theory, the estimated bending stress for the Zircaloy-2 tube can be estimated. IAEA SSR-6 Paragraph No. 726 states the following:

specimen shall be subjected to the cumulative effects of the tests specified in paras 727 and 728, Thus, the fuel must be evaluated for the effects from both the drop test and the thermal test.

The staff further assessed the geometry and displacement provided by the applicant and determined that the final maximum von Mises stress of the fuel rod resulting from both tests is around [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] MPa, which is much larger than the circumferential stress result reported in the SAR. Therefore, only evaluating the stress from thermal test does not satisfy the IAEA SSR-6, 2018 Edition (IAEA, 2018a) criteria. However, based on the fact that the helium leak test was performed without leakage as stated in Appendix II, and that the final stress could decrease due to the high temperature during the thermal test, the staff determines that the package and fuel rod and the package design is structurally safe and, therefore, compliant with the requirements in Paragraph 726, 727, and 728 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

2.2.5.5 Water Immersion Test The applicant did not perform the physical water immersion test because the criticality safety analysis performed in Section II-E of the SAR considered ingress of water into the packaging.

The staff reviewed the applicants reason for not performing the water test and found that the 0.9-m immersion will introduce much smaller pressure to the fuel assembly compared to the thermal test. Therefore, the staff determined that the water immersion would not compromise the structural integrity of the packages containment.

2.3 Evaluation Findings

Based on a review of the statements and representations contained in the application, the staff finds that the structural evaluation for the Model No. NT-XII meets the requirements of the IAEA

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 12 OFFICIAL USE ONLY - PROPRIETARY INFORMATION SSR-6, 2018 Edition, Paragraphs Nos. 607, 608, 609, 613, 616, 637, 638, 639, 614, 643, 645, 721, 722, 723, 724, 726, 727, and 728.

3.0 MATERIALS EVALUATION 3.1 Regulatory Requirements The purpose of the materials evaluation is to verify that the performance of the materials used to build the package components meets the requirements of IAEA SSR-6, 2018 Edition, Paragraph Nos. 607, 608, 609, 613, 616, 637, 638, 639, 614, 643, 645, 721, 722, 723, 724, 726, 727, and 728. A summary of the staffs materials evaluation is provided below.

3.2 Evaluation 3.2.1 Material Specifications and Standards Section I-C of the application provides material specifications for the packaging components.

For the metallic subcomponents of the packaging body receptacles, the staff confirmed that the application adequately identifies material specifications based on standard alloy grade. Based on its confirmation of the material composition and properties for the metallic packaging components, the staff determined that the material standards specified in the application are acceptable for use in the construction of the packaging components.

The nonmetallic components of the packaging include:

(1) the polymer foam for the shock absorbers, (2) the ceramic fiber insulation, and (3) the rubber packings to protect against moisture intrusion into the packaging enclosures.

The staff noted that a material consensus standard is not specified for these nonmetallic items.

However, the staff verified that the application includes sufficient information concerning the composition, properties, and performance of these materials to validate their suitability for supporting the packaging component design functions, as evaluated in the package safety analyses. Therefore, the staff determined that the material specifications for the nonmetallic packaging components are acceptable.

Based on the review of the application, the staff finds that the material specifications and standards included in the application are acceptable. Accordingly, the staff finds that the package meets the requirements in Paragraph 640 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

3.2.2 Weld Fabrication and Inspection The application includes information about the use of welded joints for the packaging receptacles. The staff noted that the initial submittal did not include information concerning the codes, standards, and other specifications that are followed for qualification of weld fabrication processes and associated nondestructive examination methods (NDE) for inspection of packaging welds that are placed into service.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 13 OFFICIAL USE ONLY - PROPRIETARY INFORMATION In its response to the staffs request for additional information (RAI M-1) (DOT, 2025c), the applicant provided a description of its requirements and use of consensus standards for qualification of weld fabrication processes and associated NDE methods. The applicant identified that welding shall be performed by qualified welders and processes in accordance with the specified national and international consensus standards, and all packaging welds shall be examined prior to first use to verify conformance with applicable codes, standards, and design requirements. The applicant provided references for national and international consensus standards addressing qualification of weld fabrication processes and associated NDE methods to ensure that welds in packaging components that are placed into service will be capable of maintaining their structural integrity.

The staff reviewed the applicants RAI response and found that the applicant provided an adequate description of consensus standards for ensuring that welding processes and personnel are adequately qualified to produce welded joints that meet the structural design and IAEA requirements. The staff verified that these standards address essential variables affecting weld quality. With respect to weld NDE, the staff confirmed that the applicant specified adequate visual and surface examination requirements and acceptance criteria for ensuring that packaging welds are free of unacceptable fabrication defects. This includes requirements for implementation of established consensus standards covering examination conditions and qualification of examination personnel. Therefore, based on its review of the applicants RAI response, the staff determined that the applicants requirements and use consensus standards for qualification of weld fabrication processes and associated NDE methods for fabrication inspection of packaging welds are acceptable.

Based on the information provided by the applicant, the staff determined with reasonable assurance that the package meets the requirements in Paragraphs 640, 648, and 673 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

3.2.3 Mechanical Properties of Materials Section II-A of the SAR lists the mechanical properties of the package materials used in the structural evaluation and provides an evaluation of the lowest service temperature performance characteristics of the package materials. The application specifies yield stress and ultimate tensile strength for the stainless-steel enclosures and bolts and the zirconium alloy cladding.

The staff reviewed the properties specified for these items and verified that they are generally consistent with those specified in the applicable standards and technical literature for these types of materials. Therefore, the staff determined that the mechanical properties of the metallic items for the packaging components are acceptable. Since the structural performance of the package for normal and accident conditions of transport is demonstrated, in part, by performing actual drop tests on a package prototype, the staff determined that the specification of the yield and tensile strength of the packaging materials are sufficient for ensuring adequate structural performance.

