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| | number = ML22006A351 | | | number = ML22006A351 |
| | issue date = 12/27/2021 | | | issue date = 12/27/2021 |
| | title = Enclosure 4: Nwp'S (Applicant'S) Comments on the Summary of the Teleconference Dated December 1, 2021 Related to Shielding RAIs (Acceptance Tests), Model Nos. TRUPACT-II and Halfpact Packages | | | title = Enclosure 4: Nwps (Applicants) Comments on the Summary of the Teleconference Dated December 1, 2021 Related to Shielding RAIs (Acceptance Tests), Model Nos. TRUPACT-II and Halfpact Packages |
| | author name = Burns S | | | author name = Burns S |
| | author affiliation = Nuclear Waste Partnership, LLC | | | author affiliation = Nuclear Waste Partnership, LLC |
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| =Text= | | =Text= |
| {{#Wiki_filter:Attendees: | | {{#Wiki_filter:Attendees: |
| | |
| Nuclear Waste Partners LLC (NWP LLC or NWP): | | Nuclear Waste Partners LLC (NWP LLC or NWP): |
| Todd Sellmer, Manager, Packaging and Information Systems Scott Burns, Packaging Engineer, Project Manager Steve Porter, Primary Shielding Reviewer U.S. DOE (DOE): | | Todd Sellmer, Manager, Packaging and Information Systems Scott Burns, Packaging Engineer, Project Manager Steve Porter, Primary Shielding Reviewer |
| DaBrisha Smith, Package Certification Specialist U.S. Nuclear Regulatory Commission (NRC): | | |
| | U.S. DOE (DOE): |
| | DaBrisha Smith, Package Certification Specialist |
| | |
| | U.S. Nuclear Regulatory Commission (NRC): |
| Norma García Santos, Project Manager William Allen, Shielding Reviewer Omar Khan, Materials Reviewer John Wise, Senior Materials Reviewer Aaron Thomilson, Inspector (Quality Assurance, Operations, and Acceptance Tests) | | Norma García Santos, Project Manager William Allen, Shielding Reviewer Omar Khan, Materials Reviewer John Wise, Senior Materials Reviewer Aaron Thomilson, Inspector (Quality Assurance, Operations, and Acceptance Tests) |
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| ==SUBJECT:== | | ==SUBJECT:== |
| 12/1/21-Conference Call with Nuclear Waste Partners LLC and the U.S. | | 12/1/21-Conference Call with Nuclear Waste Partners LL C and the U.S. |
| Department of Energy-Discuss Follow up Questions Related to Shielding RAIs RAI-Sh-5 and -8, Model Nos. TRUPACT-II and HalfPACT (Docket Nos. 71-9218 and 71-9279; EPID L-2021-LLA-0033 and L-2021-LLA-0034, respectively) | | Department of Energy-Discuss Follow up Questions Related to Shi elding RAIs RAI-Sh-5 and -8, Model Nos. TRUPACT-II and HalfPACT (Docket Nos. 71-9218 and 71-9279; EPID L-2021-LLA-0033 and L-2021-LLA-0034, respecti vely) |
| On December 1st, 2021, NRC, NWP, and DOE/CBFO participated on a phone call to discuss the follow up questions to the responses to requests for additional information (RAI) related to the shielding evaluation for revisions of the certificates of compliance of Model Nos. TRUPACT-II and HalfPACT packages. The staff sent the following clarification questions: | | |
| : 1. Is the lead thickness in the packages drawings used as the standard to determine the reject rate for the minimum lead thicknesses? | | On December 1st, 2021, NRC, NWP, and DOE/CBFO participated on a phone call to discuss the follow up questions to the responses to requests for additi onal information (RAI) related to the shielding evaluation for revisions of the certificates of c ompliance of Model Nos. TRUPACT-II and HalfPACT packages. The staff sent the following clarifi cation questions: |
| Shielded Container Minimum Cavity Width Minimum Lead Thickness SC-30G1 0.94 in. 0.88 in. | | : 1. Is the lead thickness in the packages drawings used as the standard to determine the reject rate for the minimum lead thicknesses? |
| SC-30G2 1.40 in. 1.31 in. | | |
| SC-30G3 2.75 in. 2.57 in. | | Shielded Container Minimum Cavity Width Minimum Lead Thickness SC-30G1 0.94 in. 0.88 in. |
| SC-55G2 1.98 in. 1.86 in. | | SC-30G2 1.40 in. 1.31 in. |
| : 2. Is the standard used to determine the reject rate not stepped configured (i.e., the configuration seen in the figure below adjacent to the arrow and the D), but a simple lead plate sandwiched between two stainless steel plates (i.e., the configuration seen in the figure 7-23 farthest from the arrow and the D)? (this question is related to Figure 7-23, Regulatory Hypothetical Accident Condition Type B Testing for the HalfPACT Shielded Container Payloads. | | SC-30G3 2.75 in. 2.57 in. |
| : 3. The applicant noted the following: | | SC-55G2 1.98 in. 1.86 in. |
| the radioisotope (source) is placed at a distance equal to the source to survey instrument distance representative of the SCA to be gamma scanned. | | : 2. Is the standard used to determine the reject rate not steppe d configured (i.e., the configuration seen in the figure below adjacent to the arrow and the D), but a simple lead plate sandwiched between two stainless steel plates (i.e., the configuration seen in the figure 7-23 farthest from the arrow and the D)? (this q uestion is related to Figure 7-23, Regulatory Hypothetical A ccident Condition Type B Testing for the HalfPACT Shielded Container Payloads. |
| a) Is the source placed in the center of the shielded container cavity or next to the cavity wall? | | : 3. The applicant noted the following: |
| Enclosure 2 4 | | |
| | the radioisotope (source) is placed at a distance equal to the source to survey instrument distance representative of the SCA to be gamma scann ed. |
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| | a) Is the source placed in the center of the shielded container ca vity or next to the cavity wall? |
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| | Enclosure 2 4 a)b) If it is placed next to the cavity wall, does the source move i n tandem with the detector shown in Figure 6-47, Regulatory Hypothetical Acciden t Condition Type B Testing for the HalfPACT Shielded Container Payload? |
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| | The document enclosed to this summary includes the responses fr om the applicant to these questions. This document summarizes the discussions between th e staff and the applicant. |
| | |
| | In terms of question No. 3, the staff asked how the source is l ocated during the scan. The applicant explained that, during the scan of the lead shield, there is a test port and a detector at the center of the of the lid. The source and the detector move together up and down the internal wall of the shielded canister. During production of the packag e, the lid is modified and built to the same thickness as the one used during testing.a test lid wi th a hole in the center is used. |
