ML19256A011
| ML19256A011 | |
| Person / Time | |
|---|---|
| Site: | 07109356 |
| Issue date: | 09/11/2019 |
| From: | Cole K NAC International |
| To: | Maureen Wylie NRC/OCFO |
| smh | |
| References | |
| Download: ML19256A011 (11) | |
Text
A NAC INTERNATIONAL September 11, 2019 Ms. Maureen Wylie, Chief Financial Officer Office of the Chief Financial Officer Mail Stop 6 E7 A U.S. Nuclear Regulatory Commission 11545 Rockville Pike Rockville, MD 20852-2738
SUBJECT:
Request for Review and Appeal of Fees
Dear Ms. Wylie:
Atlanta Corporate Headquarters 3930 !:,1st Jrn1es Bridge Rmd, Suite 200 No1 cross, GI\\ 300'):!
!'hone 770-447-1144 F;1.x 770-447-1797 www nJcintl com Pursuant to 10 CFR 170.51 and 10 CFR 15.31, NAC International Inc. ("NAC") hereby notifies the Office of the Chief Financial Officer that it disputes $632,398 in review fees assessed between September 2016 and May 2019 related to Docket No. 71-9356, MAGNATRAN Transportation Package. These fees and the applicable invoices are listed in Enclosure 1. As explained below and in Enclosure 1, NAC considers these fees unfair and inappropriate because they were incurred over an extended period of time due to faulty work in assessing NAC's use of its computer simulation models by the Nuclear Regulatory Commission ("NRC") and its selected contractor
("Contractor") 1* Further, NAC requests that the NRC extend the interest waiver period pending final determination of the existence or amount, if any, of the debt pursuant to 10 CFR 15.37G).
On March 12, 2019, as further discussed herein, NAC learned of an "error" in NRC and Contractor's thermal modeling, which was used during NRC's technical review of NAC's application for an NRC Certificate of Compliance ("CoC") for the MAGNA TRAN Transportation Package. For the thermal modeling, NRC and Contractor used an assumed configuration for the corner geometry between the MAGNA TRAN fuel tubes that was not representative of the physical design of the cask. Contrary to this, Contractor had repeatedly represented that its model was realistic without disclosing relevant details throughout the extended review period - even though NAC had requested this information on several occasions. Based on Contractor's presentations to the NRC, we have now discovered their model contained significant and obvious differences from the physical system and, in comparison, with respect to NAC's models. Contractor's use of an unrepresentative and overly conservative model resulted in a substantial difference ( over 50°F) between Contractor's and NA C's calculations of the peak clad temperature ("PCT").
1 Please note that NAC has attempted in this letter and its Enclosure I to fairly attribute when using the terms "NRC", "Contractor" and "NRC and Contractor", but we acknowledge that in some cases we could not be sure with the information available to us, so we made some inferences and assumptions on whether actions by either or both parties are involved.
ED20190096 Page 1 of 4
Ms. Maureen Wylie, NRC Chief Financial Officer September 11, 2019 Contractor's characterization of this substantial difference in PCT results to the NRC, without disclosing significant and obvious modeling differences to NAC, thus deprived NAC of an opportunity to identify Contractor's suspect modeling differences. Moreover, it was obviously misleading to the NRC, which spawned and amplified NRC's skepticism ofNAC's thermal results going forward by raising doubts about the accuracy or realism of NAC's modeling. This further jeopardized NAC's application by providing no effective path for NAC to reconcile the differences and resolve the issue. In turn, from September 2016 until March 2019, the NRC's doubts and skepticism led to multiple NRC requests for additional information from NAC. This, in tum, brought upon NAC a wasteful, extended review process, delaying the issuance of the MAGNATRAN Transport Cask CoC by approximately two and a half years and resulting in hundreds of thousands of dollars in unnecessary and excessive review fees.
