ML26021A161

Email Dated 1/13/26 from Ngarcia Santos (NRC) to Mrose (Inc), Follow Up Question to RAI-Th-5, Lithium Battery Performance at Low Temperature, Model No. IR-100ST, Docket No. 9385

ML26021A161
Person / Time
Site:	07109385
Issue date:	01/13/2026
From:	Joseph Borowsky, Garcia-Santos N Division of Fuel Management
To:	Maret Rose Industrial Nuclear Co
Shared Package
ML26021A160	List: ML26021A161 ML26021A162 ML26021A163
References
001029, L-2024-NEW-0008
Download: ML26021A161 (0)

Text

From:

Norma Garcia Santos To:

Mike Rose; rlm52 Cc:

Yoira Diaz Sanabria; Kristina Banovac; Jason Piotter

Subject:

QUERY-Follow Up RAI-TH-5, Model No. IR-100ST, Docket No. 9385 Date:

Tuesday, January 13, 2026 3:53:00 PM Good afternoon, Mr. Mike Rose,

The response to RAI-Th-5 needs clarification. It appears the response is saying that the package containing the LiFePO4 power cells will not be adversely affected when exposed to a temperature of -40 deg C (-40 deg F) if the LiFePO4 power cells are not operating.

-/ However, information in the SAR (e.g., section 3.3.1 and elsewhere) indicates that the power cells operate during transport. The application noted that cell charging has a 2.5 W maximum power (with a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> charging period) and occurs when the package is transported within an enclosed secure transport box in an enclosed transport vehicle. In addition, the SAR refers to the battery datasheet (reference 1.2.1 of the application), which mentions a charging temperature range of 0 deg C to 60 deg C and a discharging temperature range between -20 deg C to 60 deg C. [These temperature ranges are slightly different (but similar) to the temperature ranges provided in the RAI response. These temperature ranges were taken from the on-line battery specification sheet.]

-/ 10 CFR 71.43 tells us that a package must be designed so there is no reduction in package effectiveness during NCT (hot and cold) and 10 CFR 71.71 mentions a cold temperature of -40 deg C.

-/ The purpose of the RAI was the behavior of the lithium batteries during cold transport.

The response does not address the impact if the power cells are operating at cold temperatures (e.g., -40 deg C), which are outside the above-mentioned temperature ranges (e.g., 0 deg C to 60 deg C as well as -20 deg C to 60 deg C). Literature indicates, for example, that charging at low temperatures can lead to adverse thermal reactions.

-/ Based on the temperatures listed in the battery specification sheet, a CoC condition can be included that refers to the two temperature ranges.

Please provide a response by email and let me know if you would like to discuss this question and response over a phone call.

Thanks in advance,

Norma Garcia Santos Project Manager U.S. NRC Email: Norma.GarciaSantos@nrc.gov Phone No. 301-415-6999