ML24046A217: Difference between revisions

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{{#Wiki_filter:Request for Additional Information Docket No. 71-                                                     3004 Model No. JMS         -87Y-18.5T Japanese Certificate of Competent Authority J/2044/B(U)F
{{#Wiki_filter:Request for Additional Information Docket No. 71-3004 Model No. JMS -87Y-18.5T Japanese Certificate of Competent Authority J/2044/B(U)F


The questions below describe information needed by the staff for it to complete its review of the application and to determine whether the applicant has demonstrated compliance with regulatory requirements.
The questions below describe information needed by the staff for it to complete its review of the application and to determine whether the applicant has demonstrated compliance with regulatory requirements.
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Structural Review
Structural Review


RAI St-1                                                                                                 Provide clarification on how stress concentration effects                     (higher stresses in the surrounding region of local geometric discontinuities of the component parts) have been accounted for in           the fatigue evaluations for the reusable                     package components. Justify                     omission of or consider stress concentration effects, where                       it is applicable.
RAI St-1 Provide clarification on how stress concentration effects (higher stresses in the surrounding region of local geometric discontinuities of the component parts) have been accounted for in the fatigue evaluations for the reusable package components. Justify omission of or consider stress concentration effects, where it is applicable.


The application evaluates fatigue for the lifting devices,                   containment device and tie-down attachments in sections (II)         -A.4.4.3.3, (II)-A.10.5, (II)-A.10.6.3(11) and (II)-A.10.6.4(3) of the safety analysis report (                               SAR). However, the staff could not locate any discussion on consideration of stress concentration fac                                                     tor to account for the effect of any           irregularities or discontinuities of the component                                                                                                                       parts or justification thereof for not considering in the components fatigue evaluations.
The application evaluates fatigue for the lifting devices, containment device and tie-down attachments in sections (II) -A.4.4.3.3, (II)-A.10.5, (II)-A.10.6.3(11) and (II)-A.10.6.4(3) of the safety analysis report ( SAR). However, the staff could not locate any discussion on consideration of stress concentration fac tor to account for the effect of any irregularities or discontinuities of the component parts or justification thereof for not considering in the components fatigue evaluations.
The stress concentration factor is typically used to account for the effect of discontinuities such as holes, grooves or notches, bolt threads and head fillets that are not represented in detail in the finite element analysis (FEA) model.
The stress concentration factor is typically used to account for the effect of discontinuities such as holes, grooves or notches, bolt threads and head fillets that are not represented in detail in the finite element analysis (FEA) model.


This information is requested to determine compliance with the requirements in paragraphs 613A and 809(f) of the IAEA SSR-6, 2018 Edition.
This information is requested to determine compliance with the requirements in paragraphs 613A and 809(f) of the IAEA SSR-6, 2018 Edition.


RAI St-2                                                                                                     Clarify values of the maximum repetitive stress                                           for the cask body lifting lugs considered in section (II)                                                   -A.4.4.3.3 of the SAR.
RAI St-2 Clarify values of the maximum repetitive stress for the cask body lifting lugs considered in section (II) -A.4.4.3.3 of the SAR.


Based on the stress intensity (s) calculation at the hole of the lifting lug in section (II)-A.4.4.3.1, the staff finds that the maximum repetitive stress should be N/mm2 instead of                                                                             N/mm           2 considered by the applicant in the evaluation of the cask body lifting lug
Based on the stress intensity (s) calculation at the hole of the lifting lug in section (II)-A.4.4.3.1, the staff finds that the maximum repetitive stress should be N/mm2 instead of N/mm 2 considered by the applicant in the evaluation of the cask body lifting lug


This information is requested to determine compliance with the requirements in paragraphs 613A and 809(f) of the IAEA SSR-6, 2018 Edition.
This information is requested to determine compliance with the requirements in paragraphs 613A and 809(f) of the IAEA SSR-6, 2018 Edition.


RAI St-3                                                                                                   Verify and confirm that the stress amplitudes                                                                 corresponding to the n                               umber of stress cycles from the                               design fatigue curves are properly adjusted for differences between                                                                   the moduli of elasticity on         the design fatigue curves and that           used in the analysis of the component                                                       parts to determine                                           allowable repeated peak stress intensity in section (II)-A.10.5 and possibly other sections of the SAR.
RAI St-3 Verify and confirm that the stress amplitudes corresponding to the n umber of stress cycles from the design fatigue curves are properly adjusted for differences between the moduli of elasticity on the design fatigue curves and that used in the analysis of the component parts to determine allowable repeated peak stress intensity in section (II)-A.10.5 and possibly other sections of the SAR.