Since NAC first applied on January 19, 2011, for the CoC for the MAGNA TRAN Transportation Package under 10 CFR 71, it has paid $2,004,981 in review fees to the NRC. As shown on, NAC believes that approximately $632,398 of those fees can be attributed to delays and unnecessary rework resulting from the extended review process and the lack of openness and transparency with regard to the Contractor's work.
The NRC established 10 CFR Part 170 to prescribe fees charged for licensing services, inspection services, and special projects rendered by the NRC as authorized under Title V of the Independent Offices Appropriation Act of 1952 (31 U.S.C. § 9701). By law under 31 U.S.C. § 9701, the agency's fees must be "fair and based on (A) the cost to the government; (B) the value of the service or thing to the recipient; (C) public policy or interest served; and (D) other relevant facts."
Given these criteria, NAC should not be required to pay for the fees associated with the use of Contractor's thermal modeling and analysis because it would be unfair and inappropriate based on the relevant facts.
NAC first learned of Contractor's modeling errors at a closed meeting with Contractor and the NRC staff on March 12, 2019. According to presentation slides provided by Contractor (Slides 1-17: "MAGNATRAN Fuel Tube Gap Resolution", which are marked by Contractor as business sensitive and thus not enclosed herewith), Contractor evidently discovered the discrepancies as early as February 2018 (see Contractor slide 8). As shown in the Contractor slides:
The MAGNA TRAN fuel tubes corner geometry (Slide 6) involves two tubes and one gap.
The discrepancy was caused by Contractor's unusual modeling of the basket fuel tube gaps.
Contractor characterized this as a "conservative simplification" (Slide 5, second bullet).
Contractor's modeling configuration consisted of four gaps. This is highly non-physical and produced exaggerated (i.e., materially larger) results when compared to using a realistic (more representative of the actual geometry) configuration for calculations. NAC representatives at the March 12th meeting were greatly surprised at the Contractor's Slide 5 non-physical modeling over-simplification.
ED20190096 Page 2 of 4
Ms. Maureen Wylie, NRC Chief Financial Officer September 11, 2019 In fact, Contractor's model calculated a PCT result of 73°F greater than the result calculated by NAC's model (Slide 8).
Significantly, Contractor acknowledged that "new modeling results" (which were based on Contractor's revised model with a single gap representative of the physical configuration and similar to NAC's modeling) are "similar to the NAC ANSYS model" (Slide 11).
In effect, the Contractor's Slide 11 acknowledgment signaled a concurrence with using NAC's ANSYS model's calculations for NRC's review of the MAGNATRAN application, thereby resolving the confusing discrepancy that had been raised by Contractor to the NRC in September 2016 (see NRC Letter to Fowler, dated September 19, 2016, "
Subject:
Application for the Model No. MAGNATRAN Transportation Package - Fourth Request for Additional Information,"
ADAMS Accession No. ML16264A151). As an illustration of this dramatic turn of events, the NRC issued the CoC swiftly thereafter, on April 5, 2019, without further justification required from NAC. The identification of this fundamental error in Contractor's modeling allowed the NRC to resolve the remaining technical issue promptly and grant the MAGNATRAN CoC, for which NAC is relieved and grateful.
This error in modeling was self-evident once Contractor disclosed it was using four ( 4) basket tubes gaps in its models of the interface between each fuel tube. This was clearly a non-physical and an overly conservative simplification that was not appropriate for comparison - apples-to-apples - to NAC's realistic modeling and calculations as required by the NRC. This error would have been discovered sooner if Contractor had shared this aspect of the model with NAC for review by NAC's expert staff. Contractor's lack of transparency prevented NAC (and, in effect, also the NRC) from discovering the error, leading to extensive RAis, substantial additional modeling, analysis and documentary work for NAC, extended delay in the MAGNA TRAN Transport Cask CoC process and unnecessary additional fee costs. The absence of transparency from NRC and its Contractor about the differences in its model versus NAC's, was a stark departure in NAC's experience from all prior NRC regulatory reviews, where NRC (and its contractors, if utilized) will inform the applicant of the manner in which they have performed alternative modeling and why. This goes to the misleading aspect of the original discrepancy that was being presented to the NRC to reflect adversely on NAC. In this MAGNATRAN case, with respect to the basket tubes interface, the NRC and Contractor did not disclose any details, even when asked directly if there were any differences in their model that could possibly contribute to the large difference in modeling results, until March 12, 2019.