The staff noted that the application does not include any mechanical properties for nonmetallic items. However, other than the polymer foam used as impact absorbers, there are no nonmetallic structural components. The staff confirmed that the impact absorbing properties of the polymer foam are adequately qualified for normal and accident conditions by actual drop testing.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 14 OFFICIAL USE ONLY - PROPRIETARY INFORMATION Section II-A of the SAR includes an evaluation of material fracture toughness at the lowest service temperature. The staff reviewed this information and confirmed that the stainless steel and aluminum alloy, used for the packaging enclosures and impact absorbers, have adequate resistance to brittle fracture at the lowest service temperature since these materials do not undergo significant ductile to brittle transition over this temperature range. Based on its review of the information in Section II-A of the SAR, the staff determined that the lowest service temperature performance characteristics of the packaging materials are acceptable.

Based on its review of the application, the staff finds that the mechanical properties of the package materials used in the structural evaluation and the lowest service temperature performance characteristics of the package materials are acceptable. Accordingly, the staff finds that the package meets the requirements in Paragraphs 616, 639, 640, and 648 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

3.2.4 Thermal Properties of Materials Section II-B of the SAR provides thermal properties of the package materials used in the package thermal evaluation. The thermal properties reported in the application include:

(1) density, (2) thermal conductivity, (3) specific heat capacity, (4) emissivity, and (5) solar absorption coefficient.

The staff reviewed the thermal properties of the packaging materials and verified that they are consistent with the values available in the technical literature.

The staff reviewed the application to determine whether the package materials show adequate performance considering the maximum component temperatures for normal and accident conditions of transport. The application describes damage due to high temperature combustion of the rubber packings and polymer foam impact absorbers for the accident condition thermal test. However, the staff identified that the application adequately considered the effect of this damage on the criticality safety performance of the package. The staff also verified that the application demonstrated that the accident condition thermal test would not cause a loss of fuel rod integrity considering high temperature pressurization inside the fuel rod cladding during the thermal test. All other package materials showed acceptable thermal performance for normal and accident conditions of transport. Therefore, the staff determined that the application adequately evaluated the packaging and fuel rod materials for normal and accident conditions of transport.

Based on its review of the application, the staff finds that the thermal properties of the packaging materials used in the package thermal analyses are acceptable, and the package meets the requirements in Paragraphs 616, 639, and 640 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 15 OFFICIAL USE ONLY - PROPRIETARY INFORMATION 3.2.5 Shielding and Criticality Control Section II-D of the SAR describes the shielding analysis for the Model No. NT-XII package.

Since the NT-XII package is for transporting low activity unirradiated nuclear fuel assemblies, the package does not include any specific radiation shielding materials or shielding structures.

The staff determined that the structural integrity of the package enclosures is sufficient to ensure radiation dose rates are within the acceptable limits.

Section II-E of the SAR describes the criticality safety analysis for the NT-XII package. The Model No. NT-XII package does not use any neutron absorbers to maintain subcriticality for normal and accident conditions of transport, and the damaged condition of the polymer foam impact absorbers and rubber packings are accounted for in the criticality analysis. The staff noted that the criticality analysis shows that the structural condition of the packaging enclosures and the fuel assemblies is sufficient to ensure subcriticality of the unirradiated nuclear fuel for normal and accident conditions of transport. Therefore, the staff finds that the package materials are adequate to meet the requirements in Paragraph 673 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

3.2.6 Chemical and Galvanic Reactions Section II-A.4 of the application includes an evaluation of the potential for chemical and galvanic reactions of the packaging components and the package contents. This section lists all of the dissimilar materials that may come into contact with each other (between packaging components, between packaging components and the package contents, etc.).

The staff reviewed the applicants description of the dissimilar material contacts for the package and confirmed that no significant chemical, galvanic, and/or corrosive reactions are expected to occur between dissimilar materials since the materials are not chemically reactive and the interior of the package enclosures remain dry. The staff confirmed that the use of rubber packings for package enclosures should adequately protect against the intrusion of water and dissolved compounds from weather and debris into the package interior, thereby preventing the formation of aqueous electrolytes that could lead to significant corrosion inside the package.

The staff also confirmed that the application includes an adequate evaluation of the effects of water spray on the external surfaces of the package. However, if left unmitigated, the electrolytes from outdoor water spray may lead to localized corrosion for stainless steel surfaces over extended service periods. The evaluation of normal and expected aging mechanisms due to potential localized corrosion on external stainless steel surfaces, is addressed in Section 3.2.7 of the SER.

For accident conditions of transport, in particular thermal test conditions, the staff confirmed that the application demonstrates that the metallic components of the package do not undergo any significant chemical reaction or phase transformation. The staff noted that the applicants evaluation of thermal test conditions reports that the polymer foam and rubber showed some damage due to combustion. However, the performance of these materials did not have any adverse effect on the structural integrity or analyzed subcritical configuration of the unirradiated nuclear fuel for normal and accident conditions of transport. Therefore, the staff determined that the application includes an adequate demonstration that packaging components and package contents are adequately protected from significant adverse chemical and galvanic reactions.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 16 OFFICIAL USE ONLY - PROPRIETARY INFORMATION Based on its review of the application, the staff finds that the design and construction of Model No. NT-XII package adequately protects against adverse chemical and galvanic reactions that may affect the ability of the package to perform its safety functions, and the package meets the requirements in Paragraph 614 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

3.2.7 Evaluation of Aging Section II-F of the application describes the evaluation of aging mechanisms for the packaging components.Section III describes visual inspections of components for package handling and maintenance. The staff reviewed the following information to determine whether the application meets the requirements in Paragraph 613A of IAEA SSR-6, 2018 Edition (IAEA, 2018a) and associated guidance in the Paragraphs 613A.1 and 613A.3 of IAEA SSG-26, 2018 Edition:

(1)

List of safety-related packaging components and associated materials of construction subject to aging evaluation; (2)

Evaluation of packaging component aging mechanisms due to heat, radiation, chemical reactions, and fatigue over the 80-year planned period of use; (3)

Visual inspection criteria for managing the effects of aging mechanisms on the safety performance of packaging components.

3.2.7.1 Packaging Components and Materials Section II-F of the application includes a list of package components and associated materials that are included in the scope of the aging evaluation. The scope of components subject to aging evaluation includes the reusable components of the packaging that perform a safety function.