| | The hole in the center of the lid allows for the source to be i nserted into the cavity of the shielded container while the detector is located outside of the cavity. The source and detector move together up and down the wall of the shielded container. During production of the shielded containers, the test lid for gamma scans will be built to the same thickness and general configuration as the production lids, but will have a center penetration to a llow for the source to be inserted into the cavity for gamma scan testing. |
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| a)b) If it is placed next to the cavity wall, does the source move in tandem with the detector shown in Figure 6-47, Regulatory Hypothetical Accident Condition Type B Testing for the HalfPACT Shielded Container Payload?
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| The document enclosed to this summary includes the responses from the applicant to these questions. This document summarizes the discussions between the staff and the applicant.
| |
| In terms of question No. 3, the staff asked how the source is located during the scan. The applicant explained that, during the scan of the lead shield, there is a test port and a detector at the center of the of the lid. The source and the detector move together up and down the internal wall of the shielded canister. During production of the package, the lid is modified and built to the same thickness as the one used during testing.a test lid with a hole in the center is used.
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| The hole in the center of the lid allows for the source to be inserted into the cavity of the shielded container while the detector is located outside of the cavity. The source and detector move together up and down the wall of the shielded container. During production of the shielded containers, the test lid for gamma scans will be built to the same thickness and general configuration as the production lids, but will have a center penetration to allow for the source to be inserted into the cavity for gamma scan testing.
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| The prototypes used a 1-inch top plate during gamma scan testing. The applicant notes that the this did not cause issues with the SC-30G2 canister. For the bigger canisters (SC-30G3 and SC-55G2), the applicant added a step tolead plates matching the inner cavity diameter to mimic the production lid. Also, during testing, yellow blankets and bags of lead shot are placed on top of the link lead serving as additional shielding during gamma scan testing. The applicant also measured the anulusannulus after the drop tests (see Table 7-2 of the report). | | The prototypes used a 1-inch top plate during gamma scan testing. The applicant notes that the this did not cause issues with the SC-30G2 canister. For the bigger canisters (SC-30G3 and SC-55G2), the applicant added a step tolead plates matching the inner cavity diameter to mimic the production lid. Also, during testing, yellow blankets and bags of lead shot are placed on top of the link lead serving as additional shielding during gamma scan testing. The applicant also measured the anulusannulus after the drop tests (see Table 7-2 of the report). |
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| In terms of question No. 2, the staff asked how far the gamma scans source is from the center of the shielded container is. The applicant noted the following: | | In terms of question No. 2, the staff asked how far the gamma scans source is from the center of the shielded container is. The applicant noted the following: |
| : 1. The source is located at the same distance as during production of the container. | | : 1. The source is located at the same distance as during product ion of the container. |
| : 2. The calibration standard used to calibrate the gamma scan mimics the cross -section of the shielded container, but using minimum material conditions (i.e., thicknesses). | | : 2. The calibration standard used to calibrate the gamma scan mimics the cross -section of the shielded container, but using minimum material conditions (i.e., thicknesses). |
| : 3. During the scan test, there was no lead on top of the shielded container. Norma, we are not sure what is intended by #3. Is this referring to the point discussed that there was no lead associated with the test lid used for the SC-30G2 containers? Or is this referring to the gap observed in the end of the lead annulus? If the intention for this item is the later, a separate clarification is included for reference (attached). | | : 3. During the scan test, there was no lead on top of the shield ed container. Norma, we are not sure what is intended by #3. Is this referring to the point discussed that there was no lead associated with the test lid used for the SC-30G2 containe rs? Or is this referring to the gap observed in the end of the lead annulus? If the intent ion for this item is the later, a separate clarification is included for reference (attached). |
| Figure 7-2334, provided in revision 1 of the reportHPT-REP-0001, shows a 0.318-inch gap with no lead on the cross section of the shielded container tested. In this case, the shielded containers passed the gamma scan test, but there was an abnormal reading and the applicant decided to disassemble it to investigate the cause of the abnormal reading. The applicant pointed out that they cut multiple cross sections of the shielded canister that had an abnormal reading. This gap was formed after drop testing (note the contour matching the steel) due to the presence of a pre-existing gap that formed due to a cold shut on the other end of the annulus during lead pour. The results of the gamma scan performed after drop testing raised concern at | | |