As the foregoing indicates, the facts of this case make it unfair and inappropriate to charge NAC for fees associated with NRC and Contractor thermal modeling to assess the MAGNATRAN application and the associated difficulties of NRC oversight of the Contractor's work. As shown on Enclosure 1, NAC believes that approximately $632,398 of the total fees assessed can be attributed to delays and unnecessary rework. The disappointing lack of disclosure by Contractor until March 12, 2019 of its non-physical geometric models, resulted in significant expenditure and wasteful use of resources to the detriment of the NRC and NAC. Contractor's failure to disclose its modeling assumptions, until March 2019, led to wasteful and improper application of resources ED20190096 Page 3 of 4
Ms. Maureen Wylie, NRC Chief Financial Officer September 11, 2019 for the underlying purpose of Contractor's performing independent confirmatory calculations of the MAGNA TRAN system for the NRC.
In addition to two and a half years of delay and fees, NAC expended thousands of hours of unnecessary time and resources in an effort to resolve the large discrepancy. NAC estimates that its labor costs solely attributable to resolving the discrepancy due to Contractor's model error -
and the NRC's faulty imputation against NAC's model, exceed a half-million dollars. This wasted effort deprived NAC of the opportunity to use those internal resources and money spent on NRC review fees to develop new products or improve the competitiveness of its existing products, resulting in diminished competitiveness to pursue and win customer contracts and support other projects.
Based on the information provided in this letter and the enclosures, the fees associated with Contractor's questionable if not erroneous thermal modeling do not comport with the requirements of31 U.S.C. § 9701. Therefore, pursuant to 10 CFR 170.51 and 15.31, NAC respectfully requests that the NRC waive the fees listed in Enclosure 1.
In this regard, NAC further understands that there do not appear to be express statutory or regulatory limitations or prohibitions that would prevent a federal agency like the NRC from paying interest to a licensee or certificate holder on improperly incurred and collected fees. Thus, to make NAC whole any refund presumably should include interest from the date of payment of amounts in dispute by NAC as noted herein. However, NAC is willing to forego its assertion of such a payment of interest in consideration of a prompt resolution of the fees listed in Enclosure
- 1.
If you have any questions or wish to discuss the matter further please contact Mr. Wren Fowler, Director, Licensing for NAC.
Sincerely, NAC International Inc.
Kent S. Cole, President and CEO ENCLOSURE: -NAC MAGNA TRAN Licensing Application Review-- NRC Docket No. 71-9356 ED20190066 Page 4 of 4
ENCLOSURE 1 NAC MAGNATRAN Licensing Review NRC Docket No. 71-9356
Page1of6
ENCLOSURE1toNACInternationalInc.LetterDatedSeptember11,2019 NACMAGNATRANLicensingApplicationReview-NRCDocketNo.719356
NRCInvoice NRCReviewFeesAssessed andPaidbyNAC PercentageofNRCandContractorReviewFees JudgedbyNACasAttributabletoContractorModeling1 andthus,JudgedbyNACtobeReimbursable
[NACBestEstimateAssessmentofNRCInvoiceAmounts]
NACReviewFee ReimbursementClaim Amounts NRC Contractor NRC%/Contractor%
NRC Contractor FY15/16Q4
$36,830.00
$28,246.00 NRC0%/Contractor0%
Asexplainedbelow,NACdoesnotrequestreimbursementofreviewfeesduringthis quarter.OnSeptember16,2016NACsNRCprojectmanager(White)notifiedNACs licensing manager (Fowler) by telephone that Contractor was asserting an alleged discrepancyorerrorinNACsANSYSthermalmodelusedforcomputercalculationsof MAGNATRANthermalperformance.AsunderstoodbyNACatthetime,Contractorhad createdathermalmodelforMAGNATRANofitsownusingtheCOBRAcode.Contractor alsorananewerversionofANSYScomparedtotheversionusedbyNAC,usingtheNAC suppliedinputparametersandcalculatedhighertemperaturesthanNACscalculations withitsmodel-whichimpliedthatNACslowerresultswereincorrect.Todocument andtracktheissuetoclosure,theNRCissuedaRequestforAdditionalInformation(RAI) toNACdatedSeptember19,2016(RAIRound4;ML16264A151)solelyfocusedon NACsthermalevaluations.NACsubmittedsupplement(August10,2016)toRAIRound 3(March3,2016;ML16068A218).NootheropenNRCissueswerecommunicatedto NACduringthisquarter.