The staff confirmed that the scope of the applicants aging evaluation includes all appropriate long-lived reusable packaging components. The materials for these components include the following:

i.

austenitic stainless steel welded plates and bolts, ii.

alloy steel nuts, iii.

aluminum alloy honeycomb, iv.

polymer foam, and

v.

ceramic fiber.

The staff confirmed that an evaluation of potential aging mechanisms for the rubber packings is not needed since they are already required to be inspected for aging effects that could degrade their performance and replaced as needed prior to transport as part of the package handling and maintenance criteria described in Section III of the application (DOT, 2025a). The staff found that the applicants identification of package components and materials that are subject to aging evaluation is acceptable since it ensures that materials for long-lived reusable package components are appropriately evaluated for potential aging mechanisms over the service life of the package.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 17 OFFICIAL USE ONLY - PROPRIETARY INFORMATION 3.2.7.2 Evaluation of Package Aging Mechanisms The application specified the total number of package transports during the 80-year period and identifies the environmental and loading conditions considered in the evaluation of potential aging mechanisms during the 80-year period. These environmental and loading conditions include:

i.

highest analyzed temperature (heat) for NCT; ii.

radiation emitted by the radioactive contents; iii.

chemical reactions in materials that may lead to corrosion of components; and iv.

fatigue of package structural components caused by cyclical stress in structural materials.

The applicant evaluated each of these conditions to determine aging mechanisms that could potentially lead to package component degradation during the 80-year period of use of the package. To review the applicants evaluation, the staff used the NUREG-2214, Managing Aging Processes in Storage (MAPS) Report (NRC, 2019).

3.2.7.3 Evaluation of Potential Aging Associated with Heat, Radiation, and Chemical Reactions The applicant noted that aging due to heat, radiation, and chemical reactions assuming an 80-year continuous use of a loaded package can be considered to be conservative and bounding of the actual use of the package. The staff determined that this assumption is conservative since packaging components are only exposed to radiation from the fuel contents during limited intervals for transport and handling of a loaded package, and as addressed below, packaging components are not adversely affected by ambient heat during transport or in storage. With respect to chemical reactions, the staff verified that direct exposure of packaging components to outdoor ambient conditions is limited per the package handling and maintenance criteria since empty packagings are generally required to be stored indoors when not in use. Therefore, the staff finds the applicants 80-year continuous use assumption to be acceptable for the evaluation of aging due to heat, radiation, and chemical effects.

With respect to potential aging of components due to heat, the staff confirmed that the aging evaluation considers the highest analyzed temperature of the package for NCT. The staff determined that this represents the most adverse condition with respect to heat-induced aging since the much higher temperatures associated with the accident condition thermal test are a one-time hypothetical event and are not representative of long-term service-induced aging. The staff confirmed that the highest analyzed temperature for NCT is not a concern since adverse effects of aging mechanisms caused by steady-state high temperatures in the subject materials can only occur at significantly higher temperatures than those evaluated. Therefore, the staff finds that the applicants evaluation of potential aging due to heat exposure, and its determination that there would be no adverse changes to the subject materials from exposure to heat over the 80-year period of use, is acceptable for the 5-year revalidation term for the Model No. NT-XII package.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 18 OFFICIAL USE ONLY - PROPRIETARY INFORMATION The staff reviewed the applicants evaluation of potential aging due to radiation and confirmed that adverse changes to mechanical properties such as neutron embrittlement and loss of fracture toughness are not a concern for any of these materials since the accumulated neutron fluence over 80 years, and thus the five-year revalidation term, is at least several orders of magnitude lower than the lowest neutron fluence threshold at which adverse changes to the material microstructure and mechanical properties may need to be considered in the evaluation of structural performance. Therefore, the staff finds that the applicants evaluation of potential radiation-induced aging, and its determination that there would be no adverse changes to the subject materials from exposure to radiation, is acceptable for the five-year revalidation term for the Model No. NT-XII package.

The staff reviewed the applicants corrosion evaluation for the stainless steel components and confirmed that stainless steel passivity adequately inhibits general corrosion in most outdoor ambient environments. However, stainless steel is susceptible to localized corrosion effects, including loss of material due to pitting and crevice corrosion, when exposed to aqueous outdoor air and water environments, such as marine and road spray environments associated with shipment by road and seagoing vessel. Such outdoor air and water environments often contain dissolved salts and other aggressive chemicals. During numerous package transport operations over an 80-year period, these conditions may gradually degrade the protective passive oxide film on stainless steel surfaces leading to the formation of pits and crevice corrosion. Further, stainless steel components under high tensile stress (such as weld residual stress) exposed to aqueous outdoor air environments are also susceptible to the formation of cracks due to chloride-induced stress corrosion cracking (SCC). The staff identified that adequate visual inspections performed by qualified personnel using qualified techniques are needed in order to detect and evaluate indications of localized corrosion and SCC of stainless steel components exposed to aqueous outdoor air environments so that personnel can reliably determine the need for corrective action, such as repair or replacement of components that show unacceptable indications. The details of the staffs evaluation of the adequacy of the package handling and maintenance criteria for managing localized corrosion and SCC of stainless steel structural components, including resolution of the staffs RAI on this issue, is addressed below.

For interior sheltered environments inside the packaging enclosures, the staff noted that localized corrosion and SCC of stainless steel surfaces are not a concern provided that the interior surfaces do not undergo sustained or frequent exposure to aqueous electrolytes resulting from inleakage of water mixed with halide-bearing chemical compounds present in the outdoor environment. Since the packaging receptacles include rubber packings to prevent intrusion of water with dissolved chemical species into the interior spaces, and package handling instructions include requirements for closure of the receptacles during storage and decontamination of surfaces of empty packaging, the staff determined that the interior surfaces and components of the packaging receptacles are unlikely to be susceptible to significant localized corrosion and SCC that could degrade the packaging safety functions over the five-year revalidation term. The staff also confirmed that the interior components, including the ceramic fiber insulation and aluminum honeycomb and polymer foam impact limiters, are not vulnerable to significant general or localized corrosion since the aluminum honeycomb forms a durable protective oxide surface layer in dry air, and the ceramic fiber and polymer foam are not susceptible to corrosive chemical reactions with dry air.

