ML19058A281

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Application for Amendment 1 to NUHOMS Eos Certificate of Compliance No. 1042, Rev. 3 - Response to Request for Additional Information. with Enclosure 1: Affidavit
ML19058A281
Person / Time
Site: 07201042
Issue date: 02/19/2019
From: Narayanan P
Orano USA, TN Americas LLC
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML19058A410 List:
References
E-53166
Download: ML19058A281 (4)
v • d • e


Text

0 orano Columbia Office 7135 Minstrel Way Columbia, MD 21045 Tel: (410) 910-6900

@Orano_USA U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 February 19, 2019 E-53166

Subject:

Application for Amendment 1 to NUHOMS EOS Certificate of Compliance No. 1042, Revision 3 -

Response to Request* for Additional Information (Docket No. 72-1042, CAC No. 001028, EPID:

L-2018-LLA-0043)

References:

Letter from Christian Jacobs (NRC) to Prakash Narayanan (TN Americas LLC), "TN Americas LLC Application for Certificate of Compliance No. 1042, Amendment No. 1, to NU HOMS EOS System (Docket No. 72-1042, CAC No. 001028, EPID: L-2018-LLA-0043) - Request for Additional Information," dated December 21, 2018.

Letter from Christian Jacobs (NRC) to Prakash Narayanan (TN Americas LLC), "TN Americas LLC Application for Certificate of Compliance No. 1042, Amendment No. 1, to NU HOMS EOS System.(Docket No. 72-1042, CAC No. 001028, EPID: L-2018-LLA-0043) - Request for Additional Information Part 2," dated January 30, 2019.

This submittal provides responses to the Request for Additional Information (RAI) forwarded by the letters referenced above. Enclosure 2 of this submittal provides a response to each of the RAI items. Each RAI response has a section stating the impact of the response on the application, for both the Technical Specifications (TS) and the Updated Final Safety Analysis Report (UFSAR), indicating which sections, tables, figures, or drawings have been changed. Enclosure 3 provides a public version of Enclosure 2. Enclosure 4 provides a description of additional changes to the UFSAR and TS not associated with the RAI responses. Enclosure 5 provides a listing of CoC 1042 Amendment 1 TS changes resulting from the RAls and the additional changes per Enclosure 4, and their associated justifications. Enclosure 6 provides a list of changed TS and UFSAR pages by this Amendment 1 Revision 3

UH.55Z Ip Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal
t)H5>S document is decontrolled.

Document Control Desk February 19, 2019 E-53166 Page 2 of 3 submittal. Enclosure 7 provides a complete rev1s1on to the TS, denoted as Amendment 1 Application, Revision 3. Enclosure 8 provides the proprietary version of the UFSAR changed pages and drawings, with the public version of the UFSAR changed pages provided in. Enclosure 1 O provides a copy of Section D to Chapter 6 of Appendix P from the CoC 1004 UFSAR, Revision 16, as part of the response to RAI 7-3 and RAI 7-4. Enclosure 11 provides a listing of the computer files associated with the RAI responses. Enclosure 12 is a computer hard drive containing the computer files listed in Enclosure 11. Enclosure 13 provides a copy of Framatome document FS1-003016, Revision 9 as part of the response to RAI 6-11. 4 provides a copy of AREVA Inc. document 51-9230070-000, Revision Oas part of the response to RAI 8-7. Enclosures 13 and 14 are entirely proprietary and no public version is provided.

For the UFSAR, replacement and new Amendment 1, Revision 3 pages and drawings are provided. The pages are annotated as "72-1042 Amendment 1, Revision 3, February 2019" with changes indicated by italicized text and revision bars. The new changes associated with the RAI responses are further annotated with rectangles enclosing the changed areas and an indication of which RAI is assoc\\ated with the changes. The new changes associated with Enclosure 4 are further annotated with rectangles enclosing the changed areas and an indication that Enclosure 4 is associated with the changes.

For the TS, Amendment 1 changes on Revision 3 pages are indicated by italicized text, revision bars, and outlined in red to distinguish them from the changes proposed in Revisions 0, 1 and 2 of the Amendment 1 application.

