ML21209A098

Submittal of Amendment 3 to NUHOMS Eos Certificate of Compliance No. 1042, Revision 2 - Revised Response for Obs 4-6

ML21209A098
Person / Time
Site:	07201042
Issue date:	08/04/2021
From:	Narayanan P Orano USA, TN Americas LLC
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML21209A097	List: ML21209A098
References
CAC 001028, E-59227, EPID L-2021-LLA-0055
Download: ML21209A098 (11)

Text

August 4, 2021 E-59227 U. S. Nuclear Regulatory Commission Columbia Office Attn: Document Control Desk 7160 Riverwood Drive Columbia, MD 21046 One White Flint North Tel: (410) 910-6900 11555 Rockville Pike

@Orano_USA Rockville, MD 20852

Subject:

Application for Amendment 3 to NUHOMS EOS Certificate of Compliance No. 1042, Revision 2 (Docket 72-1042, CAC No.

001028, EPID: L-2021-LLA-0055) - Revised Response for OBS 4-6

References:

[1] Letter E-58840, dated June 23, 2021, from Prakash Narayanan, Application for Amendment 3 to NUHOMS EOS Certificate of Compliance No. 1042, Revision 1 (Docket 72-1042, CAC No.

001028, EPID: L-2021-LLA-0055) - Response to Request for Supplemental Information

[2] Letter from Christian Jacobs to Prakash Narayanan, Acceptance Review of TN Americas LLC Application for Certificate of Compliance No. 1042, Amendment No. 3, to NUHOMS EOS System (Docket No. 72-1042) - Request for Supplemental Information, dated May 20, 2021

[3] Letter E-58329, dated March 31, 2021, from Prakash Narayanan, Application for Amendment 3 to NUHOMS EOS Certificate of Compliance No. 1042, Revision 0 (Docket 72-1042)

This submittal is a supplement to Reference [1] above and provides a revised response to a specific Observation (OBS), OBS 4-6, forwarded by Reference [2]

above. As a follow-up to the above Reference [1], the NRC and TN held a clarification call on July 14, 2021 for the purpose of discussing clarification to OBS 4-6.

Enclosure 2 herein provides a proprietary version of the response to OBS 4-6. Since Enclosure 2 is entirely proprietary, no public version is provided. The OBS response has a section stating the impact of the response on the application, both Technical Specifications (TS), and updated final safety analysis report (UFSAR), indicating which sections, tables, etc., have been changed.

Enclosure 3 provides a list of changed UFSAR pages. Enclosure 4 provides the UFSAR changed pages associated with this Revision 2 to the application for Amendment 3. Enclosure 5 provides the public version of the Enclosure 4 UFSAR changed pages.

For the UFSAR, replacement and new Amendment 3, Revision 2 pages are provided. The pages include a footer on each replacement or new page annotated Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.

Document Control Desk E-59227 Page 2 of 2 as 72-1042 Amendment 3, Revision 2, July 2021 with changes indicated by italicized text and revision bars. The new changes associated with the revised OBS response are further annotated with gray shading and an indication of the OBS is associated with the changes.

Certain portions of this submittal include proprietary information, which may not be used for any purpose other than to support the NRC staffs review of the application. In accordance with 10 CFR 2.390, TN Americas LLC is providing an affidavit (Enclosure 1), specifically requesting that this proprietary information be withheld from public disclosure. The submittal also includes security-related information.

Should the NRC staff require additional information to support review of this application, please do not hesitate to contact Mr. Glenn Mathues at 410-910-6538, or by email at Glenn.Mathues@orano.group.

Sincerely, Prakash Narayanan Chief Technical Officer cc: Chris Jacobs (NRC), Senior Project Manager, Storage and Transportation Licensing Branch Division of Spent Fuel Management

Enclosures:

1. Affidavit Pursuant to 10 CFR 2.390

2. RSIs and Responses (Proprietary)

3. List of Changed UFSAR Pages Involved in CoC 1042 Amendment 3, Revision 2

4. CoC 1042 Amendment 3, Revision 2 UFSAR Changed Pages (Proprietary)

5. CoC 1042 Amendment 3, Revision 2 UFSAR Changed Pages (Public)

Enclosure 1 to E-59227 AFFIDAVIT PURSUANT TO 10 CFR 2.390 TN Americas LLC )

State ofMaryl~M )-

• SS.

County of Montgomery )

I, Prakash Narayanan, depose and say that I am Chief Technical Officer of TN Americas LLC, duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information that is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.390 of the Commission's regulations for withholding this information.