The staff confirmed that the coating on the alloy steel nuts will protect against corrosion, if it remains intact. If the coating on the nuts becomes damaged or deteriorates during routine use, the staff identified that visual inspections of the nuts would be needed to detect and evaluate

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 19 OFFICIAL USE ONLY - PROPRIETARY INFORMATION corrosion and determine the need for repair or replacement. Alloy steel nuts are also susceptible to galvanic corrosion, if the alloy steel is in direct contact with the stainless steel bolts and receptacles during package handling and transport. The details of the staffs evaluation of the adequacy of the package handling and maintenance criteria for managing corrosion of the alloy steel nuts, including resolution of the staffs RAI on this issue, are addressed below.

3.2.7.4 Evaluation of Structural Fatigue Due to Stress Cycles in Package Components The application included a structural analysis for demonstrating that the packaging components would not be susceptible to fatigue failure due to accumulated stress cycles in components. The details of the staffs evaluation of the applicants structural fatigue analyses are addressed in Section 2.0 of this SER. The staff confirmed that the applicant used acceptable material fatigue curves from credible sources for stainless steel and alloy steel structural components to demonstrate that the accumulated stress cycles are adequately bound by the applicable material fatigue curve. Considering the findings documented in Section 2.0 of this SER, the staff determined that the applicants fatigue analysis for the Model No. NT-XII package adequately demonstrated that structural components of the packaging would not be susceptible to fatigue failure during the five-year revalidation term for the package.

3.2.7.5 Criteria for Managing Effects of Aging Mechanisms on Package Components Chapter III of the application described handling procedures and maintenance criteria for the Model No. NT-XII package. Section III-A of the application described package handling procedures that cover loading operations, inspections before shipment, retrieval of the fuel assemblies from the packaging, and preparation of empty packaging. The applicants pre-shipment inspections include visual inspections to verify package component integrity.

Section III-B of the application provides maintenance criteria, including criteria for periodic visual inspection of the packaging components to be carried out at least once a year or at least once for every ten transport operations if the packaging is used more than 10 times a year. These criteria specify that if periodic inspection identifies that the packaging needs to be repaired, the repair shall be performed prior to the next transport, and a reinspection of the repaired part shall be performed to verify that the repair has been properly done.

To ensure that the effects of localized corrosion and SCC of stainless steel components and corrosion of alloy steel nuts are adequately managed, the staff issued RAI M-2 requesting that the applicant describe codes, standards, and/or other methods that are implemented to ensure that package maintenance activities will adequately manage these aging effects, such that package components are capable of performing their safety functions throughout the period of use. The staffs RAI included four criteria that should be addressed to ensure adequate aging management.

Criteria 1 and 4, Visual inspection requirements and acceptance criteria In its RAI M-2 (DOT 2025c), the applicant provided information to address each of the four criteria. In response to criteria 1 and 4, the applicant described its visual inspection requirements and acceptance criteria for ensuring the absence of significant indications of corrosion (including localized pitting and crevice corrosion) and SCC for stainless steel and alloy steel packaging components and welds exposed to outdoor air and water environments. The staff reviewed this information and verified that the applicant specified adequate visual inspection requirements and associated acceptance criteria for ensuring no unacceptable indications of general

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 20 OFFICIAL USE ONLY - PROPRIETARY INFORMATION corrosion, pitting, crevice corrosion, and SCC on the surfaces of stainless steel and alloy steel components exposed to the outdoor environment.

Criterion 2, Direct bare metal visual examination of packaging components In response to criterion 2, the applicant described its required conditions for performing direct bare metal visual examination of packaging components, including illumination criteria, requirements for visual access to component surfaces for direct visual inspection, surface cleanliness requirements, personnel qualification requirements (including visual acuity requirements), and associated consensus standards to ensure adequate control of visual inspection conditions and flaw detection capability. The applicant cited established consensus standards addressing visual examination methods and personnel qualification requirements that are published in the following technical standards documents:

i.

Japanese Industrial Standards (JIS),

ii.

International Organization for Standardization (ISO), and iii.

European Norm (EN).

The staff verified that the applicant specified adequate conditions for performing visual inspections, including specific requirements for illumination, direct visual examination distance and angle of sight, surface cleanliness, and personnel qualification and visual acuity requirements. The staff also verified that the applicant included references for suitable consensus standards to provide adequate control of visual inspection conditions and personnel qualifications to ensure that inspections can adequately detect and characterize indications of localized corrosion and SCC prior to component failure or loss of safety function.

Criterion 3, Established procedures for cleaning the outer surfaces of packages between transports In response to criterion 3, the applicant stated that it has established procedures for cleaning the outer surfaces of packages between transports and for ensuring that package surfaces are free from contamination prior to visual inspection. The staff reviewed these statements and determined that the applicant specified adequate requirements for cleaning the outer surfaces of package components to ensure that accumulated dirt and atmospheric deposits on the package surface is removed and will not obscure surface flaws. The staff also determined that removing such contamination from package surfaces effectively mitigates the corrosive chemical attack of package surfaces by preventing the formation of aqueous electrolytes containing dissolved halides due to mixture of salts and other compounds with water.

3.2.7.6 Conclusion on Evaluation of Aging In Accordance with Paragraph 613A of IAEA SSR-6, 2018 Edition (IAEA, 2018a)

Based on its review of the applicants evaluation of aging mechanisms for the Model No. NT-XII package and the applicants acceptable RAI responses addressing maintenance criteria for managing credible aging effects for package components, the staff determined that the NT-XII package application adequately describes how the design of the package takes into account

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 21 OFFICIAL USE ONLY - PROPRIETARY INFORMATION ageing mechanisms in accordance with Paragraph 613A of IAEA SSR-6 for the five-year revalidation term. Accordingly, the staff finds that the applicants evaluation of aging mechanisms for the Model No. NT-XII package and the package maintenance criteria are acceptable for meeting the requirements of Paragraph 613A of IAEA SSR-6 for the five-year revalidation term.

