AAR EVA

June 11, 2014E-38861

U.S. Nuclear Regulatory CommissionAttn: Document Control DeskOne White Flint North11555 Rockville PikeRockville, MD 20852

Subject: Application for Revision 12 to Certificate of Compliance No. 9233 for the Model No.TN-RAM Transportation Packaging, Docket No. 71-9233

References: Revision 11 to Certificate of Compliance No. 9233 for the Model No. TN-RAM

Packaging

Document E-10621, Safety Analysis Report for the TN-RAM, Revision 11

In accordance with 10 CFR 71.38, AREVA Inc. herewith submits its application to revise theCertificate of Compliance (CoC) for the TN-RAM packaging.

This submittal contains the following enclosures:

* Enclosure 1 provides a description of each safety analysis report (SAR) proposed pagechange, the reason for the change and the associated justification.

" Enclosure 2 provides an engineering evaluation that is in support of the proposed SARchanges described in Enclosure 1. This document is proprietary.

* Enclosure 3 provides the replacement pages for the proprietary version of the SAR.* Enclosure 4 provides the replacement pages for the non-proprietary version of the SAR.* Enclosure 5 provides an affidavit, in accordance with 10 CFR 2.390, specifically requesting

that you withhold proprietary information included in Enclosures 2 and 3 of this submittalfrom public disclosure. That information may not be used for any purpose other than tosupport the review of the application for revision to the TN-RAM CoC.

The changed areas in the SAR are marked as follows:" New or changed pages show "Revision 12" in the header." Changed areas are indicated using revision bars in the right-hand margin. Newly inserted

text is shown by italics.

AREVA Inc. respectfully requests an expedited review and issuance of Revision 12 of the TN-RAMCoC on or before July 3, 2014, to support an early July 2014 shipment. Only one TN-RAM caskhas been fabricated. Reportability assessments are in progress, and that cask is currentlyrestricted from use until this revision is approved.

AREVA TN

AREVA Inc.7135 Minstrel Way • Suite 300 • Columbia, MD 21045Tel: 410-910-6900 • Fax: 410-910-6902www. areva. com/AREVATN

Page 2 of 2E-38861

June 11, 2014

Should the NRC staff require additional information to support review of this application, please donot hesitate to contact Mr. Glenn Mathues at 410-910-6538 or me at 410-910-6820.

Sincerely,

Paul TriskaVice President, Technical Services

cc: John A. Vera, U.S. Nuclear Regulatory Commission0 One electronic copy (DVD) of this letter and Enclosures 1 through 5.

Enclosures:

1. SAR Proposed Page Changes, Description, and Justification2. Engineering Evaluation, Number 49944-EE-001, Revision 0 (proprietary)3. Replacement Pages for the TN-RAM SAR, Revision 12 (Proprietary Version)4. Replacement Pages for the TN-RAM SAR, Revision 12 (Non-Proprietary Version)5. Affidavit Pursuant to 10 CFR 2.390

AREVA TN

AREVA Inc.7135 Minstrel Way Suite 300 • Columbia, MD 21045Tel: 410-910-6900 • Fax: 410-910-6902www. areva .com/AREVATN

Enclosure 1 to E-38861SAR Proposed Page Changes, Description, and Justification

ContainmentBoundary?

Y/NSAR Dwg Ref. Revision Justification

1 990-701, R9, Zone C6; Remove orientation marks from all SAR Orientation marks are not needed for safe No990-702, R8, Zone F6; drawings, and from SAR Chapter 7, pages use of the package.990-705, R7, Zone E5; 7-5, 7-10, and 7-15.

990-710, R2, Zones E4& D7

2 990-702, R8, Zone C4 Revise SAR drawing to show 13.25 inches The stress analysis of the drain pipe has Yesfor drain pipe shorter leg dimension. been documented in SAR Section 2.10.5.

Initially the stress analysis of a 12 inchlong drain pipe was documented inSection 2.10.5 of Revision 1 of the SAR.The SAR section was revised to evaluatea 13.75 inch long drain pipe in Revision 5for fabrication flexibility. Comparison ofthe results show that while thedisplacement controlled stresses (Table2.10.5-2), secondary stresses, are lowerfor the 13.75 inch long pipe, the primaryand bounding stresses (Section 2.10.5.7and Table 2.10.5-4) are higher for the13.75 in long pipe. The length of the 13.25inch is enveloped by the two analyses andthe bounding stress occurs when the drainpipe is 13.75 inches long. Thus, nochange to the SAR analysis is necessary.

