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=Text=
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{{#Wiki_filter:RSI-1}}
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 20, 2018 Mr. Richard W. Boyle, Chief Sciences Branch Division of Engineering and Research Office of Hazardous Materials Safety U.S. Department of Transportation 1200 New Jersey Ave., S.E.
Washington, D.C. 20590
 
==SUBJECT:==
APPLICATION FOR THE MODEL NO. MANON TRANSPORT PACKAGE -
SUPPLEMENTAL INFORMATION NEEDED
 
==Dear Mr. Boyle:==
 
By letter dated November 5, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18192B1310), the U.S. Department of Transportation requested that the U.S. Nuclear Regulatory Commission (NRC) staff perform a review of the French Certificate of Approval F/41 O/B(U)-96 Revision Ad, for the Model No. MANON transport package and make a recommendation concerning the revalidation of the package for import and export use. Specifically, you requested that the NRC only review the content in Appendix 3 to the French certificate. The NRC staff performed an acceptance review of your application to determine whether the application contains sufficient technical information in scope and depth to allow the NRC staff to complete a detailed technical review per the International Atomic Energy Agency Specific Safety Requirements No. 6, Regulations for the Safe Transport of Radioactive Material, 2012 Edition.
This letter is to advise you that based on our acceptance review, the application does not contain sufficient technical information. The information needed to begin our review is described in the enclosed request for supplemental information. In order to start our technical review, this information should be provided within 2 weeks from the date of this letter. Upon receiving your responses to this request for supplemental information, the NRC staff will evaluate the information to determine whether the supplementary information is responsive to the NRC staffs concerns.
The staff is available for a public meeting if you wish to discuss these issues in more detail prior to deciding on your course of action. Please reference Docket No. 71-3094 and EPID L-2018-NEW-0010 in future correspondence related to this action.
 
R. Boyle                                  If you have any questions regarding these matters, please contact me at (301) 415-6577.
Sincerely,
                                              /RA/
Bernard White, Senior Project Manager Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-3094 EPID L-2018-NEW-0010
 
==Enclosure:==
 
Request for Supplemental Information
 
R. Boyle                               
 
==SUBJECT:==
APPLICATION FOR THE MODEL NO. MANON TRANSPORT PACKAGE -
SUPPLEMENTAL INFORMATION NEEDED, DATE: December 20, 2018 DISTRIBUTION: DSFM r/f NMSS r/f G:\SFST\Bernie White\Casework\TN Americas\Manon\RSI Letter for Manon.docx ADAMS P8 Accession No.: ML18355A571 OFFICE:      DSFM            DSFM          DSFM            DSFM        DSFM WWheatley for VWilson          TTate NAME:        BWhite        SFigueroa                                  JMcKirgan via email      via email via email DATE:      12/17/18        12/18/18      12/17/18        12/19/18    12/20/18 OFFICIAL RECORD COPY
 
Request for Supplemental Information U.S. Department of Transportation French Approval Certificate Number F/41 O/B(U)-96 Revision Ad Docket No. 71-3094 Model No. MANON Package By letter dated November 5, 2018, the U.S. Department of Transportation (DOT) requested that the U.S. Nuclear Regulatory Commission (NRC) staff performs a review of the French Certificate of Approval F/41 O/B(U)-96 Revision Ad, for the Model No. MANON transport package and make a recommendation concerning the revalidation of the package for import and export use.
Specifically, DOT requested that the NRC only review the content in Appendix 3 to the French certificate.
This request for supplemental information (RSI) identifies information needed by the NRC staff in connection with its acceptance review of the Model No. MANON package application to confirm whether the applicant has submitted a complete application in compliance with regulatory requirements.
SHIELDING EVALUATION RSI-1 Provide the analysis demonstrating that the package shielding is sufficient to account for the bremsstrahlung source.
The applicant requested revalidation of the MANON package with contents for the Marguerite 20 generator containing 38 kCi of Sr-90. Sr-90 is a beta emitter, which decays to Y-90, which is also a beta emitter, before decaying to a stable nuclide. The beta radiation would be stopped within the MANON packaging. However, high energy betas, especially those emitted from Y-90 which has a maximum beta energy of 2.27 MeV, when interacting with high Z material, such as the lead in the Marguerite 20 generator, will generate bremsstrahlung photons. The applicant states in document U-8021-NT-01 Revision 1, page 9 that The source term is evaluated with ORTGEN [sic] 2.2 <1> and incorporates bremsstrahlung.
The staff does not have enough information on how the bremsstrahlung source was generated or how the package materials were credited to provide sufficient shielding for this source. The information in Section 5.3 in document U-8021-NT-01 Revision 1, page 11 credits enough material to attenuate the beta source, but this is not sufficient to appropriately shield the bremsstrahlung source.
The staff requests that the applicant provide the following:
: 1. The bremsstrahlung source (i.e. energy spectrum and photons/sec).
: 2. Additional information on how the applicant generated the bremsstrahlung source. It is not clear from the statement above if it uses ORIGEN to do this or if it is evaluated using some other method. If it does use ORIGEN, the staff requests that the applicant provide the input file.
: 3. Materials and thicknesses of the packaging components credited within the shielding evaluation.
: 4. Drawings and tolerances for the credited components, with sufficient detail to justify the amount credited.
Enclosure
 
The staff needs this information to verify whether the MANON package meets the International Atomic Agencys Specific Safety Requirements No. SSR-6, Regulations for the Safe Transport of Radioactive Material 2012 Edition, requirements relating to allowable maximum radiation levels in paragraphs 526, 527, 648(b), 659(b)(i).}}

Latest revision as of 08:45, 20 October 2019

Letter to R. Boyle Application for the Model No. Manon Transport Package - Supplemental Information Needed (W/ Enclosure)
ML18355A571
Person / Time
Site: 07103094
Issue date: 12/20/2018
From: Bernie White
Spent Fuel Licensing Branch
To: Boyle R
US Dept of Energy (DOE), US Dept of Transportation (DOT)
White B
References
EPID L-2018-NEW-0010
Download: ML18355A571 (5)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 20, 2018 Mr. Richard W. Boyle, Chief Sciences Branch Division of Engineering and Research Office of Hazardous Materials Safety U.S. Department of Transportation 1200 New Jersey Ave., S.E.

