ML20315A427

Enclosure 11 - Additional Changes Not Associated with the RAIs

ML20315A427
Person / Time
Site:	07201042
Issue date:	10/29/2020
From:	Orano TN Americas, TN Americas LLC
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML20315A417	List: ML20315A418 ML20315A419 ML20315A420 ML20315A421 ML20315A422 ML20315A424 ML20315A425 ML20315A426 ML20315A427 ML20315A428
References
E-57418, EPID L-2019-LLA-0078
Download: ML20315A427 (2)

Text

Enclosure 11 to E-57418 Additional Changes Not Associated with the RAIs TN Americas LLC is requesting multiple changes to the proposed Amendment 2 Technical Specifications (TS) and Updated Final Safety Analysis Report (UFSAR) that are not related to the RAI questions. The requested changes are discussed in the following sections of this enclosure and include a description of the change, the impact on the design, and a summary of the impact on the TS and UFSAR. The changes are shown in italics and revision bars.

1. Technical Specification Table 3 for Control Components

Description:

This change has been withdrawn.

• TS Impact: TS Table 3 has been added back in to its location as was shown in Amendment 2, Revision 3, including footnotes 1 and 2. The discussion that was added in TS Section 2.1 has been revised to what was shown in Amendment 2, Revision 3.

The phrase that was added to TS Section 5.1.2 has been revised to what was shown in Amendment 2, Revision 3.

• UFSAR Impact: References to TS Table 3 are added back in to Chapters 2 and 6 as were shown in Amendment 2, Revision 3. Table 6-37a is being revised and used for another purpose. See revised item 2 below. The initial Table 6-37a information is now back in TS Table 3.

2. Co-60 Equivalent Methodology for Control Components

Description:

Due to the large variation of control component (CC) types used by Licensees, the standard approach used by TN Americas LLC is to limit the CC source in the Technical Specifications, which necessitates a CC characterization analysis by the Licensee. This approach has been used for all NUHOMS systems loaded to date. The CC characterization analysis takes into account all relevant parameters, such as host fuel assembly burnup and enrichment, and CC cooling time.

The Co-60 equivalence method is applied to a standard 18-gamma energy group source generated by ORIGEN. A CC source due to irradiated silver or hafnium would be generated using ORIGEN and automatically account for any complex decay chains.

The response functions used to convert an 18-group gamma source into a dose rate are added to UFSAR Section 6.2.4. These response functions were also used to rank the fuel assembly source terms for the EOS-37PTH DSC presented in UFSAR Section 6.2.2. To further illustrate the Co-60 equivalent method, an example for an arbitrary CC source containing silver is added to UFSAR Section 6.2.4. The methodology is generic and may be applied to any CC source with an 18-energy group representation.

• TS Impact: None

• UFSAR Impact: The discussion on Co-60 equivalence in UFSAR Section 6.2.4, Control Components, has been revised to provide clarification. Table 6-37a and Table 6-37b have been added to the UFSAR.

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Enclosure 11 to E-57418 Additional Changes Not Associated with the RAIs

3. Integrated Inner Top Cover Plate and Shield Plug

==

Description:==

This change clarifies the terminology as well as providing the dimensions and material specifications for the option of an integrated inner top cover plate and top shield plug for the EOS-37PTH and EOS-89BTH DSCs. This option is called Alternate 1 - Integrated Top Shield Plug and Inner Top Cover Plate as shown on drawings EOS01-1000-SAR and EOS01-1005-SAR.

• TS Impact: None

• UFSAR Impact: A clarification is added to Section 1.2.1.1 for EOS-37PTH and Section 1.2.1.2 for EOS-89BTH to clarify the option of using a top shield plug integrated with the inner top cover plate. Drawing EOS01-1000-SAR and Drawing EOS01-1005-SAR have been revised to add drawing details that include dimensions and material specifications for the option of using top shield plug integrated with the inner top cover plate for both the EOS-37PTH and EOS-89BTH DSCs.

4. Reduction in Maximum Allowable Heat Load

Description:

TS Section 2.1 and 2.2 (Thermal Parameters) allows the flexibility to reduce he maximum allowable heat loads based on the thermal analysis methodology in the UFSAR.

This change to Chapter 2 clarifies that the reduction if necessary may be based on the specific fuel assembly type.

• TS Impact: None

• UFSAR Impact: Section 2.4.3 of UFSAR is updated to clarify the methodology to reduce the maximum allowable heat load based on the fuel assembly type.

5. Proposed Clarifications to the ACI Code, Concrete Temperatures

Description:

Paragraph 4.4.4 of Certificate of Compliance (CoC) No. 1042 Appendix A, NUHOMS EOS' System Generic Technical Specifications (TS), TN Americas LLC (TN) requests changes for clarification. In column 1, E.4 is expanded to specify Paragraph E.4.3 to more accurately reflect the code requirement in question. In column 2, the discussions regarding E.4.1 and E.4.2 are removed and replaced with Paragraph E.4.3 requires testing of concrete for temperatures higher than those given in Paragraph E.4.1. In the third column, the phrase 28 days is deleted and the phrase which may be tested up to 56 days is added. These changes are being proposed to clarify whether concrete testing is required, based on HSM component temperatures. E.4.1 defines normal temperature limits. E.4.2 defines accident temperature limits. E.4.3 provides the guidance if the temperature limits from E.4.1 and E.4.2 are exceeded.

• TS Impact: Paragraph 4.4.4 has been edited for clarification as discussed above.

• UFSAR Impact: None.

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