| | Figure 7-2334, provided in revision 1 of the reportHPT-REP-0001, shows a 0.318-inch gap with no lead on the cross section of the shielded container tested. In this case, the shielded containers passed the gamma scan test, but there was an abnorma l reading and the applicant decided to disassemble it to investigate the cause of the abnor mal reading. The applicant pointed out that they cut multiple cross sections of the shield ed canister that had an abnormal reading. This gap was formed after drop testing (note the cont our matching the steel) due to the presence of a pre-existing gap that formed due to a cold shut o n the other end of the annulus during lead pour. The results of the gamma scan performed afte r drop testing raised concern at the ends of the annulus. The sections chosen for the post-test destructive disassembly were based on the gamma scan result comparisons between the pre-drop testing and post-drop testing gamma scans (Figure 7.30). Multiple cross sections of the shielded containers were cut where the gamma scan result comparisons warranted investigation. |
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| | Figure 7-23, provided in revision 1 of HPT-REP-0001, actually s hows a cold shut with no lead on the cross-section of the shielded container tested. It is located such t hat the geometry of the base precludes a direct shine path resulting from the gap. |
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| | The gap shown in Figure 7-34 shows the location of the gap buried on the lidis located such that the geometry of the lid precludes a direct shine path resulting from the gap. Supplemental analyses showed a minimal increase in dose rate. The applicant noted that they added a section in the shielding chapter to address axial gaps. The st aff pointed out that the applicant should ensure that there are no gaps on the packages lead shie ld during construction, since the gamma scan may not detect those gaps. |
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| | The applicant explained that they performed an analysis of the lead shield assuming a 1/2-inch gap and the package should not exceed 200 mrem prior to shipmen t (see Section 7.1.4). The staff noted that he performed a hand calculation assuming a 1/2-i nch gap resulting on a dose increase. The applicant pointed out that the increase in dose rate is captured in the 10% margin on the radioactivity limit. The staff pointed out that the 10% margin was initially used to address source redistribution and source intensity. Therefore, the app licant needs to justify the applicability of crediting the use of the 10% margin for calcul ating the dose related to a gap in the lead shield. |
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| | The applicant mentioned that they are working on refining the p rocess of using the gamma scan. The applicant commented that refining the process should ensure that the lead shield meets the minimum measurements in the packages drawings during fabrication. |
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| | The table provided in question 1, includes the minimum cavity w idth and the minimum thickness of the lead shield and steel shells. The applicant pointed out the following: |
| | : 1. The gamma scan is set at a minimum cavity width. Norma, we are not sure what is intended by #1. After the reject rate is determined using the calibration standard described items in 2, 3, and 4 below, the source is inserted in to the cavity through the center hole in the test lid while the detector remains outside of the cavity. The source and detector move up and down over the length of the cavity whi le the distance (and elevation) between them are fixed. |
| | : 2. The calibration standard is made of steel-lead-steel. |
| | : 3. The calibration standard mimics the minimum width of the shielded container lead annulus and thickness of the steel shells. |
| | : 4. The minimum thickness of the lead shield is used as to determine the reject rate during the gamma scan process. |
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| the ends of the annulus. The sections chosen for the post-test destructive disassembly were based on the gamma scan result comparisons between the pre-drop testing and post-drop testing gamma scans (Figure 7.30). Multiple cross sections of the shielded containers were cut where the gamma scan result comparisons warranted investigation.
| | The staff will contact the applicant if there are any additiona l questions about the RAI responses.}} |
| Figure 7-23, provided in revision 1 of HPT-REP-0001, actually shows a cold shut with no lead on the cross- section of the shielded container tested. It is located such that the geometry of the base precludes a direct shine path resulting from the gap.
| |
| The gap shown in Figure 7-34 shows the location of the gap buried on the lidis located such that the geometry of the lid precludes a direct shine path resulting from the gap. Supplemental analyses showed a minimal increase in dose rate. The applicant noted that they added a section in the shielding chapter to address axial gaps. The staff pointed out that the applicant should ensure that there are no gaps on the packages lead shield during construction, since the gamma scan may not detect those gaps.
| |
| The applicant explained that they performed an analysis of the lead shield assuming a 1/2-inch gap and the package should not exceed 200 mrem prior to shipment (see Section 7.1.4). The staff noted that he performed a hand calculation assuming a 1/2-inch gap resulting on a dose increase. The applicant pointed out that the increase in dose rate is captured in the 10% margin on the radioactivity limit. The staff pointed out that the 10% margin was initially used to address source redistribution and source intensity. Therefore, the applicant needs to justify the applicability of crediting the use of the 10% margin for calculating the dose related to a gap in the lead shield.
| |
| The applicant mentioned that they are working on refining the process of using the gamma scan. The applicant commented that refining the process should ensure that the lead shield meets the minimum measurements in the packages drawings during fabrication.
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| The table provided in question 1, includes the minimum cavity width and the minimum thickness of the lead shield and steel shells. The applicant pointed out the following:
| |
| : 1. The gamma scan is set at a minimum cavity width. Norma, we are not sure what is intended by #1. After the reject rate is determined using the calibration standard described items in 2, 3, and 4 below, the source is inserted into the cavity through the center hole in the test lid while the detector remains outside of the cavity. The source and detector move up and down over the length of the cavity while the distance (and elevation) between them are fixed.