3 990-703, R10, Parts Revise SAR drawing to state that lead See the evaluation directly below. NoList, Item 27 conforms to ASTM B29, without specifying

a grade.

Page 1 of 4

Enclosure 1 to E-38861SAR Proposed Page Changes, Description, and Justification

Justification for Revision Item #3: There is no effect on shielding, thermal, or differential thermal expansion as a result ofthe difference between Chemical grade and Corroding grade lead. There is no literature to indicate that the thermalconductivity, density, or coefficient of thermal expansion is different for these materials. The material properties of leadused for the structural analysis are shown in Table 2.10.1-1 B of the SAR. These are the modulus of elasticity, 27750 psi,and a quasi-static true stress strain curve for lead in compression used for end drop lead slump evaluation. The modulusof elasticity was derived in reference 1, section 3.2, from a stress strain curve of reference 2 for pure lead. The stressstrain curve used for the lead slump evaluations is taken from reference 3, which used ASTM B29 chemicallead. Reference 4 evaluates lead properties, and finds while the addition of 0.04-0.08% copper could in principlestrengthen the chemical lead, there is a lack of agreement between various researchers, and that the high strain ratetesting shows large error and unpredictable results. Therefore with the presently available data, there is no evidence thatthe substitution of corroding lead for chemical lead would have an adverse effect on the end drop stress analysis of the TN-RAM cask.References:

1. NUREG/CR-2018, A comparison of Analytical Techniques for Analyzing a Nuclear-Spent-Fuel Shipping CaskSubjected to an End-On Impact

2. Baumeister and Marks, Standard Handbook for Mechanical Engineers, McGraw-Hill, 19673. J.H Evans, Structural Analysis of Shipping Casks, Experimental Studies of the Stress-Strain Properties of Lead

Under Specified Impact Conditions, ORNL-TM-1312 volume 8, 19764. Rack and Knorovsky, An Assessment of Stress-Strain Data Suitable for Finite-Element Elastic-Plastic Analysis of

Shipping Containers, NUREG/CR-0481

I Containment

Boundary?

SAR Dwg Ref. Revision Justification YIN4 990-703, R10, Zone F4 Revise the SAR drawing to remove the This non-containment, non-structural weld No

requirement to PT inspect this weld. does not require PT inspection.Further, in the Parts List, remove the stocklength from item 10 (drain pipe) and item29 (drain sleeve), since these dimensionscan be calculated as necessary.

Page 2 of 4

Enclosure 1 to E-38861SAR Proposed Page Changes, Description, and Justification

IContainment

Boundary?

Y/NSAR Dwg Ref. Revision Justification-, I 9 9-

5 990-703, R10, ZoneD/E-6/7;990-702, R8, Zone H6

a) Revise the SAR drawing (Detail F) toremove the 35.00 and 36.50 dimensionsand show the 0.75 inch thickness asminimum.b) Revise figure to show the weldpreparation is not made on the upperforging, and remove redundant 300chamfer.c) Revise the weld symbol on 990-702,Zone H6, to show a CJP weld between theshell flange ring and outer shell, andremove the 150 weld preparationspecification from Zone H5.

These changes do not alter the design ofthe cask, and consequently have no affecton the structural or shielding functions.They clarify that a CJP weld shall be used,without unnecessary joint preparationdetail.

Yes

6 990-704, R6, Zone C7 Revise the SAR drawing to show that the The diameter of the fitting and Yesdiameter of the fitting is 4.00 inches corresponding weld have no safetymaximum. significance.

7 990-704, R6, Zone H7 Add a view to the SAR drawing to show Bolt lugs constructed using a CJP weld Noand Zone A/B-7/8 the welded lug option. have the same strength as a one-piece

type, and will have no effect on structuralbehavior.

8 990-704, R6, Zone F8 Revise the SAR drawing to state that the The actual location of the weld on the Noand Zone C2 thermal shield shell weld location is thermal shield outer shell segments which

optional, and remove the 4.25-inch fit around the impact limiter lugs will havedimension. no effect on its safety function.

9 990-705, R7, Parts List Revise the SAR drawing to show optional Optional use of the ASTM A240/A479, NoItem 20 and 990-710, washer materials as ASTM A177/A666, UNS 21800 (Nitronic 60) material will notR2, Parts List Item 20 half hard material, OR ASTM A240/A479, degrade the function of the bolting washer.

UNS 21800.

Page 3 of 4

Enclosure 1 to E-38861SAR Proposed Page Changes, Description, and Justification

I ContainmentBoundary?

