ML21067A166

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CoC 1029 Renewal User Need Memo
ML21067A166
Person / Time
Site: 07201029
Issue date: 04/13/2021
From: John Mckirgan
Storage and Transportation Licensing Branch
To: Martinez T
NRC/NMSS/DREFS/MRPB
CTMarkley - NMSS/DFM/STL - 301.415.6293
Shared Package
ML21067A164 List:
References
CAC 001028, EPID L-2019-RNW-0014
Download: ML21067A166 (6)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 13, 2021 MEMORANDUM TO: Tania Martinez, Chief (acting)

Materials Rulemaking and Project Management Branch Division of Rulemaking, Environmental, and Financial Support, NMSS FROM:

John McKirgan, Chief Storage and Transportation Licensing Branch Division of Fuel Management, NMSS

SUBJECT:

USER NEED FOR RULEMAKING FOR CERTIFICATE OF COMPLIANCE RENEWAL, INITIAL ISSUE (AMENDMENT NUMBER 0),

AMENDMENT NUMBERS 1, 3, AND 4 TO ADVANCED STANDARDIZED NUHOMS HORIZONTAL MODULAR STORAGE SYSTEM On May 22, 2019, (ML19148A484), as supplemented on December 4, 2019 (ML19338E132),

and July 10, 2020 (ML20192A127), the applicant submitted an application to renew CoC No.

1029 for the Standardized Advanced NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, under the provisions of 10 CFR Part 72, subparts K and L, for a period of 40 years beyond the initial certificate term.

The following information is being provided to request rulemaking support for the following Spent Fuel Management (SFM) 10 CFR Part 72 licensing activity:

1.

Changes to 10 CFR 72.214 rule text (changes appear in bold):

Certificate Number: 1029.

Initial Certificate Effective Date: February 5, 2003, superseded by Renewed Initial Certificate Effective Date: Month DD, 2021.

Amendment Number 1 Effective Date: May 16, 2005, superseded by Renewed Amendment Number 1 Effective Date: Month DD, 2021.

Amendment Number 2 Effective Date: Amendment not issued by the NRC.

Amendment Number 3 Effective Date: February 23, 2015, superseded by Renewed Amendment Number 3 Effective Date: Month DD, 2021.

Amendment Number 4 Effective Date: March 12, 2019, superseded by Renewed Amendment Number 4 Effective Date: Month DD, 2021.

SAR Submitted by: Transnuclear, Inc., now TN Americas, LLC.

Renewal SAR submitted by: TN Americas, LLC.

CONTACT:

Christopher Markley, NMSS/DFM (301) 415-6293 John B. McKirgan Digitally signed by John B.

McKirgan Date: 2021.04.13 08:44:14 -04'00'

T. Martinez SAR

Title:

Final Safety Analysis Report for the Standardized Advanced NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel.

Docket Number: 72-1029.

Certificate Expiration Date: February 5, 2063 Technical Specifications and Certificate of Compliance Conditions: Proposed Changes CHANGES TO CERTIFICATE OF COMPLIANCE

1. Added the following condition to the Initial CoC (Amendment 0) and Amendments 1, 3 and 4:

UFSAR UPDATE FOR RENEWED COC The CoC holder shall submit an updated final safety analysis report (UFSAR) to the Commission, in accordance with 10 CFR 72.4, within 90 days of the effective date of the CoC renewal. The UFSAR shall reflect the changes resulting from the review and approval of the CoC renewal. The CoC holder shall continue to update the UFSAR pursuant to the requirements of 10 CFR 72.248.

The CoC holder has indicated that changes will be made to the UFSAR to address aging management activities resulting from the renewal of the CoC. This condition ensures that the UFSAR changes are made in a timely fashion to enable general licensees using the storage system during the period of extended operation to develop and implement necessary procedures.

