ML24204A233

Acceptance Determination Letter with Observation, Certificate of Compliance No. 9355, Model No. 435-B

ML24204A233
Person / Time
Site:	07109355
Issue date:	08/08/2024
From:	Garcia-Santos N Division of Fuel Management
To:	Al-Daouk A US Dept of Energy, National Nuclear Security Admin
Shared Package
ML24222A581	List: ML24204A233
References
CAC 001029, EPID L-2023-LLA-0102
Download: ML24204A233 (1)

Text

August 8, 2024

Ahmad M. Al-Daouk, Director Office of Packaging and Transportation U.S. Department of Energy National Nuclear Security Administration P.O. Box 5400 Albuquerque, NM 87185

SUBJECT:

ACCEPTANCE OF THE NATIONAL NUCLEAR SECURITY ADMINISTRATION REVISION NO. 4, TO CERTIFICATE OF COMPLIANCE NO. 9355 FOR THE MODEL NO. 435-B - COST ACTIVITY CODE 001029/ENTERPRISE PROJECT IDENTIFICATION NUMBER L-2023-LLA-0102

Dear Ahmad M. Al-Daouk:

The U.S. Nuclear Regulatory Commission (NRC) staff has received your submittal dated March 5, 2024 [Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML24072A001], requesting revision No. 4 of Certificate of Compliance (CoC) No.

9355 for the Model No. 435-B package design.

The staff performed an acceptance review of your application to determine if the application contained sufficient technical information in scope and depth to allow the staff to complete a detailed technical review. The enclosure includes a staffs Observation related to the procedures and loading of the package. The staff included an Observation 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.

Your submittal has been assigned a Cost Activity Code (CAC)/Enterprise Project Identification (EPID) Number [001029/L-2023-LLA-0102]. Please reference these numbers and Docket No.

71-9355 in any future correspondence associated with this request.

Please note that the NRC staffs technical review of your submittal may identify issues that could require that you provide additional information. Based on our preliminary evaluation and projection of current review schedules, we anticipate issued a CoC by February 2025. This schedule includes the issuance, if needed, of a request for additional information (RAI) by September 2024 and receiving your response to the RAI 45 days after its issuance to allow adequate time to provide responses. Please note that these dates could change depending on the findings of our technical review, urgent assignments, or other factors, such as whether your responses to the RAI are or are not adequate. The NRC staff estimates that completing the review of your submittal will require approximately 400 staff-hours. We will promptly communicate significant schedule and/or estimate changes, if any.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for A.Al-Daouk 2

public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If you have any questions regarding this communication, please contact me via e-mail to Norma.GarciaSantos@nrc.gov.

Sincerely,

Signed by Garcia Santos, Norma on 08/08/24

Norma Garcia Santos, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards

Docket No.: 71-9355 CAC No. 001029 EPID No L-2023-LLA-0102

Enclosure:

Observation Observation Certificate of Compliance No. 9355 Docket No. 71-9355 Revision 4

OBS-7-1Clarify Section 7.1.3.1 step 10 of the application, related to:

1.the shipment of Type B contents that has been preceded in shipment by Special Form, Type A contents, Low Specific Activity (LSA) material, or Surface Contaminated Objects (SCO) contents, specifically when the vent port plug cannot be verified as being closed for the Type B contents, and

2.the performance of an ANSI N14.5 pre-shipment leakage rate test on seals that have been opened.

Section 7.1.3.1, step 10 of the application states the following:

10.Pre-shipment leakage rate testing of the main containment O-ring seal and vent port sealing washer shall be performed according to the following criteria:

a.If all of the radioactive material in the 435-B package is contained in sealed sources that have been qualified as special form according to the requirements of Section 7.1.6, Recognition of Special Form, no leakage rate test is required. NOTE: If this criterion is not met, a leakage rate test must be performed according to (b) or (c) of this step.

b.If the main containment (upper) O-ring seal has been replaced or the corresponding sealing surface repaired, or if the vent port plug or sealing washer has been replaced or the mating sealing surface repaired, the leakage rate tests shall be performed according to Section 8.2.2, Maintenance/Periodic Leakage Rate Tests.

c.If the criteria of step (b) above do not apply, as an option, pre-shipment leakage rate testing may be performed according to Section 7.4, Pre-shipment Leakage Rate Test.

For part 1 of the clarification, package users should consider the following (with underlining for emphasis) from NRC Information Notice (IN) 2016-04, ANSI N14.5-2014 Revision and Leakage Rate Testing Considerations (ML16063A287), which would also apply to special form material as well as Type A contents, LSA material, or SCO. The staff acknowledges that the circumstances described below could be unlikely.

Pre-shipment leakage rate test on Type B package containment boundary components that have been opened: Section 7.6 and Table 1 of ANSI N14.5-2014 address the pre-shipment leakage rate test on Type B package containment boundary components that have been opened. The pre-shipment

Enclosure 2

leakage rate test is necessary to confirm that the containment system is properly assembled for each shipment. Type B packages containing a Type B quantity of material could have been used to transport Type A, LSA material, or SCO in a previous shipment. Containment boundary components (e.g., seals and valves) could have been opened during a previous shipment of Type A contents, LSA material, or SCO, but a pre-shipment leakage rate test might not have been performed at that time. A pre-shipment leakage rate test should be performed on the containment boundary components that cannot be verified as being closed to confirm that the containment system is properly assembled on packages containing a Type B quantity of material.

For part 2 of the clarification, an ANSI N14.5 pre-shipment leakage rate testing should be performed on containment boundary seals that have been opened, unless a maintenance/periodic leakage rate test has been performed before each shipment, after the contents are loaded, and the containment system is assembled, in lieu of a pre-shipment leakage rate test. This is especially important for Type B contents in normal form.

This information is needed to determine compliance with 10 CFR 71.37(b),

71.51(a)(1) and (2), and 71.87(c).