Section (II)-A.10.5 of the SAR, evaluates                     containment devices                     for the combined repeated peak stress intensity. In this evaluation, the                             allowable repeated peak stress intensity is           determined by                     multiplying the stress amplitude corresponding to the number of stress cycles from the design fatigue curves by the ratio of modulus of elasticity on           the fatigue curves to the modulus of elasticity used in the analysis. Instead, it appears to the staff that                                                       the allowable                     peak stress intensity
Section (II)-A.10.5 of the SAR, evaluates containment devices for the combined repeated peak stress intensity. In this evaluation, the allowable repeated peak stress intensity is determined by multiplying the stress amplitude corresponding to the number of stress cycles from the design fatigue curves by the ratio of modulus of elasticity on the fatigue curves to the modulus of elasticity used in the analysis. Instead, it appears to the staff that the allowable peak stress intensity


Page 1 of 4 Request for Additional Information Docket No. 71-                                                     3004 Model No. JMS         -87Y-18.5T Japanese Certificate of Competent Authority J/2044/B(U)F
Page 1 of 4 Request for Additional Information Docket No. 71-3004 Model No. JMS -87Y-18.5T Japanese Certificate of Competent Authority J/2044/B(U)F


should be det                                                                                       ermined by multiplying the stress amplitude by the ratio of modulus of elasticity used in the analysis to the modulus                     of elasticity on                                                       the fatigue curves.
should be det ermined by multiplying the stress amplitude by the ratio of modulus of elasticity used in the analysis to the modulus of elasticity on the fatigue curves.


This information is needed to determine compliance with the requirements of the paragraphs 613A of the IAEA SSR-                           6, 2018 Edition.
This information is needed to determine compliance with the requirements of the paragraphs 613A of the IAEA SSR-6, 2018 Edition.


RAI St-4                                                                                                   Verify the values in the Repeated Peak Allowable Stress Intensity column of the Table                       (II)-A.31 and confirm if           they are values of the allowable stress intensity range or values of the alternating component, which is half                   of the allowable stress intensity range. Update this table                     as necessary, which needs to be worked in conjunction with resolution of other           RAIs as applicable.
RAI St-4 Verify the values in the Repeated Peak Allowable Stress Intensity column of the Table (II)-A.31 and confirm if they are values of the allowable stress intensity range or values of the alternating component, which is half of the allowable stress intensity range. Update this table as necessary, which needs to be worked in conjunction with resolution of other RAIs as applicable.


Section (II)-A.10.5 of the SAR, evaluates containment device and basket components for the combined repeated peak stress intensity.         Although conservative, it appears to the staff that the values in the Repeated Peak Allowable Stress Intensity column of the Table (II)-A.31 are values for the alternating component, which is half of the allowable stress intensity range                     from the applicable design fatigue curves. The                                                                               values                                             in this column are compared against the combined repeated peak stress intensity values per         the analysis and used to derive margin of safety in the design of the components.
Section (II)-A.10.5 of the SAR, evaluates containment device and basket components for the combined repeated peak stress intensity. Although conservative, it appears to the staff that the values in the Repeated Peak Allowable Stress Intensity column of the Table (II)-A.31 are values for the alternating component, which is half of the allowable stress intensity range from the applicable design fatigue curves. The values in this column are compared against the combined repeated peak stress intensity values per the analysis and used to derive margin of safety in the design of the components.


This information is needed to determine compliance with the requirements of the paragraphs 613A of the IAEA SSR-6, 2018 Edition.
This information is needed to determine compliance with the requirements of the paragraphs 613A of the IAEA SSR-6, 2018 Edition.


RAI St-5                                                                                                 Provide a complete evaluation of fatigue for the reusable package components for the 40-         year period of use that considers the combined effects of all applicable types of accumulated stress cycles in components during normal service conditions, including the following cycle types (as described in this question):
RAI St-5 Provide a complete evaluation of fatigue for the reusable package components for the 40- year period of use that considers the combined effects of all applicable types of accumulated stress cycles in components during normal service conditions, including the following cycle types (as described in this question):
: a.                                                                                     Lifting cycles
: a. Lifting cycles
: b.                                                                                     Pressurization cycles
: b. Pressurization cycles
: c.                                                                                       Thermal stress cycles
: c. Thermal stress cycles
: d.                                                                                     Vibration cycles
: d. Vibration cycles


The staff needs a complete fatigue evaluation that considers the combined effects of all applicable types of stress cycles during normal service, including consideration of the cycle types listed above.                                 Also, the appropriate number of cycles need to be considered in fatigue evaluation depending upon the type of cycle being evaluated. If certain types of stress cycles are         not applicable or negligible for certain components, explain why these are not applicable or are negligible.
The staff needs a complete fatigue evaluation that considers the combined effects of all applicable types of stress cycles during normal service, including consideration of the cycle types listed above. Also, the appropriate number of cycles need to be considered in fatigue evaluation depending upon the type of cycle being evaluated. If certain types of stress cycles are not applicable or negligible for certain components, explain why these are not applicable or are negligible.