The information for which proprietary treatment is sought is contained in Enclosures 2 and 4, as listed below:

• Enclosure 2 - RSis and Responses

• Enclosure 4 - Portions of certain updated final safety analysis report (UFSAR) chapters These documents have been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by TN Americas LLC in designating information as a trade secret, privileged or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commission ' s regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.

1) The information sought to be withheld from public disclosure involves portions of certain RSI responses and portions of the UFSAR, all related to the design of the NUHOMSEOS System, which are owned and have been held in confidence by TN Americas LLC.

2) The information is of a type customarily held in confidence by TN Americas LLC, and not customarily disclosed to the public. TN Americas LLC has a rational basis for determining the types of information customarily held in confidence by it.

3) Public disclosure of the information is likely to cause substantial harm to the competitive position of TN Americas LLC, because the information consists of descriptions of the design and analysis of dry spent fuel storage systems, the application of which provide a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with TN Americas LLC, take marketing or other actions to improve their product's position or impair the position of TN Americas LLC's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

Further the deponent sayeth not.

Prakash Narayanan Chief Technical Officer, TN Americas LLC Subscribed and sworn before me this 26tl1 day ofJuly, 2021.

s;eJ~

~ublic My Commission Expires fl/-! _at)~ 4 Page 1 of 1

Enclosure 2 to E-59227 RSIs and Responses Withheld Pursuant to 10 CFR 2.390

Enclosure 3 to E-59227 List of UFSAR Pages Involved in CoC 1042 Amendment 3, Revision 2 UFSAR Pages 2-22 4-177 4.9.8-10 4.9.8-63 Page 1 of 1

Enclosure 4 to E-59227 CoC 1042 Amendment 3, Revision 2 UFSAR Changed Pages Withheld Pursuant to 10 CFR 2.390

Enclosure 5 to E-59227 CoC 1042 Amendment 3, Revision 2 UFSAR Changed Pages (Public)

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Methodology for Evaluating Additional HLZCs in EOS-89BTH DSC This section provides the detailed methodology to qualify a new HLZC for EOS-89BTH DSC. HLZCs evaluated for use with the EOS-89BTH should follow the same methodology as described in Chapter 4, Section 4.9.8.2 for EOS-HSM and/or Appendix A.4, Section A.4.5.6 for HSM-MX depending on the storage module.

Similarly, the methodology laid out in Chapter 4, Section 4.9.8.3 should be followed to ensure that the various design criteria for transfer operations are satisfied. The following steps present the methodology to qualify new HLZCs for EOS-89BTH DSC:

July 2021 Revision 2 72-1042 Amendment 3 Page 2-22 All Indicated Changes are in response to revised Observation 4-6

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Proprietary Information on This Page Withheld Pursuant to 10 CFR 2.390 July 2021 Revision 2 72-1042 Amendment 3 Page 4-177 All Indicated Changes are in response to revised Observation 4-6

NUHOMS EOS System Updated Final Safety Analysis Report Rev. TBD, TBD A condition is also postulated where the air circulation is lost during transfer operation. To minimize the occurrence of this condition, the EOS-TC125 skid is equipped with redundant industrial grade blowers and each one of these blowers is capable of supplying the required minimum airflow rate. These blowers are also powered with a redundant power supply.

Both of the above scenarios (i.e., turning off air circulation to offload the EOS-89BTH DSC to the storage module or failure of the air circulation) will decrease the heat dissipation and result in a gradual increase of the maximum temperatures of the EOS-TC125 and EOS-89BTH DSC components. Therefore, for these conditions, an additional time limit is calculated to complete the transfer of the EOS-89BTH DSC from the EOS-TC125 to the storage module or to restart the air circulation or initiate other recovery operations to ensure that the peak fuel cladding temperature remains below the temperature limit of 752 °F established in [4.9.8-5].

Section 4.5.11 presents the thermal evaluation for the EOS-89BTH DSC during loading operations, including vacuum drying.

For all the normal, off-normal hot conditions, and accident design LCs considered in Table 4.9.8-8, insolation is considered per 10 CFR 71.71 [4.9.8-6].

4.9.8.3.2 EOS-89BTH DSC - Thermal Model for Transfer in EOS-TC125 July 2021 Revision 2 72-1042 Amendment 3 Page 4.9.8-10 Appendix B was added in Amendment 2.

All Indicated Changes are in response to revised Observation 4-6

NUHOMS EOS System Updated Final Safety Analysis Report Rev. TBD, TBD Proprietary Information on This Page Withheld Pursuant to 10 CFR 2.390 July 2021 Revision 2 72-1042 Amendment 3 Page 4.9.8-63 Appendix B was added in Amendment 2.

All Indicated Changes are in response to revised Observation 4-6