3.3 Content Integrity - Unirradiated Fuel Cladding Section I-D of the application states that the Model No. NT-XII package contains new zirconium alloy cladding for unirradiated fuel rod assemblies for boiler water reactors (BWRs). This section specifies the type of zirconium alloy cladding for the unirradiated fuel rods. The package structural analyses in Section II-A of the application include evaluations of the structural performance of the fuel cladding for normal and accident conditions of transport. The application includes fuel cladding integrity evaluations for the following conditions:

1)

Section II-A.5.3 evaluated the structural performance of the fuel cladding for the free drop test for NCT;

2)

Section II-A.9.2 evaluated the structural performance of the fuel cladding for the accident condition drop tests;

3)

Section II-A.9.2 evaluated the structural integrity of the fuel cladding for the accident condition thermal test.

The staff confirmed that the evaluations show that fuel cladding integrity is adequately maintained for these conditions based on actual test results showing no unacceptable damage to the fuel cladding and no release of nuclear fuel. Based on its review of the test results for the above three conditions, the staff determined that the mechanical properties of the fuel cladding are adequate for ensuring fuel rod integrity for normal and accident conditions of transport.

Based on its review of the application, the staff finds that the fuel cladding is capable of maintaining the fuel in its analyzed configuration during normal and accident conditions of transport, and the package meets the requirements in Paragraphs 673, 682, and 726 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

3.4 Evaluation Findings

Based on a review of the statements and representations contained in the application, the staff finds that the materials performance for the Model No. NT-XII package design meets the requirements of the Paragraph Nos. 607, 608, 609, 613, 616, 637, 638, 639, 614, 643, 645, 721, 722, 723, 724, 726, 727, and 728 of IAEA SSR-6, 2018 Edition.

4.0 THERMAL EVALUATION 4.1 Regulatory Requirements The purpose of the thermal evaluation is to verify that the package design meets the requirements of IAEA SSR-6, 2018 Edition (IAEA, 2018a), for this revalidation, specifically Paragraph No. 728. A summary of the staffs review is provided below.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 22 OFFICIAL USE ONLY - PROPRIETARY INFORMATION 4.2 Evaluation 4.2.1 Description of the Thermal Design and Design Criteria The Model No. NT-XII package is a passive thermal device having no mechanical cooling system or relief valves to aid in cooling the package. All cooling of the transport package is through free convection and radiation heat transfer.

Several thermal design criteria are established by the applicant for the Model No. NT-XII package to ensure that the package meets all its functional and safety requirements, per the IAEA SSR-6, 2018 Edition, (IAEA, 2018a) thermal requirements:

(1)

Thermal evaluation at an ambient temperature of 38°C (100°F) in still air, and insolation according to isolation data provided in SSR-6 (IAEA, 2018a).

(2)

Thermal evaluation at an ambient temperature of -40°C (-40°F) in still air and shade.

(3)

Exposure of the specimen fully engulfed, except for:

a simple support system, in a hydrocarbon fuel/air fire of sufficient extent, and in sufficiently quiescent ambient conditions, to provide an average emissivity coefficient of at least 0.9, with

i.

an average flame temperature of at least 800°C (1,475°F) for a period of 30 minutes, or ii.

any other thermal test that provides the equivalent total heat input to the package and which provides a time averaged environmental temperature of 800°C.

The applicant states that the contents are fresh fuel assemblies with a negligible decay heat.

4.2.2 Summary Tables of Temperatures and Pressures The summary tables of key package component temperatures for NCT were reviewed by the staff. The temperatures are consistently presented throughout the application for NCT. For HAC, the applicant presented the pre-fire, during-fire, and post-fire component temperatures. The staff verified that all components remain below their material property limits (specified in the application). The temperatures and design temperature limits for the package components under NCT and HAC were reviewed and found to be consistent throughout the application.

The packaging is not a sealed container. The applicants calculated pressures are used in the calculation of stresses for the fuel rods (as described in SAR Chapter II-A, Structural Analysis).

The structural analysis described in Chapter II-A demonstrated that the stresses are below the acceptance criteria. Therefore, the structural integrity of the fuel rods will be maintained.

The staff reviewed the temperature and pressure design limits and calculated temperatures and pressures for the package and found them to be acceptable and consistent in the SAR.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 23 OFFICIAL USE ONLY - PROPRIETARY INFORMATION 4.2.3 Material Properties The applicant provided material thermal properties such as thermal conductivity, density, specific heat, and emissivity for all modeled components of the package. The staff reviewed these thermal properties and found these properties acceptable and appropriate for the materials specified and for the conditions of the package required by the IAEA SSR-6, 2018 Edition, (IAEA, 2018a) during NCT and HAC.

4.2.4 Thermal Evaluation under Normal Conditions of Transport Based on thermal analysis provided in Section II-B.4.1 of the SAR, the staff determined that the thermal analysis of the Model No. NT-XII is adequate and acceptable.

In Section 3.2.1 of the SAR, the applicant describes the thermal approach and conditions to perform the analysis of Model No. NT-XII. All the predicted temperatures remained below the allowable limits specified in the SAR.

In Chapter II.A of the SAR, the applicant calculated the maximum internal pressure of the fuel rods and used this pressure to obtain the stresses for the fuel rods. The structural analysis described in Chapter II.A demonstrated that the stresses of the fuel rods will be maintained.

Therefore, the materials used for construction of the Model No. NT-XII package will continue to perform their intended safety function at an ambient temperature of -40°C.

The staff reviewed the applicants thermal evaluation of the Model No. NT-XII package during NCT. Based on the information provided in the application regarding NCT, the staff determines that the application meets the requirements of IAEA SSR-6, 2018 Edition, (IAEA, 2018a).