NACdoesnotrequestreimbursementofreviewfeesduringthisquarter.
$0
$0 FY16/17Q1
$4,052.75
$986.42 NRC0%/Contractor0%
During this quarter, NAC commenced preparation of a submittal to NRC with the correctedANSYSAUX12inputmatrix,whichwasunrelatedtotheContractorModeling.
NACdoesnotrequestreimbursementofreviewfeesduringthisquarter.
$0
$0 FY16/17Q2
$48,362.50
$11,302.00 NRC0%/Contractor50%
During this quarter, NAC submitted (January 11, 2017; ML17017A184) the corrected ANSYS model to the NRC including NAC Supplement 16B calculations (January 13,
$0
$5,651.00
1ContractorModelingreferstothedescriptionofNRCandContractorsthermalmodelingissuesdescribedintheNACletterrequestingreviewandappealof fees,datedSeptember11,2019.
Page2of6
2017).TheNRCsubsequentlyreviewedthesubmittalsandameetingwasheldbetween theNRC,NAC,andContractoronMarch30,2017(seeNRCmeetingsummarydatedApril 17,2017).Duringthismeeting,Contractorrepresented,viatheirpresentationslides, thatNACsmodelunderpredictedthepeakcladdingtemperature(PCT),reasoningthat theisotropicpropertiesoftheneutronabsorberpanelsthermalconductivitiesseemingly wereappliedinreverse(thissuggestionbyContractorwasincorrect).
ContractorsassertionattheMarch30thmeetingwasmisleadingandbecameasourceof confusionfortheNRC.ThiscomplicatedfurthertechnicaldiscussionsNACwashaving relatedtoaccuracyofitsthermalmodelingandprolongedthelackofaresolutionwith NRC,untiltheNRCissuedtheMAGNATRANCertificateofCompliance(CoC)toNACdated April5,2019.NACconsiderstheMarch30thmeetingasthebeginningofunnecessary regulatoryreviewsandNACreviewfeesattributabletoContractorModeling.
Thus, NAC is requesting reimbursement of 50% of review fees charged by ContractorasattributabletotheContractorModeling,butnoneoftheNRC reviewfees.
FY16/17Q3
$36,437.50
$30,901.37 NRC25%/Contractor75%
Duringthisquarter,NACperformedextensivethermalanalysesinanefforttoreplicate theresultsofthediscrepanciesassertedbyContractorandateleconferencewasheldon May11,2017betweenNACandNRC.NACisunabletoreplicatetheContractorclaims ofa75°FdegreeincreaseinPCTbasedupontheContractorModelingresults.Please notethat,duringtheprocess,NACselfidentifiedaduplicateshellelementerrorinits model, which was introduced while answering NRC RAIs with further modeling and analysis.However,thecorrectedNACmodeldidnotresultinsignificantchangesinPCT, sinceitwasassociatedwithanondominantmodeofheattransferforthesystem.NAC requesteddeferralofaplannedmeetingwithNRCbecauseitneededadditionaltimeto prepare(meetingwasdeferreduntilJuly25,2017).
