ML20202A293

NAC International, Inc., Submission of a Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1031 for the NAC International Magnastor Cask System

ML20202A293
Person / Time
Site:	07201031
Issue date:	07/14/2020
From:	Fowler W NAC International
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
ED20200085
Download: ML20202A293 (6)

Text

Atlanta Corporate Headquarters 3930 East Jones Bridge Road, Suite 200 Norcross, GA 30092 Phone 770-447-1144 www.nacintl.com July 14, 2020 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Attn: Document Control Desk

Subject:

Submission of a Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1031 for the NAC International MAGNASTOR Cask System Docket No. 72-1031

References:

1. U.S. Nuclear Regulatory Commission (NRC) Certificate of Compliance (CoC) No. 1031 for the NAC International MAGNASTOR Cask System, Amendment No. 8, March 24, 2020

2. MAGNASTOR Cask System Final Safety Analysis Report (FSAR),

Revision 10, NAC International, February 2019 NAC International (NAC) hereby submits a request to amend Reference 1. The following provides a brief summary of the amendment application:

1. The addition of a new transfer cask known as the Lightweight MAGNASTOR Transfer Cask (LMTC)

2. The addition of a new concrete cask design known as CC7

3. Increased the maximum system heat load capacity when using the LMTC and CC7

4. Added new loading patterns I, J, and K for the PWR basket assembly

5. Added new loading patterns B, C, and D for the new BWR 89 assembly basket

6. Added new loading patterns A, B, and C for the new BWR 81 assembly basket

7. Removed the previously licensed BWR basket configurations since they are bounded by the new 89 and 81 configurations; however, the PSAR analysis and licensing drawings remain as they partially support the evaluations justifying the approval of the new 89 and 81 configurations

8. The new BWR fuel basket design permits loading up to 89 undamaged BWR fuel assemblies with increased heat load capacity

9. Added a new BWR damaged fuel basket design with a capacity ofup to 81 undamaged BWR fuel assemblies, which includes 12 damaged fuel can (DPC) locations with increased heat load capacity

10. Added a new DPC for BWR fuel

11. Added new and revised previously approved drawings for the LMTC, BWR 89 fuel basket, BWR DP basket, and DPC

12. Technical Specification, Appendix A revisions to include the new LMTC, BWR 89 fuel basket, BWR DP basket, and DPC; including increased heat loads and loading patterns

13. Technical Specification, Appendix B revisions to include the new LMTC, BWR 89 fuel basket, BWR DP basket, and DPC; including increased heat loads and loading patterns ED20200085

ANAC Wtf . . INTERNAT!QNA~

U.S. Nuclear Regulatory Commission July 14, 2020 Page 2 of 2 Note, the proposed changes to the Technical Specifications, Appendix B, are based on the new formatting and reorganization that was presented in the MAGNASTOR Amd. 9 application. The new formatting and reorganization was substantial and this amendment application, here in, dovetails into the new formatting and reorganization. Enclosed in this amendment package are the Revision 20A changed pages to Reference 2 that support revising Reference 1. In addition, NAC is providing supporting proprietary calculations (Enclosure 4) for the listed changes. This submittal includes one proprietary and non-proprietary version of this package. Attached to this letter is a signed affidavit requesting all proprietary information be withheld from public disclosure via 10 CFR 2.390.

Consistent with NAC administrative practice, this proposed FSAR revision is numbered to uniquely identify the applicable changed pages. Revision bars mark the FSAR text changes on the Revision 20A pages (Enclosure 5). The included List of Effective Pages (Enclosure 5) identifies the revision level of all pages in the Reference 2 FSAR with Revision 20A incorporated. Enclosures 1 and 2 detail the list of FSAR and drawing changes, respectively. contains the proposed Technical Specification changes for this amendment. In order to better facilitate the review process, NAC is providing the Revision 20A changed pages with appropriate backing pages. In accordance with NAC's administrative practices, upon final acceptance of this application, the 20A changed pages will be reformatted and incorporated into the next revision of the MAGNASTOR FSAR. NAC is requesting an effective date for this amendment to be prior to June 2022.

If you have any comments or questions, please contact me on my direct line at 678-328-1236.

Wren Fowler Director, Licensing Engineering

Enclosures:

- List of Changes for MAGNASTOR FSAR, Amendment 11, Revision 20A - List of Drawing Changes for MAGNASTOR FSAR, Amendment 11, Revision 20A - Proposed Changes for MAGNASTOR Technical Specifications, Amendment 11, Revision 20A - Supporting Calculations for MAGNASTOR FSAR, Amendment 11, Revision 20A -FSAR Changed Pages and LOEP for MAGNASTOR FSAR, Amendment 11, Revision 20A ED20200085

INAC Wt._ INTERNATIONA~

NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 George Carver (Affiant), Vice President, Engineering and Support Services, of NAC International, hereinafter referred to as NAC, at 3930 East Jones Bridge Road, Peachtree Comers, Georgia 30092, being duly sworn, deposes and says that:

1. Affiant has reviewed the information described in Item 2 and is personally familiar with the trade secrets and privileged information contained therein, and is authorized to request its withholding.

2. The information to be withheld includes the following NAC Proprietary Information that is being provided to support the technical review of NAC' s Request for a Certificate of Compliance (CoC) (No.

1031) for the NAC International MAGNASTOR Cask System.

