ML19175A284
| ML19175A284 | |
| Person / Time | |
|---|---|
| Site: | 07201004 |
| Issue date: | 06/21/2019 |
| From: | Shaw D TN Americas LLC |
| To: | Garcia-Santos N Spent Fuel Licensing Branch |
| Garcia-Santos N | |
| Shared Package | |
| ML19176A010 | List: |
| References | |
| Download: ML19175A284 (6) | |
Text
From:
SHAW Donis (ORANO)
To:
Garcia Santos, Norma Cc:
McKirgan, John; Tate, Travis; YATES Douglas (ORANO); MIGLIORE Rick (ORANO); NARAYANAN Prakash (ORANO)
Subject:
[External_Sender] RE: RE: RE: Amendment 16 for the Model No. NUHOMS - Request to Supplement Request for Additional Information after Telephone Call on 5/22/2019 Date:
Friday, June 21, 2019 7:50:02 AM Attachments:
image002.png image003.png image004.png image005.png image006.png TN Example Input to NRC for CoC 1004 Amd 16 Item Sh-1 FQT Discussions 21_June_2019.pdf
- Norma,
Per the 28 June item highlighted in green in my June 17th email below, I am happy to attach, one week ahead of our estimated schedule, TNs example of what we have in mind for item Sh-1 and the FQT situation. If NRC staff reviews this, understands it, and does not feel a conference call is needed, please let me know. Otherwise, TN will certainly support one or more calls. We are available next week Monday through Friday, any time of day.
- Regards,
Don Shaw
From: Garcia Santos, Norma [1]
Sent: Monday, June 17, 2019 2:24 PM To: SHAW Donis (ORN-NPS)
Cc: McKirgan, John; Tate, Travis; YATES Douglas (ORN-RE)
Subject:
RE: RE: RE: Amendment 16 for the Model No. NUHOMS - Request to Supplement Request for Additional Information after Telephone Call on 5/22/2019
Security Notice: Please be aware that this email was sent by an external sender.
Good afternoon Don,
This is helpful. I will develop a schedule based on the information that you are providing, staff availability, etc.
Have a nice rest of the day, Norma
From: SHAW Donis (ORANO) <don.shaw@orano.group>
Sent: Monday, June 17, 2019 2:17 PM To: Garcia Santos, Norma <Norma.GarciaSantos@nrc.gov>
Cc: McKirgan, John <John.McKirgan@nrc.gov>; Tate, Travis <Travis.Tate@nrc.gov>; YATES Douglas (ORANO)
<Douglas.Yates@orano.group>
Subject:
[External_Sender] RE: RE: Amendment 16 for the Model No. NUHOMS - Request to Supplement Request for Additional Information after Telephone Call on 5/22/2019
- Norma,
I received your Fri 6/14/2019 10:32 email, per the snip below. Thank you for that. Regarding your request for an estimated time frame in which NRC should be receiving the response (see yellow in your 5:37 AM email further below), this situation will have to evolve, based on the discussions, but if you want my best estimate at this time, it would be as follows:
28 June - TN provides the example of what we have in mind for item Sh-1.
4th of July week - NRC considers the input from TN and schedules a call for early the week of July 8th.
17 July - Even if two calls are needed, NRC and TN reach general agreement.
31 July - TN provides responses to all three requests, with changed CoC/ITE/TS pages, but not UFSAR pages, until Sh-1 is found acceptable.
27 Sept - TN provides the full set of CoC/ITE/TS/ASME Alts/(changed) UFSAR Pages to NRC.
I hope this helps,
Don
From: Garcia Santos, Norma [2]
Sent: Friday, June 14, 2019 5:37 AM To: SHAW Donis (ORN-NPS)
Cc: McKirgan, John; Tate, Travis
Subject:
RE: RE: Amendment 16 for the Model No. NUHOMS - Request to Supplement Request for Additional Information after Telephone Call on 5/22/2019
Security Notice: Please be aware that this email was sent by an external sender.
Good afternoon,
Thanks for your prompt response. I will pass this email to the appropriate staff and will let you know the feedback that I receive. Then, I will appreciate that you provide an estimated time frame in which we should be receiving the response.
