ML21050A192
| ML21050A192 | |
| Person / Time | |
|---|---|
| Site: | 07109382 |
| Issue date: | 03/10/2021 |
| From: | Bernie White Storage and Transportation Licensing Branch |
| To: | Narayanan P TN Americas LLC |
| BHWhite - NMSS/DFM/STL - 301.415.6577 | |
| Shared Package | |
| ML21050A190 | List: |
| References | |
| EPID L-2021-NEW-0000 | |
| Download: ML21050A192 (4) | |
Text
Non-Proprietary Request for Supplemental Information Model No. Nos. TN Eagle-STC SC and TN Eagle-STC LC Docket No. 71-9382 This request for supplemental information (RSI) identifies information needed by the staff in connection with its acceptance review of an application for a certificate of compliance for the Model Nos. TN Eagle-STC SC and TN Eagle-STC LC (herein referred to as the TN Eagle-STC, unless the specific request refers only to a single model number, either the SC or LC) spent fuel packages, dated December 30, 2020 (Agencywide Documents Access and Management System Accession No. ML20365A018).
The requested information is listed by chapter number and title in the applicants safety analysis report (SAR).
Request for Supplemental Information General Provide the calculation packages for the analysis that supports the structural, thermal, shielding, and criticality analyses and conclusions in the SAR.
The calculation package should include information and analyses that support the evaluations described in each of the technical chapters. The staff needs to review the calculation packages to provide reasonable assurance that the regulations for have been met.
This information is needed to determine compliance with Title 10 of the Code of Federal Regulations (10 CFR) 71.35.
2.0 Structural Evaluation Provide the following documents referenced in the SAR.
- See proprietary enclosure, and
- The American Society of Mechanical Engineers (ASME) Guidance Document (Draft),
Use of Explicit Finite Element Analysis for the Evaluations of Nuclear Transport and Storage Packages in Energy-Limited Impact Events.
The applicant cites these aforementioned references in Appendix 2.11.7 of the TN Eagle-STC SAR which were used to support LS-DYNA drop simulations for normal conditions of transport (NCT) and hypothetical accident conditions (HAC) conditions. However, the staff does not have access to these documents nor were they furnished in the application. As discussed in Section 2.4.10 of NUREG-2216, Standard Review Plan for Transportation Packages for Spent Fuel and Radioactive Material, the staff cannot make a reasonable safety determination without reviewing the validity and applicability of these referenced documents. For this reason, the staff requires these documents to conduct its review.
This information is required to comply with 10 CFR 71.71 and 10 CFR 71.73.
7.0 Materials Evaluation See proprietary enclosure.
Enclosure 1
Observations:
2.0 Structural Evaluation Provide input and output files used to support NCT and HAC analyses.
In the SAR, Appendices 2.11.1 through 2.11.13, the applicant discusses various methods used to evaluate the TN Eagle-STC package and its components for various NCT and HAC scenarios. The staff noted that finite element (FE) modelling software (LS-DYNA and/or ANSYS) were used to conduct drop test simulations in lieu of physical testing. However, input/output files for these software codes were not provided. As discussed in Section 2.4.10 and Attachment 2A of NUREG-2216, Standard Review Plan for Transportation Packages for Spent Fuel and Radioactive Material, providing the staff this information to verify that the aforementioned analyses provide reasonable assurance that the regulations for NCT and HAC drops are being met would enhance the efficiency of the NRC review. Without these files, the geometry, boundary conditions, loading, material properties, structural behavior, etc. for the TN Eagle-STC package and its components cannot be adequately determined. For these reasons, the staff requests these files to conduct its review.
This information is required to comply with 10 CFR 71.71 and 10 CFR 71.73.
3.0 Thermal Evaluation Provide input and output files of the thermal analysis performed for bounding configurations (as described in the application) of the TN Eagle-STC transport package.
In SAR Sections 3.3 and 3.4, the applicant provides a general description of the thermal models used to perform steady state and transient analyses for the NCT and HAC of transport.
However, the application does not include any input and output files that the applicant used to perform the thermal evaluation for both NCT and HAC.
Section 3.4.3.1 of NUREG-2216 Standard Review Plan for Transportation Packages for Spent Fuel and Radioactive Material states that for each thermal analysis, the reviewer should verify that the applicant has provided information on any computer-based modeling (as described in NUREG-2216 Attachment 2A Computational Modeling Software Technical Review Guidance),
and should evaluate the thermal analyses the applicant submitted, in accordance with the attachment. Providing the staff this information to check the code input in the thermal analysis to confirm that the applicant used the proper material properties and boundary conditions would enhance the efficiency of the NRC review. The staff needs also to verify that the applicants selected code models and assumptions are adequate for the heat transfer characteristics prevailing in the TN Eagle-STC cask geometry and analyzed conditions for the bounding configurations, to make sure the analysis models are consistent with the thermal analysis described in the SAR. The staff also needs this information to verify that adequate geometry dimensions from the design drawings were properly translated to the analysis models.
