ML22180A241

Orano Federal Services, LLC, Letter from Nishka Devaser to Philip Noss of June 10, 2022, Transmittal of Response to Request for Additional Information (RAI)

ML22180A241
Person / Time
Site:	07109341
Issue date:	06/27/2022
From:	Noss P Orano Federal Services
To:	Yoira Diaz-Sanabria Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML22180A240	List: ML22180A241
References
EPID L-2021-LLA-0215, FS-22-0047
Download: ML22180A241 (4)

Text

June 27, 2022 FS-22-0047 Page 1 of 4 Federal Way Office USA 505 S. 336th Street Suite 400 Federal Way, WA 98003 Tel: (253) 552-1310

@orano_USA Yoira K. Diaz-Sanabria, Chief Storage and Transportation Licensing Branch U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Two White Flint North - Mail Stop 4 B34 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

1) BRR Package Amendment Request, Docket No. 71-9341 and EPID L-2021-LLA-0215

2) Letter from Nishka Devaser to Philip Noss of June 10, 2022, transmitting a Request for Additional Information (RAI)

Dear Ms. Diaz-Sanabria:

Orano Federal Services LLC (Orano FS) hereby submits Revision 18 of the Safety Analysis Report (SAR) for the BRR Package, Docket No. 71-9341, which includes changes made in response to the NRC RAI referenced above. Our response to the RAI is provided in Attachment A to this letter. A minor change was also made to the licensing drawing for the new canister as a result of fabrication review. All changes are discussed and justified in Attachment A.

Revisions to the SAR are marked with a change bar in the margin, and all pages have been updated to show Revision 18. A summary of all of the changes in SAR Revision 18 is provided at the end of Attachment A.

Of note, drawing 1910-01-04-SAR has also been included in Revision 18. This drawing was inadvertently omitted from the Revision 17 submittal. It is unchanged from Revision 16 of the BRR Package SAR.

In order to coordinate with the casks user schedules, we request that the certificate of compliance be issued no later than September 30, 2022.

Should you have any questions regarding this submittal, please contact me at (233) 552-1321 or via email (phil.noss@orano.group ).

Yours Truly, Philip Noss Licensing Manager Orano Federal Services LLC NOSS Philip Digitally signed by NOSS Philip Date: 2022.06.27 14:11:37 -07'00'

June 27, 2022 FS-22-0047 Page 2 of 4 Federal Way Office USA 505 S. 336th Street Suite 400 Federal Way, WA 98003 Tel: (253) 552-1310

@orano_USA Attachment A Response to RAI, BRR Package Amendment Docket 71-9341, L-2021-LLA-0215 Chapter 5: Shielding Analysis RAI 5-1.

Provide an explanation for the source of the isotopic composition of the irradiated fuel rod segments used in the ORIGEN source term calculations.

The sample inputs provided in SAR Section 5.7.5.1 convert an existing isotopic inventory into a radiation source spectrum. The applicant mentions that the ORIGEN module of SCALE 6.2.4 was used for its calculations for irradiated fuel rod segments but did not describe any depletion calculations or other source of isotope inventory. Since the applicant did not provide any details on how the irradiated fuel isotope inventory was determined in SAR Section 5.7.2, staff is unable to determine how the applicant determined the irradiated fuel rod segment isotope inventory.

This information is required to determine compliance with 10 CFR 71.47.

Response

The listed isotopic inventory is based on existing data for fuel rods of similar form and irradiation history as those intended for shipment. No depletion calculations were performed as part of the SAR analysis. The selected isotope quantities are expected to be sufficiently conservative such that any actual payload will be bounded by the resulting gamma and neutron source terms.

The shipper will be responsible for confirming that their specific payload is bounded by the analyzed gamma and neutron source terms prior to shipment.

Table 1.2-5 has been added to the SAR to define the bounding gamma energy spectrum for one full length rod and Table 1.2-6 has been added to define the bounding neutron energy spectrum. Section 5.7.2 has been revised to expand the discussion of the fuel rod source term.

RAI 5-2.

Provide an explanation for the source of the radioactive isotopic compositions of the three irradiated metal materials described in SAR Tables 5.8-3, 5.8-4, and 5.8-5 on which the ORIGEN source term calculations are based.

The sample inputs provided in SAR Section 5.8.5.1 convert an existing isotopic inventory into a radiation source spectrum. The applicant mentions that the ORIGEN module of SCALE 6.2.4 was used for its calculations for irradiated metal but did not describe nor provide sample input for activation calculations or other source of isotope inventory. Since the applicant did not provide any details

June 27, 2022 FS-22-0047 Page 3 of 4 Federal Way Office USA 505 S. 336th Street Suite 400 Federal Way, WA 98003 Tel: (253) 552-1310

@orano_USA on how the irradiated fuel isotope inventory was determined in SAR Section 5.8.2, staff is unable to determine how the applicant determined the irradiated metal source isotope inventory.

This information is required to determine compliance with 10 CFR 71.47.

Response

The radioactive isotopic compositions of the three irradiated metal materials are based on existing data for irradiated material similar to expected payloads. No activation calculations were performed as part of the SAR analysis. The resulting gamma and neutron source terms represent a conservative generic payload. The shipper will be responsible for confirming that their specific payload is bounded by the analyzed gamma and neutron source terms prior to shipment.

Table 1.2-7 (provided in the previous revision of the SAR as Table 1.2-5) presents the bounding volumetric gamma energy spectrum for the irradiated metal payload. Section 5.8.2 has been revised to expand the discussion of the irradiated metal source term.

Revision to Drawing 1910-01-03-SAR, Revision 8:

On sheet 5, zone A-6, the weld between the canister shell wall and the baseplate has been changed to: complete joint penetration, ground flush.

During the bidding process for fabrication of the canister, it was determined that the original weld shown on Revision 7 of this drawing was not practical to fabricate. The revised weld design is structurally equivalent to the original weld design, and serves to secure the baseplate to the canister shell during lifting operations. The weld is not subject to a significant load during transportation of the BRR package and it does not have a safety function when the canister is within the cask.

Restoration of Drawing 1910-01-04-SAR:

This drawing was inadvertently omitted from Revision 17 of the SAR. It is unchanged from the drawing provided in Revsion 16 of the SAR.

June 27, 2022 FS-22-0047 Page 4 of 4 Federal Way Office USA 505 S. 336th Street Suite 400 Federal Way, WA 98003 Tel: (253) 552-1310

@orano_USA Summary of Changes in SAR Rev. 18:

Section Change Justification 1.2.2.7 Added reference to new tables 1.2-5 and 1.2-6.

Update.

1.2.2.8 and 1.2.3 Tables referenced in these sections were renumbered due to insertion of two new tables.

Update.

Table 1.2-5 and Table 1.2-6 Inserted To define bounding fuel rod gamma and neutron source terms.

Table 1.2-7 and Table 1.2-8 Tables renumbered.

Table contents not changed.

Drawing 1910-01 SAR, Sheet 5, Zone A/6 Revised weld between canister bottom plate and shell.

Original weld determined to be impractical.

Drawing 1910-01 SAR Included.

Drawing was inadvertenly omitted from SAR Revision 17. Drawing unchanged.

5.7.2 Expanded discussion of fuel rod source term.

RAI response.

5.8.2 Expanded discussion of irradiated metal source term.

RAI response.

Copies:

ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Nishka Devaser, U.S. NRC Collin Knight, NSUF Post-Irradiation Examination Project Manager Nick Adams, INL P&T Program Manager Tom Criddle, Project Manager, Orano Federal Services LLC