ML20112F377

Application for the Model No. FCC-4 Transport Package - Supplemental Information Needed (Docket No. 71-3097)

ML20112F377
Person / Time
Site:	07103097
Issue date:	04/21/2020
From:	Garcia-Santos N Storage and Transportation Licensing Branch
To:	Boyle R US Dept of Transportation, Office of Hazardous Materials Safety
Garcia N
References
EPID L-2020-NEW-0000
Download: ML20112F377 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 21, 2020 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. FCC-4 TRANSPORT PACKAGE -

SUPPLEMENTAL INFORMATION NEEDED

Dear Mr. Boyle:

By letter dated January 14, 2020 (Agencywide Documents Access and Management System Accession No. ML20022A001), the U.S. Department of Transportation requested that the U.S.

Nuclear Regulatory Commission (NRC) staff performs a review of the French Approval Certificate Number F/348/AF-96, Revision Fq, Model No. FCC-4 transport package, and make a recommendation concerning the revalidation of the package for import and export use. 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 continue our review is described in the enclosure to this letter as request for supplemental information and observations. The staff included observations to allow you to start earlier on items containing the potential to be asked at a later date. Responses to observations are not required for staff to begin a detailed technical review. Observations are not the result of a detailed technical review and may be resolved once the staff begins a detailed review.

In order to start our technical review and keep this high priority case on schedule, this information should be provided within 3 weeks from the date of this letter. If the NRC receives your response in a timely manner, you should expect to receive a request for additional information in July 2020.

R. Boyle If you wish to discuss these issues in more detail prior to submitting your response, the staff is available for a public meeting. Please reference Docket No. 71-3097 and EPID L-2020-NEW-0000 in future correspondence related to this action.

If you have any questions regarding these matters, please contact me at 301-415-6999 or ngs@nrc.gov.

Sincerely, Norma Garcia Digitally signed by Norma Garcia Santos Santos Date: 2020.04.21 14:34:22 -04'00' Norma Garcia Santos, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-3097 EPID L-2020-NEW-0000

Enclosure:

Request for Supplemental Information and Observations

ML20112F377 OFFICE: DFM DFM DFM DFM SFigueroa VWilsom RTorres NAME: NGarcía Santos with comments by with comments by by email email email DATE: 4/7/20 4/8/20 4/9/20 4/7/20 OFFICE: DFM DFM DFM DFM NAME: KArmstrong MRahimi JMcKirgan by email by email by email DATE: 4/14/20 4/18/20 4/20/20 Request for Supplemental Information and Observations U.S. Department of Transportation French Approval Certificate Number F/348/AF-96, Revision Fq Docket No. 71-3097 Model No. FCC-4 Package REQUEST FOR SUPPLEMENTAL INFORMATION Materials Evaluation RSI-Ma-1 Provide the English translation of all design-basis drawings, package-contents drawings, and any other packaging design information provided as part of the application. Ensure all drawings are legible and define pertinent welding requirements consistent with the application.

Drawings in Chapters 1.3 and 1.4 and Appendices 1.3, 1.4, and 2.1 of the application were provided in French. The drawings, as well as any other supporting design-basis information related to the application, should be translated to English and provided as part of the application to allow the staff to perform an adequate safety review. Further, drawings of the transport contents, as provided in Chapter 1.3 of the application, are not legible and are in French.

Ensure that all drawings identify the weld requirements for the packaging consistent with the design assumptions in the safety analysis.

This information is necessary to ensure compliance with the requirements in Paragraphs 607 and 640 of the IAEA SSR-6, Regulations for the Safe Transport of Radioactive Material, 2012 Edition.