4.2.5 Thermal Evaluation under Hypothetical Accident Conditions The applicant performed a thermal test to evaluate the Model No. NT-XII package under the thermal conditions specified in Section 3.2.1. All measured temperatures remain below the allowable limits specified in the SAR. The applicant used the results from NCT including insolation to make the necessary adjustments for the fire test conditions. Based on the requirements in IAEA SSR-6, 2018 Edition, (IAEA, 2018a), a fire temperature of 1475°F, fire emissivity of 0.9 and a period of 30 minutes are considered for the fire test.

The applicant presented the pre-fire, during-fire, and post-fire component temperatures. The staff verified that all components remain below their material property limits (specified in the application). Thermal stresses for the Model No. NT-XII are calculated in Chapter II-A of the SAR.

The staff reviewed the applicants thermal evaluation of the Model No. NT-XII package during HAC. Based on the information provided in the application regarding HAC, the staff determines that the application meets the requirements of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

4.3 Evaluation Findings

Based on review of the statements and representations in the application, the staff finds that the thermal evaluation for the Model No. ANF-50 meets the requirements of Paragraph No. 728 of the IAEA SSR-6, 2018 Edition (IAEA, 2018a).

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 24 OFFICIAL USE ONLY - PROPRIETARY INFORMATION 5.0 CONTAINMENT EVALUATION 5.1 Regulatory Requirements The purpose of the containment evaluation is to verify that the package design meets the requirements of IAEA SSR-6, 2018 Edition, Paragraphs Nos. 641, 645, and 648 (IAEA, 2018a).

A summary of the staffs containment evaluation is provided below.

5.2 Evaluation Section 1.0 of this SER includes a description and the evaluation of the Model No. NT-XII package. Sections II-A.4.3 and I-C(6) of the SAR (DOT, 2025a) noted that the lid and flange for both the fuel receptacle and outer receptacle are bolted using JIS nuts and stainless steel

[OUO-Proprietary Information - Information withheld per 10 CFR 2.390] hex bolts. The fuel receptacle includes [OUO-Proprietary Information - Information withheld per 10 CFR 2.390]

tightening torque and the outer receptacle includes [OUO-Proprietary Information -

Information withheld per 10 CFR 2.390] tightening torque; this precludes unintentional opening or release of content during NCT. In addition, Section I-C(7) of the SAR noted that fabrication of the packaging uses TIG or carbon dioxide arc welding.

Chapter 2 of the SAR stated that the design of the package meets the applicable technical standards of Type AF packages defined in the following documents:

NRA Ordinance on off-Site Transportation of Nuclear Fuel Materials, etc. Issuance:

Order of the Prime Ministers Office No.57 of December 28, 1978 and Notification on Technical Details for Off-Site Transportation of Nuclear Fuel Materials, etc. Issuance: The Public Notice of the Science and Technology Agency No. 5, an extra of November 28, 1990.

SAR Table II-A-1 provided the design criteria for the structural analyses and SAR Section II-A.1.2 noted that the structural analytical results were checked to have a margin-of-safety of at least 1.

5.2.1 Description of Containment System Regarding Paragraph 641 of the IAEA SSR-6, 2018 Edition (IAEA, 2018a), Chapter 1 item (16)

(SAR pages 1-6) defined the containment boundary as fuel cladding tubes seal welded to Zircaloy-2 end plugs. As noted above, the fuel cladding tubes are also confined within the fuel receptacles that have numerous bolts that are torqued to specifications. Section I-D of the SAR provided details of the content and noted the fuel cladding tubes can be constructed of Zircaloy-2 tubes or Zircaloy-2 tubes with zirconium inner liner and surround the uranium dioxide and gadolinia-uranium dioxide fuel pellets. Figures I-3 and I-4 of the SAR included diagrams of the BWR fuel assembly and fuel rod, respectively.

As it relates to the containment system, the following sections offer some characteristics of the fuel cladding tubes:

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 25 OFFICIAL USE ONLY - PROPRIETARY INFORMATION (1)

Section I-D (3)-5 of the SAR - the cladding had a melting point of approximately 1,850°C.

(2)

Sections II-C.2.2 and II-B.4.4 of the SAR - the fuel rods were initially backfilled with helium to a pressure of [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] MPa.

(3)

Section I-D(3)-5 of the SAR - no chemical reactivity of the UO2 pellets and cladding tubes.

(4)

Section II-C.3.2 - no fission gas products.

(5)

Sections II-C.2.2 and II-C.2.3 of the SAR - leak tight and no penetrations.

Chapter I of the application (DOT, 2025a) includes additional information about the description of the Model No. NT-XII package.

5.2.2 Description of Content Section 1.2 of the SER includes a description of the contents of the package considered in the containment evaluation, which noted that the content has less than an A2 of activity.

5.2.3 Description of Containment System Performance The SAR described the performance of the containment system as determined from the responses to the normal and accident transport condition tests specified in the regulations.

Section II-B.4.2 of the SAR describes [OUO-Proprietary Information - Information withheld per 10 CFR 2.390]°C as the highest NCT package temperature, which is below the allowable temperature of the packages structural materials. However, the high NCT temperature was extended to 70°C in the response to RAI-St-2 (DOT, 2025c). In terms of lower operating temperatures, in Section II-A.4.2, Section II-B.4.3, and Table II-B-3 of the SAR, the applicant notes that the packages SUS 304 steel and aluminum alloy materials can be operated at -40°C.

In Section II-A.5.1.4 of the SAR, the applicant notes that NCT analyses of internal and external pressures and thermal stresses shows margins of safety greater than 1. Section II-A.9.1.1 through II-A.9.1.4 and Table II-A-22 indicates that the physical results from the normal condition water spray test, 1.2 m drop test, stacking test, and 6 kg rod penetration test showed that containment of the fuel rods was maintained, which meets the requirements of Paragraph 648 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

Regarding accident conditions, Section II-A.9.2.1.5 of the SAR indicated that a helium leak test of the fuel rods was conducted before and after physical drop I tests (i.e., different orientations of the 9-m drop tests) of the package, which confirmed there was no helium leakage and no issues with containment of the fuel rods. The results of drop test II (i.e., 1-m drop test on steel round bar) showed there was no penetration, and the bolts and flange did not break. In Sections II-A.9.2.5 and II-C.5 of the SAR, the applicant noted that a helium leak test of the fuel rods confirmed that containment was maintained after the series of tests conducted under normal and accident conditions. Finally, the table in SAR Section II-G noted that stresses generated in the fuel receptacle and cladding tubes are smaller than the criteria for generating cracks or

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 26 OFFICIAL USE ONLY - PROPRIETARY INFORMATION damage when the ambient pressure drops to 60 kilo Pascals (kPa), which meets the requirements of Paragraph 645 of IAEA SSR-6, 2018 Edition (IAEA, 2018a).