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| : 2. The calibration standard is made of steel-lead-steel.
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| : 3. The calibration standard mimics the minimum width of the shielded container lead annulus and thickness of the steel shells.
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| : 4. The minimum thickness of the lead shield is used as to determine the reject rate during the gamma scan process.
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| The staff will contact the applicant if there are any additional questions about the RAI responses.}} | |
Letter Sequence Meeting |
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MONTHYEARML21054A0512021-02-23023 February 2021 5 of the TRUPACT-II Shipping Package Application, Docket No. 71-9218, and Revision 8 of the Halfpact Shipping Package Application, Docket No. 71-9279 Project stage: Other ML22123A1622021-02-28028 February 2021 Redacted-Revision 25 of the Safety Analysis Report for the Model No TRUPACT-II, February 2021 Project stage: Other ML21054A0542021-02-28028 February 2021 CH-TRAMPAC R6 - February 2021 Project stage: Request ML21138A8522021-05-18018 May 2021 5/5/21, 1:00PM (Est), Summary for Conference Call to Discuss Identfied Request for Supplemental Information, Model Nos. TRUPACT-II, Rev. 26, and Halfpact, Rev. 10 Project stage: Other ML21125A1442021-05-20020 May 2021 Enclosure (Observations) - Application for the Model Nos. Trupact-II and Halfpact Transport Packages - Accepted for Review (EPIDs L-2021-LLA-0033 and L-2021-LLA-0034) Project stage: Other ML21125A1432021-05-20020 May 2021 Transmittal Letter - Application for the Model Nos. Trupact-II and Halfpact Transport Packages - Accepted for Review (EPIDs L-2021-LLA-0033 and L-2021-LLA-0034) Project stage: Other ML21214A1452021-08-11011 August 2021 Transmittal Letter Request for Additional Information, Model Nos Trupact II and Halfpact Transport Packages Project stage: RAI ML21214A1462021-08-11011 August 2021 2. Enclosurequest for Additional Information Model Nos. TRUPACT-II and Halfpact (EPIDs L-2021-LLA-0033 and L-2021-LLA-0034) Project stage: RAI ML21279A1902021-09-28028 September 2021 HPT-REP-0001,Regulatory Hypothetical Accident Condition Type B Testing for the Halfpact Shielded Container Payloads, Rev. 1, September 2021 Project stage: Other ML21279A1812021-10-0606 October 2021 Transmittal Letter: Response to Request for Additional Information for Revision 25 of the TRUPACT-II Shipping Package Application, Docket No.71-9218,and Revision 8 of the Halfpact Shipping Package Application, Docket No.71-9279 Project stage: Response to RAI ML21279A1872021-10-0606 October 2021 CH-TRU Payload Appendices, Revision 5, October 2021 Project stage: Other ML21279A1842021-10-0606 October 2021 CH-TRAMPAC, Revision 6, October 2021 Project stage: Other ML22123A2422021-10-0606 October 2021 Redacted-Revision 8 of the Safety Analysis Report for the Model No. Halfpact Package (Certificate of Compliance No. 9279, Revision 10) - October 2021 Project stage: Other ML22123A2072021-10-0606 October 2021 Redacted-Revision 25 of the Safety Analysis Report for the Model No. TRUPACT-II, October 2021 Project stage: Other ML22123A1632021-11-18018 November 2021 Redacted-Revision 25 of the Safety Analysis Report for the Model No. TRUPACT-II, November 2021 Project stage: Other ML21322A1212021-11-18018 November 2021 Nuclear Waste Partnership, Revision 25 of the TRUPACT-II Shipping Package Application, Docket No. 71-9218, and Revision 8 of the Halfpact Shipping Package Application, Docket No. 71-9279 (Epids L-2021-LLA-0033 and L-2021-LLA-0034) Project stage: Other ML22006A3542021-11-29029 November 2021 Enclosure 1: Transmittal Email Dated 11/29/21, Follow Up Questions and Responses Related to Acceptance Tests (Shielded Canisters), Model Nos. TRUPACT-II and Halfpact Packages Project stage: Other ML22006A3502021-11-29029 November 2021, 27 December 2021, 6 January 2022, 8 February 2022, 14 March 2022 12/1/21-Conference Call with Nuclear Waste Partners LLC and the U.S. Department of Energy-Discuss Follow Up Questions Related to Shielding RAIs RAI-Sh-5 and -8, Model Nos. TRUPACT-II and Halfpact (Docket Nos. 71-9218 and 71-9279; EPID L-202 Project stage: Request ML21322A1272021-11-30030 November 2021 Nuclear Waste Partnership, CH-TRU Payload Appendices, Revision 5, November 2021 Project stage: Other ML21322A1242021-11-30030 November 2021 Nuclear Waste Partnership, CH-TRAMPAC, Revision 6, November 2021 Project stage: Other ML22123A2442021-11-30030 November 2021 Redacted - Revision 8 of the Safety Analysis Report for the Model No. Halfpact Package (Certificate of Compliance No. 9279, Revision 10) - November 