Certain portions of this submittal include proprietary information, which may not be used for any purpose other than to support the NRC staff's review of the application. In accordance with 10 CFR 2.390, TN Americas LLC is providing an affidavit (Enclosure 1) specifically requesting that this proprietary information be withheld from public disclosure. The submittal also includes security-related information. Because Enclosure 12 is an entirely proprietary computer hard drive, no public version is provided.

TN Americas LLC is prepared to meet with the staff to resolve any additional questions the staff might have. Should the NRC staff require additional information to support review of this application, please contact Mr. Glenn Mathues by telephone at (410) 910-6538, or by email at Glenn.Mathues@orano.group.

Sincerely, 04~~

0 f)

Prakash Narayanan Chief Technical Officer

Document Control Desk February 19, 2019 cc:

Chris Jacobs (NRG SFM) as follows:

One paper copy of this cover letter E-53166 Page 3 of 3 Six computer disks containing this cover letter and Enclosures 1 through 11, 13 and 14 One computer hard drive with Enclosure 12

Enclosures:

1. Affidavit Pursuant to 1 O CFR 2.390 ---
2. Responses to Request for Additional Information (Proprietary Version)
3. Responses to Request for Additional Information (Public Version)..---
4. Additional Changes Not Associated with the RAls,..-
5. List of New CoC 1042 Amendment 1 Technical Specification Changes and Justifications/
6. List of Changed TS and UFSAR Pages Involved in CoC 1042 Amendment 1, Revision 3 --
7. Coe 1042 Proposed Amendment 1, Revision 3 Technical Specifications ---
8. CoC 1042 Amendment 1, Revision 3 UFSAR Changed Pages (Proprietary and Security-Related Version) /
9. CoC 1042 Amendment 1, Revision 3 UFSAR Changed Pages (Public Version),
10. CoC 1004 UFSAR Revision 16Appendix P, Chapter 6, Section D,,,.
11. Li~ting of Computer Files Contained in Enclosure 12,,,-
12. Computer files Associated with CoC 1042 Amendment 1, Revision 3 (Proprietary),,.

(One computer hard drive)

13. Framatome Document FS1-0030165, Revision 9 (Proprietary) y
14. AREVA Inc. Document 51-9230070-000, Revision O (Proprietary),,--

, I

TN Americas LLC State of Maryland County of Howard

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AFFIDAVIT PURSUANT TO 10 CFR 2.390 to E-53166 I, Prakash Narayanan, depose and say that I am Chief Technical Officer of TN Americas LLC, duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information that is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.390 of the Commission's regulations for withholding this information.

The information for which proprietary treatment is sought is contained in Enclosures 2, 8, 12, 13 and 14, as listed below:

  • - Portions of certain responses to Request for Additional Information (RAI)
  • 2 - Certain computer files associated with CoC 1042 Amendment l, Revision 3
  • 3 -Framatome DocumentFSl-0030165, Revision 9
  • 4-AREVA Inc. Document 51-9230070-000, Revision 0 These documents have been appropriately designated as propri~tary.

I have personal knowledge of the criteria and procedures utilized by TN Americas LLC in designating information as a trade 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 is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.

1) The information sought to be withheld from public disclosure involves portions of the RAis and responses, Framatome Document FSl-0030165, Revision 9, AREVA Inc. Document 51-9230070-000, Revision 0, UFSAR and analysis computer files, all related to the design of the NUHOMS EOS System, which are owned and have been held in confidence by TN Americas LLC.
2) The information is of a type customarily held in confidence by TN Americas LLC, and not customarily disclosed to the public. TN Americas LLC has a rational basis for determining the types of information customarily held in confidence by it.
3) Public disclosure of the information is likely to cause substantial harm to the competitive position of TN Americas LLC, because the information consists of descriptions of the design and analysis of dry spent 'fuel storage systems, the application of which provide a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with TN Americas LLC, take marketing or other actions to improve their product's position or impair the position of TN Americas LLC's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

Further the deponent sayeth not. -~-~

Prakash Narayanan Chief Technical Officer, TN Americas LLC fore me this 19th day of February, 2019.

My Commission Expires /0 I I l<. I J.J_

RONDA JONES NOTARY PUBLIC STATE OF MARYLAND My Commission Expires October 16, 2019 Page 1 of 1

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