Y/N-U

SAR Dwg Ref. Revision Justification10 990-705, R7, Zone C8 Revise the SAR drawing to state that up to Using threaded plugs to fill the 3 extra lid Yes

and Zone C1 3 mislocated lid lifting holes may be lifting holes will not have a significantrepaired by installing a threaded plug effect on the structural or shieldingmade of ASTM Type 304 material, ground function of the closure lid. This option isflush to the lid surface, applicable to Unit limited to the existing cask only.One only.

11 990-708, R8, Zone B7 Revise the SAR drawing to optionally The option to close the lower end of the Noand Zone A6 allow the bolting boss to have a lower end bolting boss inside the impact limiters by a

closed off by a welded cover, welded cap has no effect on the safetyfunction of the impact limiters.

12 990-710, R1, Parts Revise the Material Description from Editorial Change, "Condition N1100" is not YesList, Item 19 (Material "ASTM A-564, TP 630 Condition N1100" listed in ASTM A-564. The correctDescription) to "ASTM A-564, TP 630 Condition condition is "Condition H 1100."

Hi 100."13 990-703, R9, Zone E8 Remove the 300 dimension for the chamfer This change does not alter the design of Yes

in Detail F of drawing 990-703 the cask, and consequently has no effecton the structural or shielding functions. Thechamfer is currently over constrained with 3dimensions (.22", .38" and 30')

Page 4 of 4

Non-Proprietary

SAFETY ANALYSIS REPORTfor the

TN-RAM

E-1 0621

June 2014

AREVA Inc.7135 Minstrel Way, Suite 300

Columbia, Maryland 21045

I

Rev. 12 I

TN-RAM SARREVISION LOG

E-10621

Rev. No. Date Description12 6/10/14 Revised pages as follows:

SAR cover pageSAR page 1-14SAR pages 7-5, 7-10, 7-15

New page as follows:Revision log page 4

Revised drawings as follows:Drawing 990-701Drawing 990-702Drawing 990- 703Drawing 990- 704Drawing 990- 705Drawing 990- 708Drawing 990-710

New drawings as follows:none

4

Rev. 12 1

1.3 Appendix

TN-RAM DRAWINGS / DOCUMENTS

DWG/DOC'TNO.

990-701

990-702

990-703

990-704

990-705

990-706

990-707

990-708

990-709

990-710

E-10615

TITLE REVISION

TN-RAM Packaging Assembly

Shell Assembly

Shell Parts List & Details

Shell Details

Lid Assembly & Parts List

Lid Details

Impact Limiter Assembly

Impact Limiter Details & Parts List

Impact Limiter Attachment Bolt

Optional Lid Details

Lead Pouring Requirements

9

8

10

6

7

4

4

8

2

2

0

1-14

C-1413 Rev. 12 1

7.1.2.16 Transfer the lid to a position directly over the cask cavity. Establish correct lid

orientation and lower the lid until fully seated. Visually verify proper lid installation.

7.1.2.17 Continue lowering the lift beam(s) and engage the lift beam(s) to the cask.

7.1.2.18 Raise the cask to the pool surface, survey the cask for safe radiation levels and check

that the lid is properly seated. Wash down exposed cask surfaces and lift beam

surfaces with clean water.

7.1.2.19 Install two or more lid bolts hand tight.

7.1.2.20 Slowly remove the cask from the pool while thoroughly washing all exposed surfaces

with a clean water spray.

7.1.2.21 Move the cask to the preparation area.

7.1.2.22 Disengage the lid lifting attachments and lift beam(s).

7.1.2.23 Survey and decontaminate the cask surfaces as required to permit safe working

conditions.

7.1.2.24 Inspect the lid bolts. Replace defective bolts and note any defect indications on the

cask loading report. Apply a light coating of an approved lubricant to the bolt threads

and install all 16 lid bolts. Tighten to hand tight. Torque all lid bolts to 950 ±50 ft-

lbs. in several stages using an approved torquing sequence.

7-5

C-1413 Rev. 12 I

7.1.3.15 Inspect the O-rings in the lid for damage and replace if defects are noted, with new

o-rings which have been determined to be free of defects and have a current shelf

life, in accordance with the following. Record inspection results on the cask loading

report.

7.1.3.15.1 Remove the defective 0-ring.

7.1.3.15.2 Clean the O-ring groove.

7.1.3.15.3 Inspect the new O-ring to determine that it is free of defects.

7.1.3.15.4 Position the O-ring uniformly around the lid over the O-ring groove.

7.1.3.15.5 Press lightly at four diametrically opposite positions.

7.1.3.15.6 Continue to press the O-ring at diametrically opposite positions until it

is fully seated in the gasket groove.