• Enclosure 4, NAC International Proprietary Calculations Structural o 71160-2021 Rev. 0 and Data Disk 1 of 1 o 71160-2027 Rev. 0 and Data Disk 1 of 1 o 71160-2033 Rev. 0 and Data Disk 1 of 1 Thermal o 71160-3065 Rev. 1 and Data Disk 1 of 1 o 71160-3070 Rev. 1 and Data Disk 1 of 1 o 71160-3075 Rev. 1 and Data Disk 1 of 1 o 71160-3080 Rev. 1 and Data Disk 1 of 1 o 71160-3086 Rev. 1 and Data Disk 1 of 1 o 71160-3087 Rev. 1 and Data Disk 1 of 1 o 71160-3060 Rev. 1 and Data Disk 1 of 1 o 71160-3085 Rev. 1 and Data Disk 1 of 1 o 71160-3081 Rev. 2 and Data Disk 1 of 1 o 71160-3071 Rev. 1 and Data Disk 1 of 1 o 71160-3021 Rev. 2 Shielding o 71160-5031 Rev. 1 and Data Disk 1 of 1 o 71160-5032 Rev. 1 and Data Disk 1 of 1 o 71160-5033 Rev. 1 and Data Disk 1 of 1 o 71160-5034 Rev. 0 and Data Disk 1 of 1 o 71160-5035 Rev. 0 and Data Disk 1 of 1 o 71160-5036 Rev. 0 and Data Disk 1 of 1 o 71160-5053 Rev. 0 Criticality o 71160-6013 Rev .2 and Data Disk 1 of 1 o 71160-6014 Rev. 0 and Data Disk 1 of 1

• Enclosure 5, MAGNASTOR FSAR, Revision 20A-Proprietary Version NAC is the owner of the information contained in the above documents. Thus, all of the above identified information is considered NAC Proprietary Information.

3. NAC makes this application for withholding of proprietary information based upon the exemption from disclosure set forth in: the Freedom oflnformation Act ("FOIA"); 5 USC Sec. 552(b)(4) and the Trade ED20200085 Page 1 of 4

NAC AINT~RNATIQNA~ NACINTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 Secrets Act; 18 USC Sec. 1905; and NRC Regulations 10 CFR Part 9J7(a)(4), 2.390(a)(4), and 2.390(b)(l) for "trade secrets and commercial financial information obtained from a person, and privileged or confidential" (Exemption 4). The information for which exemption from disclosure is herein sought is all "confidential commercial information," and some portions may also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4.

4. Examples of categories of information that fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by competitors of NAC, without license from NAC, constitutes a competitive economic advantage over other companies.

b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product.

c. Information that reveals cost or price information, production capacities, budget levels or commercial strategies of NAC, its customers, or its suppliers.

d. Information that reveals aspects of past, present or future NAC customer-funded development plans and programs of potential commercial value to NAC.

e. Information that discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information that is sought to be withheld is considered to be proprietary for the reasons set forth in Items 4.a, 4.b, and 4.d.

5. The information to be withheld is being transmitted to the NRC in confidence.

6. The information sought to be withheld, including that compiled from many sources, is of a sort customarily held in confidence by NAC, and is, in fact, so held. This information has, to the best of my knowledge and belief, consistently been held in confidence by NAC. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements, which provide for maintenance of the information in confidence. Its initial designation as proprietary information and the subsequent steps taken to prevent its unauthorized disclosure are as set forth in Items 7 and 8 following.

7. Initial approval of proprietary treatment of a document/information is made by the Vice President, Engineering, the Project Manager, the Licensing Specialist, or the Director, Licensing - the persons most likely to know the value and sensitivity of the information in relation to industry knowledge.

Access to proprietary documents within NAC is limited via "controlled distribution" to individuals on a "need to know" basis. The procedure for external release of NAC proprietary documents typically requires the approval of the Project Manager based on a review of the documents for technical content, competitive effect and accuracy of the proprietary designation. Disclosures of proprietary documents outside of NAC are limited to regulatory agencies, customers and potential customers and their agents, suppliers, licensees and contractors with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

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.NAC J, INTERNATIQNA~

NACINTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390

8. NAC has invested a significant amount of time and money in the research, development, engineering and analytical costs to develop the information that is sought to be withheld as proprietary. This information is considered to be proprietary because it contains detailed descriptions of analytical approaches, methodologies, technical data and/or evaluation results not available elsewhere. The precise value of the expertise required to develop the proprietary information is difficult to quantify, but it is clearly substantial.

9. *Public disclosure of the information to be withheld is likely to cause substantial harm to the competitive position of NAC, as the owner of the information, and reduce or eliminate the availability of profit-making opportunities. The proprietary information is part of NAC's comprehensive spent fuel storage and transport technology base, and its commercial value extends beyond the original development cost to include the development of the expertise to determine and apply the appropriate evaluation process.

The value of this proprietary information and the competitive advantage that it provides to NAC would be lost if the information were disclosed to the public. Making such information available to other parties, including competitors, without their having to make similar investments of time, labor and money would provide competitors with an unfair advantage and deprive NAC of the opportunity to seek an adequate return on its large investment.

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NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF GEORGIA, COUNTY OF GWINNETT Mr. George Carver, being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated herein are true and correct to the best of his knowledge, information and belief.

Executed at Pea ree Comers, Georgia, this \4 day of .J v\y ,2020.

George Carver Vice President, Engineering and Support Services NAC International Subscribed and sworn before me this \J:.t day of ..JU\':::-\ , 2020.

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