ML21064A052

Enclosure 1 - Conversation Record TN-32 Renewal Request for Additional Information (RAI) 5

ML21064A052
Person / Time
Site:	07201021
Issue date:	03/03/2021
From:	Christian Jacobs Storage and Transportation Licensing Branch
To:	Yates D TN Americas LLC
CJJacobs - NMSS/DFM/STL - 301.415.6825
Shared Package
ML21064A050	List: ML21064A051 ML21064A052
References
CAC 001028, CoC No. 1021, EPID L-2020-RNW-0009
Download: ML21064A052 (1)

Text

ENCLOSURE 1 Conversation Record TN-32 Renewal Request for Additional Information (RAI) 5 March 3, 2021 The response to RAI-5 states:

the shielding intended safety function of the TN-32 cask is defined as meeting the requirements of 10 CFR Part 20 (i.e., 10 CFR 20.1301) and 10 CFR Part 72.104, i.e.,

doses to members of the public outside the independent spent fuel storage installation (ISFSI) and not tied to a specific cask.

NRC staff requested the following clarification: The response states that the intended safety function is defined as meeting the requirements of Part 20, but with 10 CFR 20.1301 as an i.e.

in parenthesis, this is in conflict with the FSAR and the statements in Section 4.3.3 of the application. Section 4.3.3 of the application was referenced in the response to RAI 5 and has a similar statement without the i.e. in parentheses: shielding intended safety function (i.e.,

met the requirements of 10 CFR Part 20 and 10 CFR Part 72.104).

This is an important distinction, as the difference of having the i.e. or not carries a different intended safety function. The NRC staff needs the applicant to clarify if the intended safety function is only to meet 10 CFR 20.1301 of Part 20 (and thus not be used to reduce occupational exposure in consideration of 10 CFR Part 20 Subpart C regulations such as 10 CFR 20.1201). This information is needed to determine compliance with 72.240(c).

TN clarified that the intended safety function for the neutron shield is to reduce exposures to meet 10 CFR Part 20.

TN has agreed to provide the following supplemental information to clarify their previous responses to RAI-5:

TN to develop a meaningful way to manage the degradation effects of the neutron shield during the renewal period. NRC staff reiterated that acceptable AMPs were demonstrated in the North Anna and Prairie Island renewals. TN will attempt to provide similar wording (e.g., annual perimeter survey) used in the North Anna renewal that can be generically applied in this CoC.

The supplemental response provided for the TN-32 Renewal would also have to be provided for the TN-68 Renewal.