2021 Project stage: Other ML22103A0682021-12-0909 December 2021 NRC Staff Follow Up Questions Related to the Shielding Evaluation for Revision 10 of the Certificate of Compliance for the Model No. Halfpact Package Project stage: Other ML22103A0642021-12-0909 December 2021, 28 January 2022 Email from S. Burns to N. Garcia Dated January 28, 2021 Responses to RAI Follow Up Questions Related to the Shielding Evaluation for Revision 10 of the Certificate of Compliance for the Model No. Halfpact Package Project stage: Request ML22006A3562021-12-27027 December 2021 Enclosure 5: Clarification Regarding Testing Performed During the Shielded Container Prototype Testing (Drop Tests, Gamma Scans, Destructive Disassembly), Model Nos. TRUPACT-II and Halfpact Packages Project stage: Other ML22006A3532021-12-27027 December 2021 Enclosure 2: Attachment to Email Dated 11-29-21, Responses to Follow Up Questions, Acceptance Tests for the Lead Ssield of the Shielded Canisters (Model Nos. TRUPACT-II and Halfpact Packages Project stage: Other ML22006A3522021-12-27027 December 2021 Enclosure 3: Email Dated 12/27/21 from S. Burns (Nwp) to N. Garcia Santos (Nrc), Comments on Telephone Call Summary Dated 12/1/21, Model Nos. TRUPACT-II and Halfpact Packages Project stage: Other ML22006A3512021-12-27027 December 2021 Enclosure 4: Nwps (Applicants) Comments on the Summary of the Teleconference Dated December 1, 2021 Related to Shielding RAIs (Acceptance Tests), Model Nos. TRUPACT-II and Halfpact Packages Project stage: Meeting ML22006A3552022-01-0606 January 2022 12/1/21-Conference Call Summary: Follow Up Questions Related to Shielding RAIs RAI-Sh-5 and -8 (Acceptance Tests, Shielded Canisters), Model Nos. TRUPACT-II and Halfpact Packages Project stage: RAI ML22103A0692022-01-28028 January 2022 Email from S. Burns to N. Garcia Dated January 28, 2021 Responses to RAI Follow Up Questions Related to the Shielding Evaluation for Revision 10 of the Certificate of Compliance for the Model No. Halfpact Package Project stage: Response to RAI ML22103A0702022-01-28028 January 2022 Attachment--Email from S. Burns to N. Garcia Dated January 28, 2021 Responses to RAI Follow Up Questions Related to the Shielding Evaluation for Revision 10 of the Certificate of Compliance for the Model No. Halfpact Package Project stage: Response to RAI ML22091A1622022-02-0808 February 2022 Email Dated 2/8/2022 from S. Burns (Nwp) to N. Garcia Santos (Nrc), Estimated Date to Submit Letter with Responses to the Follow Up Questions Discussed on December 1st, 2021 Telephone Call (Model Nos. TRUPACT-II and Halfpact Packages) Project stage: Other ML22055A6292022-02-24024 February 2022 Transmittal Letter: TRUPACT-II Package Application, Revision 25, Docket No. 71-9218, and Halfpact Package Application, Revision 8, Docket No. 71-9279 (Epids L-2021-LLA-0033 and L-2021-LLA-0034) Project stage: Other ML22055A6332022-02-28028 February 2022 Nuclear Waste Partnership, LLC, CH-TRU Payload Appendices, Revision 5 Project stage: Request ML22055A6322022-02-28028 February 2022 Nuclear Waste Partnership, LLC, CH-TRAMPAC, Revision 6 Project stage: Request ML22091A1632022-03-14014 March 2022 Email Dated 3/14/2022, from S. Burns (Nwp) to N. Garcia Santos, Response to NRC Staffs Follow Up Question on Supplemental RAI Responses Dated 2/24/22 Shielded Container Lid and Bases Lead (Model Nos. TRUPACT-II and Halfpact) Project stage: Supplement ML22118B0152022-04-14014 April 2022 Attachment 4 to Email Dated 4/14/22 from Sburns (Nwp) to Ngarcia Santos (NRC) Courtesy Review - Summary Combined Comments from Nwp on Draft Certificate of Compliance No. 9279, Revision 10 Project stage: Draft Other ML22118B0142022-04-14014 April 2022 Attachment 3 to Email Dated 4/14/22 from Sburns (Nwp) to Ngarcia Santos (NRC) Courtesy Review - Comments from Nwp on Draft Certificate of Compliance No. 9218, Revision 26 Project stage: Draft Other ML22118B0132022-04-14014 April 2022 Attachment 2 to Email Dated 4/14/22 from Sburns (Nwp) to Ngarcia Santos (NRC) Courtesy Review - Summary of Combined Comments from Nwp on Draft Certificate of Compliance No. 9279, Revision 10 Project stage: Draft Other ML22118B0122022-04-14014 April 2022 Attachment 1 to Email Dated 4/14/22 from Sburns (Nwp) to Ngarcia Santos (NRC) Courtesy Review - Combined Comments from Nwp on Draft Certificate of Compliance No. 9279, Revision 10 Project stage: Draft Other ML22118A8562022-04-14014 April 2022 Email Dated 04/14/2022 from S. Burns (Nwp) to N. Garcia Santos (NRC) Subject--Renewal and Courtesy Review Certificate of Compliance Nos. 9279 and 9218 Project stage: Other ML22118A8552022-04-14014 April 2022 Email Dated 04/14/2022 from Sburns (Nwp) to Ngarcia Santos, Subject--Courtesy Review of