Have a nice rest of the day, Norma
From: SHAW Donis (ORANO) <don.shaw@orano.group>
Sent: Thursday, June 13, 2019 3:22 PM To: Garcia Santos, Norma <Norma.GarciaSantos@nrc.gov>
Cc: McKirgan, John <John.McKirgan@nrc.gov>; Tate, Travis <Travis.Tate@nrc.gov>; Araguas, Christian
<Christian.Araguas@nrc.gov>; Diaz-Sanabria, Yoira <Yoira.Diaz-Sanabria@nrc.gov>; Li, Zhian <Zhian.Li@nrc.gov>;
Piotter, Jason <Jason.Piotter@nrc.gov>; Davis, Marlone <Marlone.Davis@nrc.gov>; Chung, Donald
<Donald.Chung@nrc.gov>; SHIH Yueh Kan (ORANO) <peter.shih@orano.group>; HAROON Raheel (ORANO)
<raheel.haroon@orano.group>; NARAYANAN Prakash (ORANO) <prakash.narayanan@orano.group>; YATES Douglas (ORANO) <Douglas.Yates@orano.group>; MIGLIORE Rick (ORANO) <rick.migliore@orano.group>
Subject:
[External_Sender] RE: Amendment 16 for the Model No. NUHOMS - Request to Supplement Request for Additional Information after Telephone Call on 5/22/2019
- Norma,
TN has assessed the three requests to supplement the request for additional information. We find items Th-1 and Op-1 straightforward and have not concerns or questions regarding those two. For item Sh-1, TN would like to proceed as follows. We certainly welcome your feedback.
- TN will develop an example of what we have in mind for item Sh-1.
- We are hopeful that an approach very similar to that used for CoC 1042 EOS RAI 6-7 will also work here, but cannot say for sure until we get into the specific details.
- We are also hopeful that the example will be ready for NRC consideration on or before June 28th, but many factors could impact this.
- We will then wait until NRC is ready for a conference call to discuss the approach, with a goal of reaching a general agreement.
The reason we want to proceed cautiously on Sh-1 is that there are a great many fuel qualifications tables in CoC 1004 and the change package for the technical specifications and the updated final safety analysis report will very likely be quite large and involve a great many hours to process.
Best regards,
Don
From: SHAW Donis (ORN-NPS)
Sent: Wednesday, June 12, 2019 12:23 PM To: 'Garcia Santos, Norma' Cc: McKirgan, John; Tate, Travis; Araguas, Christian; Diaz-Sanabria, Yoira; Li, Zhian; Piotter, Jason; Davis, Marlone; Chung, Donald; SHIH Peter (TRANSNUCLEAR INC) (peter.shih@areva.com); HAROON Raheel (TRANSNUCLEAR INC)
(raheel.haroon@areva.com); NARAYANAN Prakash (TRANSNUCLEAR INC) (prakash.narayanan@areva.com); YATES Douglas (ORN-RE); MIGLIORE Rick (ORN-NPS)
Subject:
RE: Amendment 16 for the Model No. NUHOMS - Request to Supplement Request for Additional Information after Telephone Call on 5/22/2019
- Norma,
I want to acknowledge receipt of your email below. TN is assessing this request and I will communicate our estimate for providing the requested information. I believe I will have that estimate today or tomorrow, but if we feel we need additional time to make this determination, I will communicate that to you tomorrow, June 13th.
- Regards,
Don
Don Shaw Licensing Manager TN Americas LLC 7135 Minstrel Way, Suite 300 Columbia, Maryland 21045 USA Phone: 410.910.6878 Fax: 410.910.6902 Mobile: 240.565.3452 don.shaw@orano.group
www.orano.group
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From: Garcia Santos, Norma [3]
Sent: Tuesday, June 11, 2019 4:57 PM To: SHAW Donis (ORN-NPS)
Cc: McKirgan, John; Tate, Travis; Araguas, Christian; Diaz-Sanabria, Yoira; Li, Zhian; Piotter, Jason; Davis, Marlone; Chung, Donald
Subject:
Amendment 16 for the Model No. NUHOMS - Request to Supplement Request for Additional Information after Telephone Call on 5/22/2019
Security Notice: Please be aware that this email was sent by an external sender.
Dear Mr. Shaw:
By letter dated June 7, 2018 [Agencywide Documents Access and Management System (ADAMS)
Accession No. ML18162A093] and e-mail dated February 27, 2019 (ADAMS Accession No. ML19084A083), Orano-TN (Orano or the applicant) submitted supplement to a response to a request for additional information (RAI) and to its application in accordance with 10CFRPart 72. The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the information provided and concluded that additional information is needed to clarify the following items:
Th-1 Provide a revised completion time (based on a blocked vent condition), in addition to the short-term actions that must be completed to return the system to normal operation. (See ADAMS Accession No. ML19084A083)
The following items apply to the technical specification (TS) 3.1.4 proposed in Amendment 16:
- 1) Action D is initiated if
a) A.2 (air vents blocked) cannot be completed within 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> OR If item A.2 is tripped, by default, the air vents are blocked this assumption is no longer valid. This makes the 30day completion time unacceptable UNLESS is the applicant demonstrates that the steady state temperatures of the fuel cladding and the concrete remain below limits.
b) C.2 (unexplained temperature excursion, return to normal operation) cannot be completed within 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.