RSI-Ma-2 Provide the following references cited in the application. Ensure all documents are translated into English.

a. From Appendix 1.3-1, DOS-13-00081778-031_01:

i. Standard NF EN 10088-3 ii. Standard NF EN 485-2

b. From Appendix 1.3-3, FFDC05098 EN:

i. Standard NF EN 10045-1 ii. Reference to method developed by the CEA and AREVA NP and presented to the ASTM Conference at Annecy in June 2001.

c. From Chapter 1.4, DOS-1300081778-040_02:

i. CODAP - 2005 - Section I, Appendix I1.A1 and I1.A2, including Tables I1.A1-1 and I1.A1.2 for Category A.

ii. NF A 35-557 - Metallurgical Products - Special Steels suitable for thermal processing for high-performance external thread fixing components used in mechanical constructions.

iii. NF EN 10113 Hot-rolled weldable products in fine-grain structural steel. Part 1: General conditions for delivery (Classification index: A 36-201).

Enclosure

iv. NF EN 10025 - Hot rolled products in non-alloy structural steels -

Technical requirements for delivery (Classification index:

A 35-501).

v. NF EN 10088 Stainless Steels - (Classification index:

A 35-574), Section 3: Technical Conditions relating to the delivery of part-finished products, bars, machined wires and profiles for general purpose use.

vi. NF EN 10028 Flat steel products for pressure vessels.

vii. NF A36-601 Forged steel components for boilers and pressure vessels. Carbon and carbon manganese steels.

viii. NF EN 10028 Flat steel products for pressure vessels.

Stainless steels.

d. From Appendix 1.4-3, FFDC01079EN:

i. Standard 35501 ii. Standard EN 10025 iii. NF EN 10045-1

e. From Appendix 2.2-3, DOS-13-00081778-203_01:

i. AREVA NP document FS1-0004231, Revision 1.0: Volume calculations for different fuel rod designs - Transport problem ii. AREVA NP internal document FD-16-00285, Revision 1.0:

Answers to questions by the ASN on EDGAR tests and the Zircaloy-4 model.

This information is necessary to ensure compliance with the requirements in Paragraphs 607 and 640 of the IAEA SSR-6, 2012 Edition.

OBSERVATIONS Criticality Safety Evaluation OBS-Cr-1 Provide the chemical composition of the chromium oxides as well as the concentration that will be present within uranium dioxide (UO2).

Certificate of the French Competent Authority No. F/348/AF-96 (Revision Fq) for the Model No. FCC-4 packaging states that, for all contents, the UO2 pellets may contain chromium oxides. The application does not include more specific information about the chemical composition of the chromium oxides including concentrations that will exist within the UO2.

This information is needed to ensure compliance with the requirements in Paragraph 673 of the IAEA SSR-6, 2012 Edition.

2

OBS-Cr-2 Justify that ignoring the inclusion of chromium oxide within the UO2 is conservative with respect to criticality safety.

The following criticality analysis files state that the chromium oxides are ignored in the criticality analysis:

• 107 SUNSI Encl 3 FCC 4 Ap 2.5-1 FFDC00817 EN (175 PUBLIC Encl 4 FCC 4 Ap 2.5-3 FFDC01106EN NPV) that represents Contents Nos. 1, 2, 3, and 11 for the FCC-4, and

• 109 SUNSI Encl 3 FCC 4 Ap 2.5-2 FFDC01046EN.pdf (173 PUBLIC Encl 4 FCC 4 Ap 2.5-2 FFDC01046EN NPV) that represents Contents Nos. 4, 5, 6, 7, 8, 9, 10, and 12 for the FCC-4.

These files state the following:

The addition into the pellets of capturing compounds (chromium oxide for instance) in quantities close to those of the impurities is ignored in the study of criticality as their presence reduces the reactivity of the assemblies.

The staff has seen studies to support criticality safety analyses for other packages involving UO2 fuel with chromium oxides that show that the reactivity effect of a specific quantity of chromium oxide may be statistically insignificant for a small number of rods. However, the staff requests justification that the proposed level of chromium oxide reduces reactivity if all rods contain chromium oxides.

This information is needed to ensure compliance with the requirements in Paragraph 673 of the IAEA SSR-6, 2012 Edition.

3