Washington, D.C. 20590

SUBJECT:

APPLICATION FOR THE MODEL NO. MANON TRANSPORT PACKAGE -

SUPPLEMENTAL INFORMATION NEEDED

Dear Mr. Boyle:

By letter dated November 5, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18192B1310), the U.S. Department of Transportation requested that the U.S. Nuclear Regulatory Commission (NRC) staff perform a review of the French Certificate of Approval F/41 O/B(U)-96 Revision Ad, for the Model No. MANON transport package and make a recommendation concerning the revalidation of the package for import and export use. Specifically, you requested that the NRC only review the content in Appendix 3 to the French certificate. The NRC staff performed an acceptance review of your application to determine whether the application contains sufficient technical information in scope and depth to allow the NRC staff to complete a detailed technical review per the International Atomic Energy Agency Specific Safety Requirements No. 6, Regulations for the Safe Transport of Radioactive Material, 2012 Edition.

This letter is to advise you that based on our acceptance review, the application does not contain sufficient technical information. The information needed to begin our review is described in the enclosed request for supplemental information. In order to start our technical review, this information should be provided within 2 weeks from the date of this letter. Upon receiving your responses to this request for supplemental information, the NRC staff will evaluate the information to determine whether the supplementary information is responsive to the NRC staffs concerns.

The staff is available for a public meeting if you wish to discuss these issues in more detail prior to deciding on your course of action. Please reference Docket No. 71-3094 and EPID L-2018-NEW-0010 in future correspondence related to this action.

R. Boyle If you have any questions regarding these matters, please contact me at (301) 415-6577.

Sincerely,

/RA/

Bernard White, Senior Project Manager Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-3094 EPID L-2018-NEW-0010

Enclosure:

Request for Supplemental Information

R. Boyle

SUBJECT:

APPLICATION FOR THE MODEL NO. MANON TRANSPORT PACKAGE -

SUPPLEMENTAL INFORMATION NEEDED, DATE: December 20, 2018 DISTRIBUTION: DSFM r/f NMSS r/f G:\SFST\Bernie White\Casework\TN Americas\Manon\RSI Letter for Manon.docx ADAMS P8 Accession No.: ML18355A571 OFFICE: DSFM DSFM DSFM DSFM DSFM WWheatley for VWilson TTate NAME: BWhite SFigueroa JMcKirgan via email via email via email DATE: 12/17/18 12/18/18 12/17/18 12/19/18 12/20/18 OFFICIAL RECORD COPY

Request for Supplemental Information U.S. Department of Transportation French Approval Certificate Number F/41 O/B(U)-96 Revision Ad Docket No. 71-3094 Model No. MANON Package By letter dated November 5, 2018, the U.S. Department of Transportation (DOT) requested that the U.S. Nuclear Regulatory Commission (NRC) staff performs a review of the French Certificate of Approval F/41 O/B(U)-96 Revision Ad, for the Model No. MANON transport package and make a recommendation concerning the revalidation of the package for import and export use.

Specifically, DOT requested that the NRC only review the content in Appendix 3 to the French certificate.

This request for supplemental information (RSI) identifies information needed by the NRC staff in connection with its acceptance review of the Model No. MANON package application to confirm whether the applicant has submitted a complete application in compliance with regulatory requirements.

SHIELDING EVALUATION RSI-1 Provide the analysis demonstrating that the package shielding is sufficient to account for the bremsstrahlung source.

The applicant requested revalidation of the MANON package with contents for the Marguerite 20 generator containing 38 kCi of Sr-90. Sr-90 is a beta emitter, which decays to Y-90, which is also a beta emitter, before decaying to a stable nuclide. The beta radiation would be stopped within the MANON packaging. However, high energy betas, especially those emitted from Y-90 which has a maximum beta energy of 2.27 MeV, when interacting with high Z material, such as the lead in the Marguerite 20 generator, will generate bremsstrahlung photons. The applicant states in document U-8021-NT-01 Revision 1, page 9 that The source term is evaluated with ORTGEN [sic] 2.2 <1> and incorporates bremsstrahlung.

The staff does not have enough information on how the bremsstrahlung source was generated or how the package materials were credited to provide sufficient shielding for this source. The information in Section 5.3 in document U-8021-NT-01 Revision 1, page 11 credits enough material to attenuate the beta source, but this is not sufficient to appropriately shield the bremsstrahlung source.

The staff requests that the applicant provide the following:

1. The bremsstrahlung source (i.e. energy spectrum and photons/sec).
2. Additional information on how the applicant generated the bremsstrahlung source. It is not clear from the statement above if it uses ORIGEN to do this or if it is evaluated using some other method. If it does use ORIGEN, the staff requests that the applicant provide the input file.
3. Materials and thicknesses of the packaging components credited within the shielding evaluation.
4. Drawings and tolerances for the credited components, with sufficient detail to justify the amount credited.

Enclosure

The staff needs this information to verify whether the MANON package meets the International Atomic Agencys Specific Safety Requirements No. SSR-6, Regulations for the Safe Transport of Radioactive Material 2012 Edition, requirements relating to allowable maximum radiation levels in paragraphs 526, 527, 648(b), 659(b)(i).