If such a complete fatigue evaluation cannot be performed, or if the fatigue evaluation cannot show adequate protection against fatigue failure considering the combined effects of all applicable types of accumulated stress cycles in components, provide the following information:
If such a complete fatigue evaluation cannot be performed, or if the fatigue evaluation cannot show adequate protection against fatigue failure considering the combined effects of all applicable types of accumulated stress cycles in components, provide the following information:


a.1                                                                     a description about how periodic maintenance inspections will be used to identify and address fatigue cracks in components of the package.
a.1 a description about how periodic maintenance inspections will be used to identify and address fatigue cracks in components of the package.


Page 2 of 4 Request for Additional Information Docket No. 71-                                                     3004 Model No. JMS         -87Y-18.5T Japanese Certificate of Competent Authority J/2044/B(U)F
Page 2 of 4 Request for Additional Information Docket No. 71-3004 Model No. JMS -87Y-18.5T Japanese Certificate of Competent Authority J/2044/B(U)F


b.1                                                                     A description of the corrective actions that will be taken for any detected fatigue cracks, such as analytical flaw evaluation with follow-up inspections, repair/replacement of components with cracks, etc.
b.1 A description of the corrective actions that will be taken for any detected fatigue cracks, such as analytical flaw evaluation with follow-up inspections, repair/replacement of components with cracks, etc.


The following provide additional descriptions about accumulated stress cycles as provided in the application:
The following provide additional descriptions about accumulated stress cycles as provided in the application:
: 1.                                                                                     Lifting cycles -           The staff recognizes that these cycles are already evaluated in section (II)-A.4.4.3.3 for the cask body and lid                     lifting device, section (II)-A.10.6.4(3) for the skid lifting device and table         (II)-F.2 of the SAR. However, the staff noted that the lifting cycles are evaluated without considering the other types of stress cycles that may also be accumulated by the lifting devices for the cask body and the lid. To perform an adequate analytical evaluation that demonstrates sufficient safety margin against fatigue failure of these components, the combined effects of accumulated lifting cycles along with other applicable types of accumulated stress cycles in these components (including consideration of cycle types listed herein) on the potential for fatigue of lifting devices should be considered.
: 1. Lifting cycles - The staff recognizes that these cycles are already evaluated in section (II)-A.4.4.3.3 for the cask body and lid lifting device, section (II)-A.10.6.4(3) for the skid lifting device and table (II)-F.2 of the SAR. However, the staff noted that the lifting cycles are evaluated without considering the other types of stress cycles that may also be accumulated by the lifting devices for the cask body and the lid. To perform an adequate analytical evaluation that demonstrates sufficient safety margin against fatigue failure of these components, the combined effects of accumulated lifting cycles along with other applicable types of accumulated stress cycles in these components (including consideration of cycle types listed herein) on the potential for fatigue of lifting devices should be considered.
: 2.                                                                                     Pressurization and thermal stress cycles -                     The staff recognize           that pressure and thermal cycles are already evaluated in sections (II)         -A.10.5 and table II-F.2 for the containment device                     (i.e., cask body, lid and connecting bolts). However, the staff noted that the containment device pressurization & thermal cycles are evaluated for 1000 cycles over 30 years, which is contrary to the 40-                                                       year service life considered for           the components fatigue evaluations elsewhere. Also,           the staff noted that thermal stress cycles may occur in components due                                           to cyclical fluctuation of spatial temperature gradients within components, which could exceed 1000 cycles over 40-                                                     year service life. In addition, the staff noted that this evaluation does not address the potential for fatigue of package components due to the combined effects of other types of stress cycles that may also be accumulated by the containment device                   components. To perform an adequate analytical evaluation that demonstrates sufficient safety margin against fatigue failure of these components, the combined effects of accumulated pressurization & thermal                                                     cycles along with other applicable types of accumulated stress cycles in these components (including consideration of cycle types listed herein) on the potential for fatigue of containment device                     components should be considered.
: 2. Pressurization and thermal stress cycles - The staff recognize that pressure and thermal cycles are already evaluated in sections (II) -A.10.5 and table II-F.2 for the containment device (i.e., cask body, lid and connecting bolts). However, the staff noted that the containment device pressurization & thermal cycles are evaluated for 1000 cycles over 30 years, which is contrary to the 40- year service life considered for the components fatigue evaluations elsewhere. Also, the staff noted that thermal stress cycles may occur in components due to cyclical fluctuation of spatial temperature gradients within components, which could exceed 1000 cycles over 40- year service life. In addition, the staff noted that this evaluation does not address the potential for fatigue of package components due to the combined effects of other types of stress cycles that may also be accumulated by the containment device components. To perform an adequate analytical evaluation that demonstrates sufficient safety margin against fatigue failure of these components, the combined effects of accumulated pressurization & thermal cycles along with other applicable types of accumulated stress cycles in these components (including consideration of cycle types listed herein) on the potential for fatigue of containment device components should be considered.
: 3.                                                                                     Vibration cycles -           The staff noted that section (II)-A.4.7 provide an evaluation that demonstrates that package resonance is a not a concern considering package vibration caused by vehicle transport. The staff also recognizes that the tie-down attachments are already evaluated in section (II)-A.10.6.3(11) of the SAR for fatigue cycles.                                                                                     However, the staff noted that the tie         -down attachment components are evaluated for 4         000 cycles, which the applicant has inappropriately considered as lifting cycles, and not as vibratory cycles. The                                                                   package components could experience
: 3. Vibration cycles - The staff noted that section (II)-A.4.7 provide an evaluation that demonstrates that package resonance is a not a concern considering package vibration caused by vehicle transport. The staff also recognizes that the tie-down attachments are already evaluated in section (II)-A.10.6.3(11) of the SAR for fatigue cycles. However, the staff noted that the tie -down attachment components are evaluated for 4 000 cycles, which the applicant has inappropriately considered as lifting cycles, and not as vibratory cycles. The package components could experience