The staff generally will review analysis models in order to inform their safety finding on cask designs submitted to the NRC for a Certificate of Compliance. The accuracy of these models must be verified in order to provide reasonable assurance that the design under review meets the appropriate regulations.
This information is needed to determine compliance with 10 CFR 71.31(a)(2), 71.35(a), and 10 CFR 71.41(a).
5.0 Shielding Evaluation Provide representative input/output files for dose rate calculations.
The staff requests that the applicant provide representative input/output files for the dose rate evaluations. This should include:
- ORIGEN-ARP depletion input/output file for neutron and gamma source from a representative pressurized-water reactor (PWR) fuel assembly;
- ORIGEN-ARP depletion input/output file for neutron and gamma source from a representative boiling-water reactor fuel assembly;
- ORIGEN-ARP depletion input/output file for neutron and gamma source from a representative mixed oxide fuel assembly;
- MCNP input/output files for neutron and gamma dose calculations under NCT and HAC for the EOS-37PTH dry shielded canister (DSC);
- MCNP input/output files for neutron and gamma dose calculations under NCT and HAC for the EOS-89BTH DSC;
- MCNP input/output files for neutron and gamma dose calculations under NCT and HAC for the 24PT1 DSC;
- MCNP input/output files for neutron and gamma dose calculations under NCT and HAC for the 24PT4 DSC;
- MCNP input/output files for neutron and gamma dose calculations under NCT and HAC for the 32PTH1 DSC; and
- MCNP input/output files for neutron and gamma dose calculations under NCT and HAC for Fuel/Control Components (FC), Fuel-Only (FO), and Failed Fuel (FF) DSCs.
Providing the information would enhance the efficiency of the NRC review, since the staff uses this information to ensure that the components are appropriately modeled with appropriate depletion parameters and transport options and to ensure that calculations have achieved proper convergence.
This information is needed to determine compliance with 10 CFR 71.47(b) and 10 CFR 71.51(a)(2).
6.0 Criticality Evaluation Provide representative input files for criticality calculations.
The staff requests that the applicant provide representative SCALE input files for the criticality evaluations of the package. These should include:
- TRITON depletion input file for generating ORIGEN-ARP reactor libraries for a representative PWR assembly with burnable poison rod assembly exposure;
- TRITON depletion input file for generating ORIGEN-ARP reactor libraries for a representative PWR assembly with control rod exposure;
- KENO V.a input files for criticality evaluations of the EOS-89BTH DSC in the TN Eagle-STC package;
- STARBUCS input files for criticality evaluations of the EOS-37PTH DSC in the TN Eagle-STC package; and
- STARBUCS input files for criticality evaluations of Combustion Engineering 14x14 spent nuclear fuel in the 32PT DSC with the 24 poison plate configuration in the TN Eagle-STC package.
Providing the information would enhance the efficiency of the NRC review, since the staff uses this information to ensure that the components are appropriately modeled with appropriate depletion parameters and transport options and to ensure that calculations have achieved proper convergence.
This information is needed to determine compliance with 10 CFR 71.55 and 10 CFR 71.59.
- 10. Quality Assurance Chapter 10, Quality Assurance, states that, TN Americas LLC (TN) has a Quality Assurance (QA) program that has been previously approved by the NRC. The TN QA program has been established in accordance with the requirements of 10 CFR Parts 71 and 72, Subparts H and G, respectively. The QA program applies to the design, purchase, fabrication, handling, shipping, storing, cleaning, assembly, inspection, testing, operation, maintenance, repair, and modification of the TN Eagle Cask and components [emphasis added] identified as "important-to- safety".
The staff requests that the applicant provide clarification and discussion as to whether the dry shielded canisters (DSCs) listed within SAR Section 1.2.3 are within the scope of TN Eagle Cask and components discussed in SAR Section 10 and therefore subject to the QA program.
Specific discussion is requested for those components of the DSC that are credited as performing a safety function, see observation No. 1 in General Information Evaluation, above.
Note that as stated in Section 1.2.3 of the SAR, it appears that the DSC, including the basket, is considered to be contents in the TN Eagle package. If the DSC and basket provides a safety function (e.g., spacing of the fuel assemblies for thermal or criticality analyses), then as defined in 10 CFR 71.4 the packaging means the assembly of components necessary to ensure compliance with the packaging requirements of this part.
The staff uses this information to ensure the identification of packaging components, items, and attributes important to safety and how the QA program will control them.
This information is needed to determine compliance with 10 CFR 71.101 and 10 CFR 71.105.