Duringthisquarter,theNRCissued(letterdatedApril17,2017)asummaryoftheMarch 30,2017closedmeetingwithNACregardingoutstandingthermalmodelingissues.
ContractorfurtherclaimedthatthePCTcalculatedbyNACsmodelisexcessively highbecauseofanewissuebroughtupbytheirreview,specifically:thewayNAC was modeling an effective thermal conductivity for the neutron absorber panel regionversusamodelthatwouldbeexplicitinnature.NACexpendedfurther resourcestoexplicitlymodeleachlayerofthefueltubeandneutronabsorber.The resultswerenodifferentthantheeffectivethermalconductivitymodel.OtherNAC modelingeffortsperformedtovalidateandaddressContractorconcernsincluded increasinglyrefinedmeshmodeling,whichresultedinnegligibledifferencesinPCT fromonemodelchangetothenext.
$9,109.38
$23,176.03
Page3of6
TheNRC,attheMarch30thmeeting,devotedattentiontoContractorModeling resultsforthenormalconditionsoftransport(NCT)thermalmodel,andthusraised furtherquestionspertainingtoNACshypotheticalaccidentconditions(HAC)fire accidentanalysiswhichusedaNRClicensedmodelingapproachreferredtoasthe deltaTmethod,whichNAChadpreviouslyusedaNRCapprovedinCoCsforother NACtransportcasktechnology(NACsLWTandSTCcasks).ThedeltaTapproachis conservativeandyetthereremainedlargemargintotheregulatorytemperature limit.However,ContractorsassertionsaboutNACsNCTresultsandmodeling,in general,createdsignificantadditionalNACworkwhereNACbuiltandranamore detailed3DtransientsimulationthatdemonstratedthatthedeltaTmethodwas conservative.Theresultoftheadditional3DmodellingshowedaresultingPCTof 747°F(amodestincreaseof16°FabovethesteadystateNCTPCT),whichisover 300°FbelowtheaccidentPCTlimitof1058°F.NACdeemstheadditionaleffort, borneoftheContractorModeling,asunnecessaryandwasteful.
Thus, NAC is requesting reimbursement of both NRC (25%) and Contractor (75%)reviewforthequarter.
FY16/17Q4
$14,971.50
$104,133.39 NRC35%/Contractor100%
Duringthisquarter,duringameetingbetweenNRC,NAC,andContractoronJuly25,2017 (see, for example, NRCs meeting summary dated August 10, 2017, p. 2) Contractor claimstheirCOBRAmodelisproducingcorrectPCTvaluesandnotNACsANSYSmodel.
NRCquestionswhetherNACperformedavalidationtodeterminewhetheritsdigital representationinthecomputercodeoftheeffectivethermalconductivitymatchedthe physicsoftheheattransferoutofthebasket.
Contractorpresumablywasawareofthecorrectfueltubecornerconfiguration,whichis significantlydifferentthanContractoracknowledgedastheunusualconfigurationused intheirCOBRAmodel(seeContractorslidesdatedMarch12,2019).Duringthemeeting July25,2017meeting,NRCindicatedtheyhadreviewedNACsAUX12correction.NAC shareditsselfidentificationoftheduplicateshellelementsandthepreliminaryresults of the corrected model. From this point forward, no further modeling errors were identifiedbyNACwithrespecttotheMAGNATRANANSYSthermalmodel.
Thus,NACisrequestingpartialreimbursement(35%)forNRCreviewfeesand all(100%)forContractorduetocontinuingissueswiththeContractorreview of NACs model and inaccurate claims. [During this quarter, there do not appeartobeanyContractorfeesthatareunrelatedtotheContractorErrors-inotherwords,100%ofthefeesarejudgedastobeaffectedbytheContractor Modelingandthusarereimbursable.]
