ML20113E983
| ML20113E983 | |
| Person / Time | |
|---|---|
| Site: | Orano USA |
| Issue date: | 04/22/2020 |
| From: | Santos N Division of Fuel Management |
| To: | Boyle R US Dept of Transportation, Office of Hazardous Materials Safety |
| Garcia-Santos N | |
| References | |
| EPID L-2020-LLA-0011 | |
| Download: ML20113E983 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 22, 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-3 TRANSPORT PACKAGE -
ACCEPTED FOR REVIEW
Dear Mr. Boyle:
By letter dated December 12, 2019 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML20052D258), 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/347/AF-96, Revision Fs, Model No. FCC-3 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. The enclosure includes staffs observations related to the criticality safety evaluation. 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 staff begins a detailed review.
This letter acknowledges acceptance of your application. The application appears to contain the information needed for our technical review. We have established a schedule for the review and estimated that the staff may need approximately 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> to complete its review. The schedule allows for the staff to issue the first request for additional information (RAI) in July 2020 and, if a second RAI is not needed, a certificate of compliance in October 2020, based on you responding to the first RAI in August 2020. In general, no additional changes to the application should be submitted except for changes resulting from your response to an RAI.
R. Boyle Please reference Docket No. 71-3083 and EPID L-2020-LLA-0011 in future correspondence related to this action. The staff is available to meet and discuss your proposed responses.
If you have any questions regarding this matter, please contact me at 301-415-6999 or ngs@nrc.gov.
Sincerely, Norma Garcia Digitally signed by Norma Garcia Santos Santos Date: 2020.04.22 14:15:49 -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. 71-3083 EPID L-2020-LLA-0011
Enclosure:
Observations Related to the Proposed Revision to Model No. FCC-3.
ML20113E983 OFFICE\DIV: DFM DFM DFM DFM DFM SFigueroa VWilson KArmstrong JMcKirgan NAME: NGarcía Santos by email by email by email by email DATE: 4/16/20 4/17/20 4/20/20 4/20/20 4/21/20 Observations Related to the Proposed Revision to Model No. FCC-3 Package U.S. Department of Transportation French Approval Certificate Number F/347/AF-96, Revision Fs Docket No. 71-3083 Criticality Safety Evaluation OBS-Cr-1 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/347/AF-96 (Revision Fs) for the Model No. FCC-3 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.
OBS-Cr-2 Provide the following information regarding the assumption of chromium oxides in the criticality analyses:
- a. justify that ignoring the inclusion of chromium oxide within the UO2 is conservative with respect to criticality safety, and
- b. explain how the chromium oxide is treated for Contents Nos. 3 and 4 for the Model No. FCC-3.
The following criticality analysis files state that the chromium oxides are ignored in the criticality analysis:
- 095 SUNSI Encl 3 FCC 3 Ap 2.5-1 FFDC00817 EN (160 PUBLIC Encl 4 FCC 3 Ap 2.5-1 FFDC00817 EN) that represents Content Nos. 1 and 2 for the FCC-3, and
- 097 SUNSI Encl 3 FCC 3 Ap 2.5-2 FFDC01046EN (162 PUBLIC Encl 4 FCC 3 Ap 2.5-2 FFDC01046EN) that represents Content Nos. 5, 6, 7, and 8 for the FCC-3.
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.
1 Cr means criticality.
Enclosure
In addition, the following criticality file does not mention how chromium oxide is represented within the criticality analysis:
099 SUNSI Encl 3 FCC 3 Ap 2.5-3 FFDC01106-A E0.pdf, (164 PUBLIC Encl 4 FCC 3 Ap 2.5-3 FFDC01106EN) that represents Contents Nos. 3 and 4 for the FCC-3.
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.
2