7.1.3.15.7 Inspect the new O-ring to verify that it is free of defects. Record

inspection results on the cask loading report.

7.1.3.16 Attach the lid lifting attachment to cask lid.

7.1.3.17 Transfer the lid to a position directly over the cask cavity. Establish correct lid

orientation. Install the lid. Visually verify that the lid is correctly oriented and fully

seated.

7.1.3.18 Move the cask to the preparation area.

7.1.3.19 Disengage the lid lifting attachments and lift beam(s).

7.1.3.20 Survey and decontaminate the cask surfaces as required to permit safe working

conditions.

7.1.3.21 Inspect the lid bolts. Replace defective bolts and note any defect indications on the

cask loading report. Apply a light coating of an approved lubricant to the bolt

threads and install all 16 lid bolts. Tighten to hand tight. Torque all lid bolts to 950

±50 ft-lbs. in several stages using an approved torquing sequence.

7-10

G-1413 Rev. 12 1

7.2.2.12 Engage the lift beam(s) to the cask.

7.2.2.13 Lift the cask from the preparation area and move to the unloading area.

7.2.2.14 Disengage the lift beam(s) from the cask.

7.2.2.15 Attach a suitable crane to lid lifting sling and remove the lid.

7.2.2.16 Install the cask seal surface protective cover.

7.2.2.17 Remove the shield disk.

NOTE: Perform the following steps remotely using manipulator crane, appropriate remote

tooling, viewing equipment and personnel radiation protection as appropriate for the

facility.

7.2.2.18 Using the appropriate handling tool and hoist, unload the cask contents into the

disposal area in accordance with site-approved procedures.

NOTE: The following steps may be performed hands-on.

7.2.2.19 Replace the shield disk.

7.2.2.20 Remove the cask seal surface protective cover.

7.2.2.21 Move cask to the preparation area for lid installation.

7.2.2.22 Attach the lid lifting attachment to the cask lid.

7.2.2.23 Transfer the lid to a position directly over the cask cavity. Establish correct lid

orientation and lower the lid until fully seated. Visually verify proper lid installation.

7.2.2.24 Disengage the lid lifting attachments and lift beam(s).

7.2.2.25 Survey and decontaminate the cask surfaces as required to permit safe working

conditions.

7-15

Enclosure 5 to E-38861

AFFIDAVIT PURSUANTTO 10 CFR 2.390

* AREVA Inc.State of Maryland ) SS.County of Howard )

I, Paul Triska, depose and say that I am a Vice President of AREVA Inc., duly authorized to execute this affidavit,and have reviewed or caused to have reviewed the information that is identified as proprietary and referenced in thefollowing paragraph. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.390 of theCommission's regulations for withholding this information.

The information for which proprietary treatment is sought is contained in Enclosures 2 and 3, as listed below:

* Engineering Evaluation, Number 49944-EE-001, Revision 0

* The following drawings from CoC 9233 Safety Analysis Report:

990-701 Revision 9 990-705 Revision 7990-703 Revision 10 990-708 Revision 8990-704 Revision 6 990-710 Revision 2

I have personal knowledge of the criteria and procedures utilized by AREVA Inc., in designating information as atrade secret, privileged or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commission's regulations, the following isfurnished for consideration by the Commission in determining whether the information sought to be withheld from publicdisclosure, included in the above referenced document, should be withheld.

1) The information sought to be withheld from public disclosure involves an engineering evaluation and portions of asafety analysis report, related to the design of the TN-RAM transportation packaging system, which are owned andhave been held in confidence by AREVA Inc.

2) The information is of a type customarily held in confidence by AREVA Inc., and not customarily disclosed to thepublic. AREVA Inc., has a rational basis for determining the types of information customarily held in confidence byit.

3) Public disclosure of the information is likely to cause substantial harm to the competitive position of AREVA Inc.,because the information is related to the design and licensing approach of transport packaging, the application ofwhich provides a competitive economic advantage. The availability of such information to competitors would enablethem to modify their product to better compete with AREVA Inc., take marketing or other actions to improve theirproduct's position or impair the position of AREVA Inc.'s product, and avoid developing similar data and analyses insupport of their processes, methods or apparatus.

Further the deponent sayeth not.

Paul TriskaVice President, AREVA Inc.

Subscribed and sworn to me before this I Ph day of Jun_ D-

ot Publi TA o= • •. •: -

My Commission Expires 1 / "- /