Section II-B.5 of the SAR includes a discussion of the thermal results after a test package underwent drop tests and was subsequently placed in an 800°C furnace for 30 minutes. Test results that accounted for an initial package maximum temperature of [OUO-Proprietary Information - Information withheld per 10 CFR 2.390]°C showed maximum temperatures of the outer receptacle, inner fuel receptacle, and fuel rods were approximately [OUO-Proprietary Information - Information withheld per 10 CFR 2.390]°C. In Section II-B.5.6 of the SAR, the applicant noted that these temperatures would not structurally affect the receptacles or the fuel rods. In addition, Table II-B-5 indicated that the leak tightness of the fuel rods would be maintained after the HAC tests.

Regarding fuel rod pressure, Section II-B-4.4 of the SAR calculated a maximum NCT cladding tube internal pressure of [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] MPa (based on the increase in pressure from a helium backfill temperature of 0°C and the calculated hot NCT temperature of [OUO-Proprietary Information - Information withheld per 10 CFR 2.390]°C (i.e., ideal gas law). These conditions were bounded by the fire HAC pressure and stress calculations discussed in Section II-B.5.4 of the SAR, which calculated a maximum internal pressure and cladding tube circumferential stress of [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] MPa, respectively. In Section II-B.5.6 of the SAR, the applicant points out that the circumferential stress was less than the fuel cladding tube proof stress of 60 MPa at the above-mentioned fire HAC [OUO-Proprietary Information - Information withheld per 10 CFR 2.390]°C cladding temperature (which was much less than the zirconium and Zircaloy-2 melting point of 1,850°C reported in Section I-D of the SAR).

5.3 Evaluation Findings

Based on a review of the statements and representations contained in the application, the staff finds that the containment design and evaluation for the Model No. NT-XII package design with the specified content of 9x9 BWR commercial uranium fresh fuel assemblies meets the requirements of the IAEA SSR-6, 2018 Edition, Paragraphs Nos. 641, 645, and 648(a) (IAEA, 2018a).

6.0 CRITICALITY SAFETY EVALUATION 6.1 Regulatory Requirements The purpose of the criticality safety evaluation is to verify that the package design meets the requirements of IAEA SSR-6, 2018 Edition, Paragraphs Nos. 673-686 (IAEA, 2018a). A summary of the staffs criticality safety evaluation is provided below.

6.2 Evaluation The applicant performed tests consistent with IAEA SSR-6, 2018 Edition, Paragraphs 726-728 (IAEA, 2018a) and documented maximum deformation in Section II-E.2.2 of the SAR. The staff finds that the applicant incorporated conservative changes to its criticality model to account for HAC deformation, as described in Section II-E.3.1 of the SAR. Dimensions of the packaging and fuel assemblies under HAC are shown in Figures II-E-1 and II-E-2 of the SAR.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 27 OFFICIAL USE ONLY - PROPRIETARY INFORMATION 6.2.1 Modeling The applicant performed the criticality analysis using the KENO-V.a module within the SCALE code suite. SCALE/KENO is a widely accepted and extensively validated tool for criticality safety applications, and the staff finds its use appropriate. To ensure accuracy, the applicant conducted a parametric benchmarking evaluation using [OUO-Proprietary Information -

Information withheld per 10 CFR 2.390] cases from the LEU-COMP-THERM category, which is representative of heterogeneous thermal LEU systems such as commercial LWR fuel. Fuel pellet diameter was selected as the correlation parameter because it strongly influences the hydrogen-to-fissile ratio (H/X), a key factor in eff calculations. The benchmarking results, presented in Figure II-E-5 and Table II-E-4 of the SAR, demonstrate that the applicants calculated eff value is less than 0.95, including three times the Monte Carlo calculation uncertainty. Based on this, the staff finds with reasonable assurance that the applicants methodology and results are technically sound.

6.2.2 Normal and Accident Conditions of Transport The applicant evaluated single packages and arrays under NCT and HAC (Section II-E.1 of the SAR). The limiting configuration was determined by the applicant to be an array of packages under HAC. The bounding model was developed by the applicant using this configuration, with conservative assumptions including the following:

(1) minimum plate thickness to increase inter-package interaction and reduce moderator displacement; (2) free movement of assemblies within the fuel receptacle to maximize reactivity; (3) conservative polyethylene behavior under HAC, assumed to melt and adhere uniformly along fuel rods and modeled as an additional cladding layer to place hydrogen-rich material closest to fissile material; (4) optimal water moderation density (Figure II-E-4 of the SAR); and (5) no reliance on fixed neutron absorbers with omission of burnable poisons integral to BWR fuel.

These assumptions conservatively increase calculated eff. The applicants analysis demonstrates that single packages and arrays of packages are adequately subcritical, per the requirements for fissile material packages in the IAEA SSR-6, 2018 Edition (IAEA, 2018a).

The applicant evaluated package arrays in accordance with SSR-6 requirements (IAEA, 2018a).