Page 3 of 4 Request for Additional Information Docket No. 71-                                                     3004 Model No. JMS         -87Y-18.5T Japanese Certificate of Competent Authority J/2044/B(U)F
Page 3 of 4 Request for Additional Information Docket No. 71-3004 Model No. JMS -87Y-18.5T Japanese Certificate of Competent Authority J/2044/B(U)F


many vibration cycles from numerous vehicle transports by road during the 40-year                                                               service life, which may exceed 4000 lifting cycles considered in the                                           fatigue evaluation.                                           In addition, the staff noted that this evaluation does not address the                                           potential for fatigue of package components due to the combined effects of the accumulation of many vibration cycles resulting from the allowed transports of the package                                           over 40-                                           year service life, along with the accumulation                                           of other applicable types of stress cycles, including consideration of the cycle types listed herein.
many vibration cycles from numerous vehicle transports by road during the 40-year service life, which may exceed 4000 lifting cycles considered in the fatigue evaluation. In addition, the staff noted that this evaluation does not address the potential for fatigue of package components due to the combined effects of the accumulation of many vibration cycles resulting from the allowed transports of the package over 40- year service life, along with the accumulation of other applicable types of stress cycles, including consideration of the cycle types listed herein.


To                                             determine that fatigue as not an aging concern, as indicated in section (       II)-F of the application, the staff needs a complete fatigue evaluation that considers the combined effects of all applicable types of stress cycles during normal service, including consideration of the cycle types listed above. Also, the appropriate number of cycles need to be considered in fatigue evaluation depending upon the type of cycle being evaluated.
To determine that fatigue as not an aging concern, as indicated in section ( II)-F of the application, the staff needs a complete fatigue evaluation that considers the combined effects of all applicable types of stress cycles during normal service, including consideration of the cycle types listed above. Also, the appropriate number of cycles need to be considered in fatigue evaluation depending upon the type of cycle being evaluated.


This information is requested to determine compliance with the requirements in paragraphs 503(e), 613, 613A, and 809(f) of the IAEA SSR-6, 2018 Edition.
This information is requested to determine compliance with the requirements in paragraphs 503(e), 613, 613A, and 809(f) of the IAEA SSR-6, 2018 Edition.