$5,240.03
$104,133.39
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FY17/18Q1
$50,890.50
$5,933.44 NRC50%/Contractor100%
Duringthisquarter,NACformallysubmittedthecorrectedANSYSmodelthathadthe duplicateshellelements(October6,2017;ML17291A395).NACrequestsContractors disclosure of its model for NAC review (November 13 and 28, 2017 NAC emails; December15,2017NACcallrecord),whichrequestsallweredeclinedbyContractor.
Thus, NAC is requesting reimbursement of NRC review fees (50%) and all (100%)forContractorreviewfeesduetocontinuingissueswiththeContractor reviewofNACsmodelandinaccuratecriticisms.[Duringthisquarter,theredo not appear to be any Contractor fees that are unrelated to the Contractor Modeling-inotherwords,100%ofthefeesarejudgedastobeaffectedbythe ContractorModelingandthusarereimbursable.]
$25,445.25
$5,933.44 FY17/18Q2
$60,496.00
$111,426.43 NRC75%/Contractor100%
Duringthisquarter,theNRCandContractorconductedanauditatNACsHQofficeduring January 2325, 2018. Based on prior communications with the NRC, NAC expected Contractortosharetheirmodel.Contractorwouldnotsharetheirmodel(however,it appearsContractoremployedsomeunusualANSYSmodelingthatwasspeculativeand wasteful).IfNAChadseentheirmodel,itwouldhaverevealedissueswithContractors modeling results. During the audit, NAC presented a detailed review of its model.
Contractor was complimentary and said they did not have any concern with NACs modelingofthefueltubeinterfaceandneutronabsorberexceptregardingthesizeof gapsmodeledandtheirsensitivity.Note,NACsPCTwasstillwithin5degreesoforiginal calculationsdespiteallthemodelingpermutationsperformedattherequestoftheNRC andContractor.NRCdoubtspersistedregardingNACscalculations(seeJanuary12,2018 NACemailregardingNRCresponsetoquestionsonhowContractorsmodelswillbeused tolicenseMAGNATRAN).
Thus, NAC is requesting reimbursement of NRC review fees (75%) and all (100%)ofContractors.[Duringthisquarter,theredonotappeartobeany ContractorfeesthatareunrelatedtotheContractorModeling-inotherwords, 100%ofthefeesarejudgedastobeaffectedbytheContractorModelingand thusarereimbursable.]
$45,372.00
$111,426.43 FY17/18Q3
$79,952.00
$22,954.13 NRC100%/Contractor100%
Duringthisquarter,NACsubmitted(April9,2018)asupplementbasedontheJanuary 2325,2018audit.Inaddition,yetanothernewthermalissuewasbroughtupjustifying Contractors claim that the PCT was over 800°F, thus NRCs focus of NAC thermal modelingconcernsshiftstothelicensingdrawingandminimumcontactwidthoffuel tubecornersasthereasonforPCTvaluesover800°Fdegrees(seeMay16,2018NACcall
$79,952.00
$22,954.13
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record-NAC/FowlerwithNRC/PMWhite).Duringthistime,theNRCwasstilladdressing shieldingtolerances.
Thus,NACisrequestingreimbursementforallNRCreviewfees(100%)and Contractorsfees(100%).[Duringthisquarter,theredonotappeartobeany ContractorfeesthatareunrelatedtotheContractorModeling-inotherwords, 100%ofthefeesarejudgedastobeaffectedbytheContractorModelingand thusarereimbursable.]
FY17/18Q4
$52,522.75
$25,417.03 NRC100%/Contractor100%
Duringthisquarter,NACsubmittedthefirstoftwosupplementsbasedonateleconwith theNRCandContractorheldonJuly11,2018coveringthreeissuesraisedintheNRC RAIs.NACssubmittalprovideddetailedanalysisaddressingthesensitivityofthesystem tothecontactwidthofthefueltubecorners.NACsanalysisdemonstratedthesystem isnotsensitivetothisdimension.Also,theNRCissueswithshieldingtoleranceswere resolved.NRCteleconferenceswithNACwereheldonAugust5andAugust24,2018.
