ML25062A097
| ML25062A097 | |
| Person / Time | |
|---|---|
| Site: | 07109384 |
| Issue date: | 02/28/2025 |
| From: | Robatel Technologies |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML25062A092 | List: |
| References | |
| 2021-034-SCL-01 | |
| Download: ML25062A097 (1) | |
Text
This clarification letter regarding the Part 71 Application for Approval of RT-200 Type B Cask Package for Radioactive Material represents Robatels approach to its business as applied to the specifications of this submittal. This response letter requests that the Nuclear Regulatory Commission respects the proprietary information and withholds it from public disclosure subject to the provisions of 10 CFR 2.390.
Robatel Technologies 5115 Bernard Dr. Suite 304 Roanoke, VA 24018 February 20, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738
Subject:
Robatel Technologies, LLC, Additional Clarification for the U.S. NRC Request for Additional Information for Review of the Robatel Technologies, LLC Model No. RT-200 Type B(U) Cask
Reference:
ADAMS Accession No. ML24304A911, dated October 30, 2024 This letter provides additional clarification to the responses provided in the letter dated October 30, 2024 (Accession No. ML24304A911) which addressed the Requests for Additional Information (RAIs) noted in the U.S. NRC letter, dated August 30, 2024 (Accession No. ML24222A718).
RAI-St-2P PROPRIETARY/TRADE SECRET INFORMATION REMOVED -
WITHHELD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390
2 PROPRIETARY/TRADE SECRET INFORMATION REMOVED -
WITHHELD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390
3 RAI-Co-2 Per RAI-Co-2, the applicant removed closure bolt from the containment boundary, and revised the statement in section 4.1.1 (SAR Revision 1) as The package containment system is defined as the containment vessel (the inner shell, the rear forging plate and the front forging flange),
together with the associated lid and O-ring seals. Recommend to further revise this statement to make the containment boundary more clearly defined:
The statement will be clarified and updated to read:
The package containment system is defined as the containment vessel (the inner shell, the rear forging plate, and the front forging flange), together with the cask lid, the vent and drain port cover plates, the associated inner elastomer O-ring seals installed on the cask lid and vent and drain port cover plates, and the associated containment welds.
RAI-AM-7 Additional clarification is needed to ensure common understanding of Robatel's response to RAI-AM-7 as it relates to the use of French Confederation for Non-Destructive Testing (COFREND) certified personnel and American Society for Nondestructive Testing (ASNT) certified personnel as discussed in Safety Analysis Report (SAR), revision 1, Chapter 8, ACCEPTANCE TESTS AND MAINTENACE PROGRAM.
The optional use of COFREND certified inspectors in lieu of ASNT certified inspectors will be removed from the SAR. The following sections will be updated as follows:
8.1.1 Visual Inspections and Measurements Current: Visual and non-destructive examinations shall be performed by ASNT or COFREND certified inspectors Updated: Visual and non-destructive examinations shall be performed by ASNT qualified inspectors 8.1.2 Weld Examinations Current: Non-destructive examinations shall be performed by ASNT or COFREND certified inspectors.
PROPRIETARY/TRADE SECRET INFORMATION REMOVED -
WITHHELD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390
4 Updated: Non-destructive examinations shall be performed by ASNT qualified inspectors.
8.1.4 Leakage Tests Current: Detailed leakage test procedures shall at a minimum meet the requirements below and shall be approved by ASNT NDT or COFREND Level III leak testing certified personnel. The use of COFREND certified personnel instead of ASNT certified personnel is accepted for leakage testing for the RT-200 based on the equivalence note 103622 EQN 001 [Ref. 78].
Updated: Detailed leakage test procedures shall at a minimum meet the requirements below and shall be approved by ASNT NDT Level III leak testing qualified personnel.
Current:
- Test personnel shall be ASNT NDT or COFREND Level II certified for the respective leak test procedure.
Updated:
- Test personnel shall be ASNT NDT Level II qualified for the respective leak test procedure.
8.2.2 Leakage Tests Current: All procedures shall meet the requirements for leakage testing below and shall be approved by ASNT NDT or COFREND Level III certified personnel in leakage testing.
Leakage rate testing shall be performed by personnel that are qualified and certified in accordance with the requirements of SNT-TC-1A-2006 or COFREND equivalent. Refer to Section 8.3.2 for additional guidance on leakage rate determination.
Updated: All procedures shall meet the requirements for leakage testing below and shall be approved by ASNT NDT Level III qualified personnel in leakage testing.
Leakage rate testing shall be performed by personnel that are qualified in accordance with the requirements of SNT-TC-1A. Refer to Section 8.3.2 for additional guidance on leakage rate determination.
8.2.2.1 Periodic and Maintenance Leak Test Current: and testing personnel qualification and certification shall be in accordance with ANSI N14.5 [Ref. 72] or ISO 12807 [Ref. 74], in accordance with NUREG 2216 provisions [Ref. 76].
These tests must be carried out and interpreted by ASNT-SNT-TC-1A or COFREND II qualified personnel in accordance with NF EN ISO 9712 [Ref. 73].
Updated: and testing personnel qualification shall be in accordance with ANSI N14.5
[Ref. 72], in accordance with NUREG 2216 provisions [Ref. 76].
These tests must be carried out and interpreted by ASNT SNT-TC-1A Level II qualified personnel.