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Latest revision as of 15:07, 5 October 2024

Redacted, Attachment-Email Dated 5-30-23 from Ngarcia Santos (NRC) to Rboyle (DOT) Staggered Request for Additional Information for the Revalidation Recommendation of the Model No. JMS-87Y-18.5T, Structural Evaluation
ML24046A217
Person / Time
Site: 07103004
Issue date: 05/30/2023
From: Garcia-Santos N
Storage and Transportation Licensing Branch
To: Boyle R
US Dept of Transportation (DOT), Office of Hazardous Materials Safety
Shared Package
ML24046A215 List:
References
CAC 001794, EPID L-2023-DOT-0005
Download: ML24046A217 (4)


Text

Request for Additional Information Docket No. 71-3004 Model No. JMS -87Y-18.5T Japanese Certificate of Competent Authority J/2044/B(U)F

The questions below describe information needed by the staff for it to complete its review of the application and to determine whether the applicant has demonstrated compliance with regulatory requirements.

Structural Review

RAI St-1 Provide clarification on how stress concentration effects (higher stresses in the surrounding region of local geometric discontinuities of the component parts) have been accounted for in the fatigue evaluations for the reusable package components. Justify omission of or consider stress concentration effects, where it is applicable.

The application evaluates fatigue for the lifting devices, containment device and tie-down attachments in sections (II) -A.4.4.3.3, (II)-A.10.5, (II)-A.10.6.3(11) and (II)-A.10.6.4(3) of the safety analysis report ( SAR). However, the staff could not locate any discussion on consideration of stress concentration fac tor to account for the effect of any irregularities or discontinuities of the component parts or justification thereof for not considering in the components fatigue evaluations.

The stress concentration factor is typically used to account for the effect of discontinuities such as holes, grooves or notches, bolt threads and head fillets that are not represented in detail in the finite element analysis (FEA) model.

This information is requested to determine compliance with the requirements in paragraphs 613A and 809(f) of the IAEA SSR-6, 2018 Edition.

RAI St-2 Clarify values of the maximum repetitive stress for the cask body lifting lugs considered in section (II) -A.4.4.3.3 of the SAR.

Based on the stress intensity (s) calculation at the hole of the lifting lug in section (II)-A.4.4.3.1, the staff finds that the maximum repetitive stress should be N/mm2 instead of N/mm 2 considered by the applicant in the evaluation of the cask body lifting lug

This information is requested to determine compliance with the requirements in paragraphs 613A and 809(f) of the IAEA SSR-6, 2018 Edition.

RAI St-3 Verify and confirm that the stress amplitudes corresponding to the n umber of stress cycles from the design fatigue curves are properly adjusted for differences between the moduli of elasticity on the design fatigue curves and that used in the analysis of the component parts to determine allowable repeated peak stress intensity in section (II)-A.10.5 and possibly other sections of the SAR.

Section (II)-A.10.5 of the SAR, evaluates containment devices for the combined repeated peak stress intensity. In this evaluation, the allowable repeated peak stress intensity is determined by multiplying the stress amplitude corresponding to the number of stress cycles from the design fatigue curves by the ratio of modulus of elasticity on the fatigue curves to the modulus of elasticity used in the analysis. Instead, it appears to the staff that the allowable peak stress intensity

Page 1 of 4 Request for Additional Information Docket No. 71-3004 Model No. JMS -87Y-18.5T Japanese Certificate of Competent Authority J/2044/B(U)F

should be det ermined by multiplying the stress amplitude by the ratio of modulus of elasticity used in the analysis to the modulus of elasticity on the fatigue curves.

This information is needed to determine compliance with the requirements of the paragraphs 613A of the IAEA SSR-6, 2018 Edition.

RAI St-4 Verify the values in the Repeated Peak Allowable Stress Intensity column of the Table (II)-A.31 and confirm if they are values of the allowable stress intensity range or values of the alternating component, which is half of the allowable stress intensity range. Update this table as necessary, which needs to be worked in conjunction with resolution of other RAIs as applicable.

Section (II)-A.10.5 of the SAR, evaluates containment device and basket components for the combined repeated peak stress intensity. Although conservative, it appears to the staff that the values in the Repeated Peak Allowable Stress Intensity column of the Table (II)-A.31 are values for the alternating component, which is half of the allowable stress intensity range from the applicable design fatigue curves. The values in this column are compared against the combined repeated peak stress intensity values per the analysis and used to derive margin of safety in the design of the components.

This information is needed to determine compliance with the requirements of the paragraphs 613A of the IAEA SSR-6, 2018 Edition.