To satisfy Paragraph 684 for NCT, the analysis considered an array exceeding five times the transport limit of [OUO-Proprietary Information - Information withheld per 10 CFR 2.390]

packages (i.e., more than [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] packages). This was achieved using the bounding configuration modeled as [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] rows by [OUO-Proprietary Information - Information withheld per 10 CFR 2.390] tiers ([OUO-Proprietary Information - Information withheld per 10 CFR 2.390] packages) with an infinite number of longitudinal rows, as shown in Figure II-E-3 of the SAR, which also satisfies Paragraph 685 for HAC. From these evaluations, the applicant derived N = [OUO-Proprietary Information -

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 28 OFFICIAL USE ONLY - PROPRIETARY INFORMATION Information withheld per 10 CFR 2.390] for NCT and N = [OUO-Proprietary Information -

Information withheld per 10 CFR 2.390] for HAC. In accordance with Paragraph 686, the smaller value, N = [OUO-Proprietary Information - Information withheld per 10 CFR 2.390],

was used to calculate the Criticality Safety Index (CSI), resulting in CSI = 50 ÷ [OUO-Proprietary Information - Information withheld per 10 CFR 2.390], which is conservative.

6.3 Evaluation Findings

Based on a review of the statements and representations contained in the application, the staff finds that the criticality safety evaluation for the Model No. NT-XII package design meets the requirements of the IAEA SSR-6, 2018 Edition, Paragraphs Nos. 673-686.

7.0 PACKAGE OPERATIONS 7.1 Regulatory Requirements The purpose of the evaluation of the package operations is to verify that the package design meets the requirements of IAEA SSR-6, 2018 Edition, Paragraphs Nos. 501 - 588 (IAEA.

2018a). A summary of the staffs evaluation of the operating procedures for the Model No. NT-XII is provided below.

7.2 Evaluation The applicant discusses and evaluates the package operations in different sections of this SER.

The staff issued an RAI (i.e., RAI-OP-1) requesting the applicant to describe the actions required if any harmful scratches, cracks, and abnormalities are found during lifting inspections.

In its RAI response (DOT, 2025c), the applicant noted that it would add in the next update of the SAR a description of the possible actions taken if any abnormalities were to be found during lifting inspections to ensure that any lifting attachments on the package will not fail when used in the intended manner and that if failure of the attachments should occur, the ability of the package to meet other requirements of IAEA SSR-6 would not be impaired. The staff reviewed the applicants response to the RAI (DOT, 2025c) and determined that the measures described for addressing lifting inspections that fail to meet acceptance criteria are sufficient. Therefore, the staff concludes that the applicants response to RAI-OP-1 is acceptable.

Nevertheless, until the SAR for this package is revised, the staff recommends adding the following condition to the DOT U.S. certificate Model No. NT-XII:

A repair and re-inspection of the lifting attachment shall include a visual inspection to ensure that there are no abnormalities or harmful, scratches, cracks, etc., that may affect the safety function of the lifting attachment.

7.3 Evaluation Findings

Based on a review of the statements and representations contained in the application, the staff finds that the package operations for the Model No. NT-XII package design meets the requirements of the IAEA SSR-6 2018 Edition Paragraphs Nos. 501 - 588 (IAEA, 2018a).

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 29 OFFICIAL USE ONLY - PROPRIETARY INFORMATION 8.0 QUALITY ASSURANCE PROGRAM 8.1 Regulatory Requirements The purpose of the evaluation of the quality assurance (QA) description is to verify that the applicant meets the requirements of IAEA SSR-6, 2018 Edition, Paragraphs Nos. 301 - 315 (IAEA, 2018a). A summary of the staffs quality assurance program evaluation is provided below.

8.2 Evaluation The applicant developed and described a QA program for activities associated with transportation packaging components important to safety. Those activities include design, procurement, fabrication, assembly, testing, modification, maintenance, repair, and use. The applicants description of the QA program (i.e., management system and compliance assurance programs in IAEA SSR-6, 2018 Edition) meets the requirements of the applicable IAEA SSR-6, 2018 Edition. The staff finds, with reasonable assurance, that the description of the QA program for the Model No. NT-XII transportation packaging meets the requirements in IAEA SSR-6, 2018 Edition (IAEA, 2018a) by including the following elements:

1) design controls,

2) materials and services procurement controls,

3) records and document controls,

4) fabrication controls,

5) nonconformance and corrective actions controls,

6) an audit program, and

7) operations or programs controls, as appropriate.

These controls are adequate to ensure that the package will allow safe transport of the radioactive material authorized in this approval.

8.3 Evaluation Findings

Based on a review of the statements and representations contained in the application, the staff finds that the quality assurance description for the Model No. NT-XII package design meets the requirements of the IAEA SSR-6, 2018 Edition, Paragraphs Nos. 301 - 315.

9.0 REFERENCES

(IAEA, 2018a)

International Atomic Energy Agency No. SSR-6, Regulations for the Safe Transport of Radioactive Material, 2018 Edition.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 30 OFFICIAL USE ONLY - PROPRIETARY INFORMATION (IAEA, 2018b)

International Atomic Energy Agency No. SSG-26, Revision 1, Advisory Material for the IAEA Regulations for the Safe Transport of Radioactive Material, 2018 Edition.

(DOT, 2025a)

Richard W. Boyle, U.S. Department of Transportation (DOT), letter to Director, Division of Fuel Management, U.S. Nuclear Regulatory Commission (NRC), February 10, 2025, ML25148A393.

(DOT, 2025b)

Alex Cheng, U.S. Department of Transportation (DOT), Email to Ms.

Norma Garcia Santos, U.S. Nuclear Regulatory Commission (NRC),

September 10, 2025, ML25253A446.

(DOT, 2025c)

Alex Cheng, U.S. Department of Transportation (DOT), Email to Ms.

Norma Garcia Santos U.S. Nuclear Regulatory Commission (NRC),

November 14, 2025, ML26029A328.

(EDL, 2025)

Adrian Rony, Edlow International Company, Letter to Dr. Ryan Vierling, U.S. Department of Transportation (DOT), August 5, 2025, ML25234A196.

(NRC, 2019)

United States (U.S.) Nuclear Regulatory Commission (NRC). NUREG-2214, Managing Aging Processes in Storage (MAPS) Report, July 2019 (ML19214A111).

CONCLUSION Based on the statements and representations in the information provided by DOT and the applicant, the staff recommends the revalidation of Japans Certificate of Approval No.

J/2007/AF-96, Revision 1, Model No. NT-XII, (DOT, 2025a) as described in the section of this SER titled REVALIDATION RECOMMENDATION.