2. Added the following condition to the Initial CoC (Amendment 0) and Amendments 1, 3 and 4:

72.212 EVALUATIONS FOR RENEWED COC USE Any general licensee that initiates spent fuel dry storage operations with the Standardized Advanced NUHOMS Horizontal Modular Storage System after the effective date of the CoC renewal, and any general licensee operating a Standardized Advanced NUHOMS Horizontal Modular Storage System as of the effective date of the CoC renewal, including those that put additional storage systems into service after that date, shall:

a. as part of the evaluations required by 10 CFR 72.212(b)(5), include evaluations related to the terms, conditions, and specifications of this CoC amendment as modified (i.e., changed or added) as a result of the CoC renewal;
b. as part of the document review required by 10 CFR 72.212(b)(6),

include a review of the UFSAR changes resulting from the CoC renewal and the NRC Safety Evaluation Report related to the CoC renewal; and

T. Martinez

c. ensure that the evaluations required by 10 CFR 72.212(b)(7) and (8) capture the evaluations and review described in (a.) and (b.) of this CoC condition.

The general licensee shall complete [this] Condition [11/12] prior to entering the period of extended operation or no later than one year after the effective date of the CoC renewal, whichever is later.

The staff considers it important to ensure that appropriate considerations for the period of extended operation are evaluated in the general licensees report required by 10 CFR 72.212, Conditions of general license issued under § 72.210. These considerations arise from the analyses and assumptions in the renewal application regarding operations during the period of extended operation. This includes potential use by general licensees that may use the new Standardized Advanced NUHOMS Horizontal Modular Storage System after the CoC has been renewed either at a new or an existing general license ISFSI. The renewal of the CoC is based on assumptions and analyses of the DSS and the sites where it is used. Licensees considering the use of the Standardized Advanced NUHOMS Horizontal Modular Storage System must evaluate it for use at their respective sites. This condition also makes it clear that general licensees that currently use a Standardized Advanced NUHOMS Horizontal Modular Storage System will need to update their 10 CFR 72.212 reports even if they do not put additional DSSs into service after the renewals effective date, in accordance with 10 CFR 72.212(b)(11).

3. Added the following condition to the Initial CoC (Amendment 0) and Amendments 1, 3 and 4:

AMENDMENTS AND REVISIONS FOR RENEWED COC All future amendments and revisions to this CoC shall include evaluations of the impacts to aging management activities (i.e., time-limited aging analyses and aging management programs) to ensure that they remain adequate for any changes to SSCs within the scope of the CoC renewal.

The CoC may continue to be amended after it has been renewed. This condition ensures that amendments to the CoC also address aging management impacts that may arise from the changes to the system in proposed amendments.

4. Added the following condition to the Initial CoC (Amendment 0) and Amendments 1, 3 and 4:

USE OF COC 1004 TRANSFER CASKS General licensees shall not use the OS197, OS197H, and the OS200FC TCs aged 20 years or more to perform the TC functions described in the Standardized Advanced NUHOMS System UFSAR after the PEO for CoC 1004 ends.

The CoC No. 1004 TC was initially certified for a term of 20 years. The CoC No. 1004 renewal application did not assess performance of the TC after the initial 20 year period.

Therefore, staff consider use of the CoC No. 1004 TC aged 20 years or older to be

T. Martinez prohibited in the absence of additional information to support TC performance for the PEO.

CHANGES TO TECHNICAL SPECIFICATIONS

1. Added the following text to the Initial CoC (Amendment 0) and Amendments 1, 3 and 4 in Section 4.3.3 Transfer Cask:

The general licensee shall ensure that the requirements of the applicable TRANSFER CASK aging management program (AMP) under the Renewed CoC 1004 have been satisfied.

2. Added the following section, Aging Management Program to the Initial CoC (Amendment 0) and Amendment 1 as Section 5.2.6, and in Amendments 3 and 4 as Section 5.2.7:

Aging Management Program Each general licensee shall have a program to establish, implement, and maintain written procedures for each aging management program (AMP) described in the updated final safety analysis report (UFSAR). The program shall include provisions for changing AMP elements, as necessary, and, within the limitations of the approved licensing bases, to address new information on aging effects based on inspection findings and/or industry operating experience provided to the general licensee during the renewal period. The program document shall contain a reference to the specific aspect of the AMP element implemented by that program document, and that reference shall be maintained even if the program document is modified.