RAI St-5 Provide a complete evaluation of fatigue for the reusable package components for the 40- year period of use that considers the combined effects of all applicable types of accumulated stress cycles in components during normal service conditions, including the following cycle types (as described in this question):

a. Lifting cycles
b. Pressurization cycles
c. Thermal stress cycles
d. Vibration cycles

The staff needs a complete fatigue evaluation that considers the combined effects of all applicable types of stress cycles during normal service, including consideration of the cycle types listed above. Also, the appropriate number of cycles need to be considered in fatigue evaluation depending upon the type of cycle being evaluated. If certain types of stress cycles are not applicable or negligible for certain components, explain why these are not applicable or are negligible.

If such a complete fatigue evaluation cannot be performed, or if the fatigue evaluation cannot show adequate protection against fatigue failure considering the combined effects of all applicable types of accumulated stress cycles in components, provide the following information:

a.1 a description about how periodic maintenance inspections will be used to identify and address fatigue cracks in components of the package.

Page 2 of 4 Request for Additional Information Docket No. 71-3004 Model No. JMS -87Y-18.5T Japanese Certificate of Competent Authority J/2044/B(U)F

b.1 A description of the corrective actions that will be taken for any detected fatigue cracks, such as analytical flaw evaluation with follow-up inspections, repair/replacement of components with cracks, etc.

The following provide additional descriptions about accumulated stress cycles as provided in the application:

1. Lifting cycles - The staff recognizes that these cycles are already evaluated in section (II)-A.4.4.3.3 for the cask body and lid lifting device, section (II)-A.10.6.4(3) for the skid lifting device and table (II)-F.2 of the SAR. However, the staff noted that the lifting cycles are evaluated without considering the other types of stress cycles that may also be accumulated by the lifting devices for the cask body and the lid. To perform an adequate analytical evaluation that demonstrates sufficient safety margin against fatigue failure of these components, the combined effects of accumulated lifting cycles along with other applicable types of accumulated stress cycles in these components (including consideration of cycle types listed herein) on the potential for fatigue of lifting devices should be considered.
2. Pressurization and thermal stress cycles - The staff recognize that pressure and thermal cycles are already evaluated in sections (II) -A.10.5 and table II-F.2 for the containment device (i.e., cask body, lid and connecting bolts). However, the staff noted that the containment device pressurization & thermal cycles are evaluated for 1000 cycles over 30 years, which is contrary to the 40- year service life considered for the components fatigue evaluations elsewhere. Also, the staff noted that thermal stress cycles may occur in components due to cyclical fluctuation of spatial temperature gradients within components, which could exceed 1000 cycles over 40- year service life. In addition, the staff noted that this evaluation does not address the potential for fatigue of package components due to the combined effects of other types of stress cycles that may also be accumulated by the containment device components. To perform an adequate analytical evaluation that demonstrates sufficient safety margin against fatigue failure of these components, the combined effects of accumulated pressurization & thermal cycles along with other applicable types of accumulated stress cycles in these components (including consideration of cycle types listed herein) on the potential for fatigue of containment device components should be considered.
3. Vibration cycles - The staff noted that section (II)-A.4.7 provide an evaluation that demonstrates that package resonance is a not a concern considering package vibration caused by vehicle transport. The staff also recognizes that the tie-down attachments are already evaluated in section (II)-A.10.6.3(11) of the SAR for fatigue cycles. However, the staff noted that the tie -down attachment components are evaluated for 4 000 cycles, which the applicant has inappropriately considered as lifting cycles, and not as vibratory cycles. The package components could experience

Page 3 of 4 Request for Additional Information Docket No. 71-3004 Model No. JMS -87Y-18.5T Japanese Certificate of Competent Authority J/2044/B(U)F

many vibration cycles from numerous vehicle transports by road during the 40-year service life, which may exceed 4000 lifting cycles considered in the fatigue evaluation. In addition, the staff noted that this evaluation does not address the potential for fatigue of package components due to the combined effects of the accumulation of many vibration cycles resulting from the allowed transports of the package over 40- year service life, along with the accumulation of other applicable types of stress cycles, including consideration of the cycle types listed herein.

To determine that fatigue as not an aging concern, as indicated in section ( II)-F of the application, the staff needs a complete fatigue evaluation that considers the combined effects of all applicable types of stress cycles during normal service, including consideration of the cycle types listed above. Also, the appropriate number of cycles need to be considered in fatigue evaluation depending upon the type of cycle being evaluated.

This information is requested to determine compliance with the requirements in paragraphs 503(e), 613, 613A, and 809(f) of the IAEA SSR-6, 2018 Edition.

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