NACprovidedasubmittal(August30,2018)supplementingitsearlierresponse(April9, 2018submittal)
Thus,NACisrequestingallNRC(100%)andContractor(100%)reviewfeesbe reimbursed. [During this quarter, there do not appear to be any NRC or ContractorfeesthatareunrelatedtotheContractorModeling-inotherwords, 100% of the NRC and Contractor fees are judged as to be affected by the ContractorModelingandthusarereimbursable.]
$52,522.75
$25,417.03 FY18/19Q1
$17,737.50
$16,983.04 NRC100%/Contractor100%
Duringthisquarter,NACheldateleconferencewithNRConOctober24,2018,regarding theAugust24,2018meetingsummary(i.e.,meetingsummarythatwasbasedupon teleconferencewithNRCheldJuly11,2018onthermalmodelingissues).
OnOctober30,2018NACsubmittedthesecondandfinalsupplement(i.e.,supplemental tothesubmittaldatedAugust30,2018)basedonthepreviousquartersteleconferences withNRC(July11,August15andAugust24).
Thus,NACisrequestingallNRC(100%)andContractor(100%)reviewfeesbe reimbursed. [During this quarter, there do not appear to be any NRC or ContractorfeesthatareunrelatedtotheContractorModeling-inotherwords, 100% of the NRC and Contractor fees are judged as to be affected by the ContractorModelingandthusarereimbursable.]
$17,737.50
$16,983.04 FY18/19Q2
$101,681.25
$0.00 NRC80%/Contractorn/a%
$81,345.00
$0.00
Page6of6
Duringthisquarter,theNRCwithsupportfromNACdevelopstheCoCandSER.Dueto excessive efforts associated with documenting the almost two years of unwarranted additional thermal modeling efforts, NAC is requesting some NRC review fees be reimbursed.SeeMarch12,2019NRCclosedmeetingContractorspresentationslides (e.g.,slides5,6,8and11),whichrevealthatContractorstubecornergeometrymodeling is unusual and nonphysical and was clearly the reason for discrepancy with NACs calculationsbyContractorsintroducinganerrorof73°Foverprediction.Contractor concedesequivalentresultswithNACsmodelareobtainedifContractoradoptsNACs modelingconfiguration.
Thus, NAC is requesting reimbursement of NRC review fees (80%) and all (100%)forContractorreviewfeesduetocontinuingissueswiththeContractor reviewofNACsmodelandinaccurateclaims.[Duringthisquarter,theredo not appear to be any Contractor fees that are unrelated to the Contractor Modeling-inotherwords,100%ofthefeesarejudgedastobeaffectedbythe ContractorModelingandthusarereimbursable.]
SubtotalsNRC/Contractor: $316,723.91
$315,674.49 FY18/19Q3
$TBD
$TBD WithnofurtherrequirementsforNACactionwithrespecttoitsMAGNATRANthermal modelingcalculations,onApril5,2019,NRCissuestheinitialCoCforMAGNATRAN,NRC Docket no. 719356. After all the additional work, calculations, explanations and correspondence/submittalswiththeNRC-sincetheSeptember2016initialassertions byContractorthatNACsmodelingwasnotcorrectwhichcauseddoubtsbyNRCofNACs modeling and design calculations there were no changes in the MAGNATRAN cask design necessary as a prerequisite to NRCs issuance of the CoC on April 5, 2019.
ComparedtoNACsmodelingpredictionsfromtheSeptember2016timeframe,after yearsofNACstryingtoexplainitsmodelingandcalculationstoNRC(andContractor),
including performing extensive thermal modeling using extremely fine nodalmesh densities and a large number of sensitivity studies - the final NRCaccepted NAC calculationsrepresentedanetchangeintemperatureofnomorethanapproximately3 degreesF,comparedtoNACsresultsintheSeptember2016timeframe.