The general licensee shall establish and implement this program document prior to entering the period of extended operation or no later than one year after the effective date of the CoC renewal, whichever is later. The general licensee shall maintain the program document for as long as the general licensee continues to operate Standardized Advanced NUHOMS Horizontal Modular Storage Systems in service for longer than 20 years.

The CoC holder proposed a condition to revise or create programs or procedures for implementing the AMPS in the FSAR supplement. This specification ensures that programs or procedures address AMP activities required for extended storage operations.

T. Martinez Docket No.: 72-1029 ADAMS

References:

1.

Memo to REFS requesting Rulemaking (ML21067A166). File located at G:\\SFST\\TN\\CoC 1029\\Renewal\\CoC 1029 Renewal (for REFS).

2.

Draft SER for Renewed CoC No. 1004, Amendment Nos. 0, 1, 3 and 4 (ML21067A167).

File located at G:\\SFST\\TN\\CoC 1029\\Renewal\\CoC 1029 Renewal (for REFS).

3.

Preliminary Certificate of Compliance No. 1029, Renewed Amendment 0, (ML21067A168). File located at G:\\SFST\\TN\\CoC 1029\\Renewal\\CoC 1029 Renewal (for REFS).

4.

Preliminary Technical Specifications for CoC No. 1029, Renewed Amendment No. 0, (ML21067A169). File located at G:\\SFST\\TN\\CoC 1029\\Renewal\\CoC 1029 Renewal (for REFS).

5.

Preliminary Certificate of Compliance No. 1029, Renewed Amendment 1, (ML21067A170). File located at G:\\SFST\\TN\\CoC 1029\\Renewal\\CoC 1029 Renewal (for REFS).

6.

Preliminary Technical Specifications for CoC No. 1029, Renewed Amendment No. 1, (ML21067A171). File located at G:\\SFST\\TN\\CoC 1029\\Renewal\\CoC 1029 Renewal (for REFS).

7.

Preliminary Certificate of Compliance No. 1029, Renewed Amendment 3, (ML21067A172). File located at G:\\SFST\\TN\\CoC 1029\\Renewal\\CoC 1029 Renewal (for REFS).

8.

Preliminary Technical Specifications for CoC No. 1029, Renewed Amendment No. 3, (ML21067A173). File located at G:\\SFST\\TN\\CoC 1029\\Renewal\\CoC 1029 Renewal (for REFS).

9.

Preliminary Certificate of Compliance No. 1029, Renewed Amendment 4, (ML21067A174). File located at G:\\SFST\\TN\\CoC 1029\\Renewal\\CoC 1029 Renewal (for REFS).

10.

Preliminary Technical Specifications for CoC No. 1029, Renewed Amendment No. 4, (ML21067A175). File located at G:\\SFST\\TN\\CoC 1029\\Renewal\\CoC 1029 Renewal (for REFS).

T. Martinez

SUBJECT:

USER NEED FOR RULEMAKING FOR CERTIFICATE OF COMPLIANCE RENEWAL, INITIAL ISSUE (AMENDMENT NUMBER 0), AMENDMENT NUMBERS 1, 3, AND 4 TO ADVANCED STANDARDIZED NUHOMS HORIZONTAL MODULAR STORAGE SYSTEM DOCUMENT DATE: April 13, 2021 DISTRIBUTION:

NMSS r/f DFM r/f OGC-POC ADAMS No.: ML21067A164 (Package); ML21067A166 (Memo)

  • By Email OFFICE DFM DFM DFM DFM NAME CMarkley WWheatley*

DDunn*

LCuadrado*

DATE 12/10/2020 12/15/2020 12/10/2020 12/22/2020 OFFICE DFM DFM DFM DFM NAME ZLi*

RRodriguez*

RChang*

TBoyce, JWise for*

DATE 12/15/2020 12/15/2020 12/18/2020 12/23/2020 OFFICE QTE OGC DFM NAME JDougherty*

Abell*

JMcKirgan*

DATE 12/10/2020 3/5/2021 4/9/2021 OFFICIAL RECORD COPY