Certificate of Compliance Nos. 9279 and 9218 Project stage: Other ML22104A2662022-04-28028 April 2022 Enclosure 1 - Revision No. 26 of Certificate of Compliance No. 9218 for the Model No. TRUPACT-II Transport Packages Project stage: Other ML22104A2652022-04-28028 April 2022 Enclosure 2 - Revision No. 10 of Certificate of Compliance No. 9279 for the Model No. Halfpact Trasport Packages Project stage: Other ML22104A2672022-04-28028 April 2022 Enclosure 3 - Safety Evaluation Report, Certificate of Compliance No. 9218, Rev. 26, Model No. TRUPACT-II and Certificate of Compliance No. 9279, Rev. 10, Model No. Halfpact Transport Packages Project stage: Approval ML22118B1442022-04-28028 April 2022 Transmittal: Letter Certificate of Compliance No. 9218, Rev. 26, Model No. TRUPACT-II and Certificate of Compliance No. 9279, Rev. 10, Model No. Halfpact Transport Packages Project stage: Other ML24067A1282024-02-27027 February 2024 Initial Submittal of the Safety Analysis Report for Docket No. 71-9384 Project stage: Request ML24089A2562024-04-0101 April 2024 NRC Approval of Robatel Technologies, LLC Request for Withholding Information from Public Disclosure for the Initial Submittal of the Safety Analysis Report for Docket No. 71-9384 - Enterprise Project Identification Number L-2024-NEW-0003 Project stage: Withholding Request Acceptance ML24145A1342024-06-0505 June 2024 Cover Letter Application for Certificate of Compliance for the Model RT-200 Type B(U) Cask - Accepted for Review Project stage: Other ML24145A1362024-06-0505 June 2024 Enclosure 2 Observations Robatel RT-200 Type B(U) Cask - NON-PROPRIETARY Project stage: Other ML24222A7182024-08-30030 August 2024 Cover Letter - Requests for Additional Information Robatel RT-200 Type B(U) Cask, Docket No. 71-9384 Project stage: RAI 2021-09-28
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Category:E-Mail
MONTHYEARL-2023-003, Email Dated May 8, 2023, from T. E. Sellmer (Simco) to N. Garcia Santos (NRC) and D. Smith (Doe), Subject: Halfpact Letter Authorization (Change in Need Date)2023-05-0808 May 2023 Email Dated May 8, 2023, from T. E. Sellmer (Simco) to N. Garcia Santos (NRC) and D. Smith (Doe), Subject: Halfpact Letter Authorization (Change in Need Date) ML23089A2582023-03-29029 March 2023 Email Attachment, Staggered Request for Additional Information (Structural Evaluation and Operating Procedures), Model No. Halfpact - One-time Letter Authorization ML23089A2572023-03-29029 March 2023 Email from Ngarcia Santos (NRC) to T.E. Sellmer (Simco), Subject: Structural and Operations - Staggered RAIs Pertaining to the Halfpact Letter Authorization ML22320A1032022-11-15015 November 2022 Email from S. Burns (Nwp) to N. Garcia Santos (Nrc), Subject-IMPORTANT, Courtesy Review, Revised Draft CoCs for the TRUPACT-II and Halfpact Packages ML22320A1042022-11-14014 November 2022 Nuclear Waste Partnership, LLC (Applicant), T Sellmer Comments on Draft Certificate of Compliance No. 9279, Revision 11 ML22278A0012022-10-0404 October 2022 Email from T. Sellmer (Nwp) to N. Garcia Santos (NRC) Et Al., Delay of RAI Response-CoC, Revision 27, Model No. TRUPACT-II and CoC, Revision 11, Model No. Halfpact CoCs ML22278A0072022-09-0808 September 2022 Email from T.E. Sellmer (Nwp) to N. Garcia Santos (NRC) Acknowledgement of Application for CoC, Revision 27, Model No. TRUPACT-II and CoC, Revision 11, Model No. Halfpact Packages ML22118A8562022-04-14014 April 2022 Email Dated 04/14/2022 from S. Burns (Nwp) to N. Garcia Santos (NRC) Subject--Renewal and Courtesy Review Certificate of Compliance Nos. 9279 and 9218 ML22118A8552022-04-14014 April 2022 Email Dated 04/14/2022 from Sburns (Nwp) to Ngarcia Santos, Subject--Courtesy Review of Certificate of Compliance Nos. 9279 and 9218 ML22091A1632022-03-14014 March 2022 Email Dated 3/14/2022, from S. Burns (Nwp) to N. Garcia Santos, Response to NRC Staffs Follow Up Question on Supplemental RAI Responses Dated 2/24/22 Shielded Container Lid and Bases Lead (Model Nos. TRUPACT-II and Halfpact) ML22091A1622022-02-0808 February 2022 Email Dated 2/8/2022 from S. Burns (Nwp) to N. Garcia Santos (Nrc), Estimated Date to Submit Letter with Responses to the Follow Up Questions Discussed on December 1st, 2021 Telephone Call (Model Nos. TRUPACT-II and Halfpact Packages) ML22103A0692022-01-28028 January 2022 Email from S. Burns to N. Garcia Dated January 28, 2021 Responses to RAI Follow Up Questions Related to the Shielding Evaluation for Revision 10 of the Certificate of Compliance for the Model No. Halfpact Package ML22006A3532021-12-27027 December 2021 Enclosure 2: Attachment to Email Dated 11-29-21, Responses to Follow Up Questions, Acceptance Tests for the Lead Ssield of the Shielded Canisters (Model