Licensing the High Burnup Research Cask Transportation Package – Lessons Learned

Orano implemented an innovative approach to satisfy the regulatory requirements and obtain the Certificate of Compliance to transport the High Burnup Research Cask (HBU).

AUTHORS
John McEntire PMP, Donald McGee PMP, and Sven Bader PhD
Orano Federal Services

PRESENTING
March 12, 2025 - Entire white paper will be posted here
Waste Management Symposia

ABSTRACT
Obtaining a Certificate of Compliance (CoC) issued by the U.S. Nuclear Regulatory Commission (NRC) for the High Burnup Research Cask (“the Cask”) transportation package presented unique challenges. In accordance with 10 CFR Part 71, Orano implemented an innovative approach to satisfy the regulatory requirements and obtain the CoC. The Cask is an Orano TN Americas TN-32B vertical dry storage system with a modified closure lid allowing for the insertion of thermocouples to measure temperature at predetermined locations from within the cask loaded with used fuel. The Cask contains thirty-two high burnup (HBU) used fuel assemblies that were selected specifically for conducting research to understand aging mechanisms and behavior of HBU used fuel during dry storage conditions. After about a 10-year storage period, the Cask with its contents will be shipped to a U.S. fuel examination facility to be opened while remaining dry, allowing the used fuel to be extracted and comparative analyses to be conducted against “sibling” donor used fuel pins, which are representative of the used fuel loaded in the Cask and established a baseline for analyses. Future analyses of the HBU used fuel loaded in the Cask will provide data to support regulations and guidance for HBU used fuel aging management programs and inform stakeholders on the continued safe interim and long-term storage, transportation, and disposal options for this fuel.

Several design enhancements were incorporated prior to loading the Cask with HBU used fuel to prepare it for a future shipment without having to potentially re-open before shipping. While these enhancements helped resolve most transport licensing concerns with the original cask design, not all challenges could have been anticipated without beginning the detailed analyses and presenting the licensing approach for this package with its unique modifications to the NRC reviewers. Orano began transport licensing activities immediately following the loading of the Cask in November 2017. During development of the package design and licensing approach, several challenges presented themselves to Orano, including selection of impact absorber material and consideration of use of the installed thermocouples beyond the future transport. Addressing these challenges resulted in identifying special tests needed to demonstrate the thermocouple lance containment function during hypothetical accident conditions of transport. Other challenges in project management occurred during the work, including the onset of the COVID-19 pandemic and the need for prioritizing other transport package reviews for licensing by the NRC in parallel with the Cask licensing. The initial application was completed and transmitted to the NRC for acceptance review in August 2021. The NRC’s detailed application review began in October 2021 and Orano received a CoC for transport in July 2024.

Transporting the Cask in the 2027 timeframe is extremely important to ensure that continued storage license commitments (i.e., tollgates) are achieved. The first commitments are due in April 2028, when both Xcel Energy’s Prairie Island Nuclear Generating Plant and Constellation’s Calvert Cliffs Nuclear Power Plant rely on the initial data from the Cask to be granted a storage license extension. This same commitment was subsequently extended to all commercial nuclear facilities across the U.S.

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