If item C.2 is tripped, then Action D must provide a remedy which immediately (or within a credible timeframe) restores the system to normal operation. The 30day time limit has not been shown to be the limiting time frame for this restoration.
- 2) The basis for the time limit of 30 days for completing Action D is based on the air vents being unblocked.
In the former TS 3.1.4 (Amendment 15), the 30day time limit was the time allowed for a calculation to be performed, not for returning the system to normal conditions. The shortterm action for returning the system to normal conditions was either unloading into a Transfer Cask or returning the DSC to the fuel building.
Sh-1 Provide the following information:
- a. the bounding burn up, enrichment, and cooling time (BECT) combination(s), which represents the design basis source term (e.g., strengths and spectra of the neutron and gamma emitted from the spent fuel) to be defined in the TS in place of the content definition currently provided by the fuel qualification tables (FQTs), and
- b. the revised technical specifications of the Model No. NUHOMS with the information requested in this question.
In the proposed amendment 16 to Certificate of Compliance (CoC) No. 1004 for the Model No.
NUHOMS storage system, the applicant proposed to relocate the fuel qualifications tables (FQTs) from the technical specifications to the final safety analysis report. Nevertheless, the applicant did not provide the fuel parameters that would define the allowable spent fuel contents with respect to the design basis source terms to be included in the technical specifications for this storage system instead of the fuel qualification tables.
In terms of the shielding design, 10 CFR 72.234(a) requires that the cask design meets the requirements of 10 CFR 72.236. Specifically, 10 CFR 72.236(d) requires that cask design meet the dose limits of 10 CFR 72.104 and 72.106. In accordance with the regulatory requirement of 10 CFR 72.236(a), specifications must be provided for the spent fuel to be stored in the storage cask.
Based on the study published in NUREG/CR-6716, Recommendations on Fuel Parameters for Standard Technical Specifications for Spent Fuel Storage Casks, and NUREG/CR-6802, A Quantitative Impact Assessment of Hypothetical Spent Fuel Reconfiguration in Spent Fuel Storage Casks and Transportation Packages, the source terms, among other irradiation parameters, are dependent primarily on the BECT. Because a wide variety of different combinations of BECT may produce the same source terms, it is necessary to accurately define the allowable BECTs for the staff to reach a reasonable assurance finding that the source terms from the allowable fuel assemblies are within the bound of the design basis source terms.
NUREG/CR-6716 includes a study on the sensitivities of the neutron and gamma source terms of the spent fuel against all major parameters that impact the source terms. The study found that the fuel parameters with most significant impact on dose rate are fuel burnup, enrichment, and cooling time. This study recommends including these parameters in standard TSs.
The recommendation is based on a balanced consideration of the parameters that are important to safety and appropriate flexibility for the applicant to make changes to the allowed contents.
Specifically, NUREG/CR-6716 states the following:
[T] the objective is to replace the current detailed TS with more general Standard Technical Specifications (STS) that concentrate control on those fuel parameters that are most important to maintaining safety. The remaining fuel parameters are of lesser importance and would be handled under the Section 72.48 process, which allows the licensees to change those parameters by performing additional safety analyses to update the FSAR.
This information is needed to determine compliance with the regulatory requirements 10 CFR 72.234(a) and (d), 72.104, and 72.106.
Op-1 Clarify the following:
- a. if the time limits identified in LCO 3.1.3 incorporate or cover the use of the OS197FC (OS197L), and
- b. if OS197FC and OS197L are the same.
The staff added Condition No. 5 to the CoC No. 1004 in Amendment 11. In its application for amendment 16 of CoC No. 1004, the applicant proposed to eliminate this condition from the CoC because the applicant considered this condition strictly a notification requirement and covered by LCO 3.1.3. The staff reviewed LCO 3.1.3 and could not determine if the applicant considered the use of the OS197FC transfer cask as part of the actions to initiate active cooling within a specified time limit. Condition No. 5 includes a 30-day period, which the staff has accepted in various applications to address recovery from off-normal and accident conditions.
This information is needed to determine if it meets the evaluation criteria to be maintained in the TS/CoC or move to the Final Safety Analysis Report (FSAR).
On May 22, 2019, the staff held a telephone call with the applicant to discuss questions related to moving the fuel qualification tables to the final safety analysis report (ADAMS Accession No. ML19151A758). The staff also mentioned that there were some questions that need to be resolved. In the May 22 telephone call, the applicant mentioned that it would consider the staffs comments when developing the response to the staffs questions. Please let me know when you will be providing the information requested in this communication.
You may contact me at (301) 415-6999 or by email if you have any questions regarding this review.
Sincerely,
Norma García Santos, Project Manager Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards
Docket No. 72-1004 CAC No. A33009 EPID L-2017-LLA-0112