Nos. TRUPACT-II and Halfpact Packages ML22006A3522021-12-27027 December 2021 Enclosure 3: Email Dated 12/27/21 from S. Burns (Nwp) to N. Garcia Santos (Nrc), Comments on Telephone Call Summary Dated 12/1/21, Model Nos. TRUPACT-II and Halfpact Packages ML22006A3512021-12-27027 December 2021 Enclosure 4: Nwps (Applicants) Comments on the Summary of the Teleconference Dated December 1, 2021 Related to Shielding RAIs (Acceptance Tests), Model Nos. TRUPACT-II and Halfpact Packages ML22006A3542021-11-29029 November 2021 Enclosure 1: Transmittal Email Dated 11/29/21, Follow Up Questions and Responses Related to Acceptance Tests (Shielded Canisters), Model Nos. TRUPACT-II and Halfpact Packages ML20316A0012020-09-28028 September 2020 Email from K. Moyant (Nwp) to N. Garcia Santos (NRC) - Follow Up to Telephone Call Regarding the Materials and Criticality Evaluations, TRUPACT-II (Rev. 25) and Halfpact (Rev. 9) 2023-05-08
[Table view] Category:Meeting Summary
MONTHYEARML22006A3512021-12-27027 December 2021 Enclosure 4: Nwps (Applicants) Comments on the Summary of the Teleconference Dated December 1, 2021 Related to Shielding RAIs (Acceptance Tests), Model Nos. TRUPACT-II and Halfpact Packages 2021-12-27
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23095A1112023-04-17017 April 2023 Enclosure - Requests for Additional Information for the Letter Authorization for the Model No. Halfpact Package ML23089A2572023-03-29029 March 2023 Email from Ngarcia Santos (NRC) to T.E. Sellmer (Simco), Subject: Structural and Operations - Staggered RAIs Pertaining to the Halfpact Letter Authorization ML23089A2582023-03-29029 March 2023 Email Attachment, Staggered Request for Additional Information (Structural Evaluation and Operating Procedures), Model No. Halfpact - One-time Letter Authorization ML22256A3052022-09-19019 September 2022 Enclosure- Request for Additional Information Model Nos. TRUPACT-II and Halfpact ML22006A3512021-12-27027 December 2021 Enclosure 4: Nwps (Applicants) Comments on the Summary of the Teleconference Dated December 1, 2021 Related to Shielding RAIs (Acceptance Tests), Model Nos. TRUPACT-II and Halfpact Packages ML21214A1462021-08-11011 August 2021 2. Enclosurequest for Additional Information Model Nos. TRUPACT-II and Halfpact (EPIDs L-2021-LLA-0033 and L-2021-LLA-0034) ML21214A1452021-08-11011 August 2021 Transmittal Letter Request for Additional Information, Model Nos Trupact II and Halfpact Transport Packages 2023-04-17
[Table view] |
Text
Attendees:
Nuclear Waste Partners LLC (NWP LLC or NWP):
Todd Sellmer, Manager, Packaging and Information Systems Scott Burns, Packaging Engineer, Project Manager Steve Porter, Primary Shielding Reviewer
U.S. DOE (DOE):
DaBrisha Smith, Package Certification Specialist
U.S. Nuclear Regulatory Commission (NRC):
Norma García Santos, Project Manager William Allen, Shielding Reviewer Omar Khan, Materials Reviewer John Wise, Senior Materials Reviewer Aaron Thomilson, Inspector (Quality Assurance, Operations, and Acceptance Tests)
SUBJECT:
12/1/21-Conference Call with Nuclear Waste Partners LL C and the U.S.
Department of Energy-Discuss Follow up Questions Related to Shi elding RAIs RAI-Sh-5 and -8, Model Nos. TRUPACT-II and HalfPACT (Docket Nos. 71-9218 and 71-9279; EPID L-2021-LLA-0033 and L-2021-LLA-0034, respecti vely)
On December 1st, 2021, NRC, NWP, and DOE/CBFO participated on a phone call to discuss the follow up questions to the responses to requests for additi onal information (RAI) related to the shielding evaluation for revisions of the certificates of c ompliance of Model Nos. TRUPACT-II and HalfPACT packages. The staff sent the following clarifi cation questions:
- 1. Is the lead thickness in the packages drawings used as the standard to determine the reject rate for the minimum lead thicknesses?
Shielded Container Minimum Cavity Width Minimum Lead Thickness SC-30G1 0.94 in. 0.88 in.
SC-30G2 1.40 in. 1.31 in.
SC-30G3 2.75 in. 2.57 in.
SC-55G2 1.98 in. 1.86 in.
- 2. Is the standard used to determine the reject rate not steppe d configured (i.e., the configuration seen in the figure below adjacent to the arrow and the D), but a simple lead plate sandwiched between two stainless steel plates (i.e., the configuration seen in the figure 7-23 farthest from the arrow and the D)? (this q uestion is related to Figure 7-23, Regulatory Hypothetical A ccident Condition Type B Testing for the HalfPACT Shielded Container Payloads.
- 3. The applicant noted the following:
the radioisotope (source) is placed at a distance equal to the source to survey instrument distance representative of the SCA to be gamma scann ed.
a) Is the source placed in the center of the shielded container ca vity or next to the cavity wall?
Enclosure 2 4 a)b) If it is placed next to the cavity wall, does the source move i n tandem with the detector shown in Figure 6-47, Regulatory Hypothetical Acciden t Condition Type B Testing for the HalfPACT Shielded Container Payload?
The document enclosed to this summary includes the responses fr om the applicant to these questions. This document summarizes the discussions between th e staff and the applicant.
In terms of question No. 3, the staff asked how the source is l ocated during the scan. The applicant explained that, during the scan of the lead shield, there is a test port and a detector at the center of the of the lid. The source and the detector move together up and down the internal wall of the shielded canister. During production of the packag e, the lid is modified and built to the same thickness as the one used during testing.a test lid wi th a hole in the center is used.
The hole in the center of the lid allows for the source to be i nserted into the cavity of the shielded container while the detector is located outside of the cavity. The source and detector move together up and down the wall of the shielded container. During production of the shielded containers, the test lid for gamma scans will be built to the same thickness and general configuration as the production lids, but will have a center penetration to a llow for the source to be inserted into the cavity for gamma scan testing.
The prototypes used a 1-inch top plate during gamma scan testing. The applicant notes that the this did not cause issues with the SC-30G2 canister. For the bigger canisters (SC-30G3 and SC-55G2), the applicant added a step tolead plates matching the inner cavity diameter to mimic the production lid. Also, during testing, yellow blankets and bags of lead shot are placed on top of the link lead serving as additional shielding during gamma scan testing. The applicant also measured the anulusannulus after the drop tests (see Table 7-2 of the report).
In terms of question No. 2, the staff asked how far the gamma scans source is from the center of the shielded container is. The applicant noted the following:
- 1. The source is located at the same distance as during product ion of the container.
- 2. The calibration standard used to calibrate the gamma scan mimics the cross -section of the shielded container, but using minimum material conditions (i.e., thicknesses).
- 3. During the scan test, there was no lead on top of the shield ed container. Norma, we are not sure what is intended by #3. Is this referring to the point discussed that there was no lead associated with the test lid used for the SC-30G2 containe rs? Or is this referring to the gap observed in the end of the lead annulus? If the intent ion for this item is the later, a separate clarification is included for reference (attached).
Figure 7-2334, provided in revision 1 of the reportHPT-REP-0001, shows a 0.318-inch gap with no lead on the cross section of the shielded container tested. In this case, the shielded containers passed the gamma scan test, but there was an abnorma l reading and the applicant decided to disassemble it to investigate the cause of the abnor mal reading. The applicant pointed out that they cut multiple cross sections of the shield ed canister that had an abnormal reading. This gap was formed after drop testing (note the cont our matching the steel) due to the presence of a pre-existing gap that formed due to a cold shut o n the other end of the annulus during lead pour. The results of the gamma scan performed afte r drop testing raised concern at the ends of the annulus. The sections chosen for the post-test destructive disassembly were based on the gamma scan result comparisons between the pre-drop testing and post-drop testing gamma scans (Figure 7.30). Multiple cross sections of the shielded containers were cut where the gamma scan result comparisons warranted investigation.
Figure 7-23, provided in revision 1 of HPT-REP-0001, actually s hows a cold shut with no lead on the cross-section of the shielded container tested. It is located such t hat the geometry of the base precludes a direct shine path resulting from the gap.
The gap shown in Figure 7-34 shows the location of the gap buried on the lidis located such that the geometry of the lid precludes a direct shine path resulting from the gap. Supplemental analyses showed a minimal increase in dose rate. The applicant noted that they added a section in the shielding chapter to address axial gaps. The st aff pointed out that the applicant should ensure that there are no gaps on the packages lead shie ld during construction, since the gamma scan may not detect those gaps.
The applicant explained that they performed an analysis of the lead shield assuming a 1/2-inch gap and the package should not exceed 200 mrem prior to shipmen t (see Section 7.1.4). The staff noted that he performed a hand calculation assuming a 1/2-i nch gap resulting on a dose increase. The applicant pointed out that the increase in dose rate is captured in the 10% margin on the radioactivity limit. The staff pointed out that the 10% margin was initially used to address source redistribution and source intensity. Therefore, the app licant needs to justify the applicability of crediting the use of the 10% margin for calcul ating the dose related to a gap in the lead shield.
The applicant mentioned that they are working on refining the p rocess of using the gamma scan. The applicant commented that refining the process should ensure that the lead shield meets the minimum measurements in the packages drawings during fabrication.
The table provided in question 1, includes the minimum cavity w idth and the minimum thickness of the lead shield and steel shells. The applicant pointed out the following:
- 1. The gamma scan is set at a minimum cavity width. Norma, we are not sure what is intended by #1. After the reject rate is determined using the calibration standard described items in 2, 3, and 4 below, the source is inserted in to the cavity through the center hole in the test lid while the detector remains outside of the cavity. The source and detector move up and down over the length of the cavity whi le the distance (and elevation) between them are fixed.
- 2. The calibration standard is made of steel-lead-steel.
- 3. The calibration standard mimics the minimum width of the shielded container lead annulus and thickness of the steel shells.
- 4. The minimum thickness of the lead shield is used as to determine the reject rate during the gamma scan process.
The staff will contact the applicant if there are any additiona l questions about the RAI responses.