ML21246A136

Tn Americas LLC, Application for Amendment 3 to NUHOMS Eos Certificate of Compliance No. 1042, Revision 3 (Docket 72-1042, CAC No. 001028, EPID: L-2021-LLA-0055) - Revised Response to Obs 4-5 and Revised UFSAR Pages

ML21246A136
Person / Time
Site:	07201042
Issue date:	09/03/2021
From:	Narayanan P TN Americas LLC
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML21246A135	List: ML21246A136
References
CAC 001028, E-59394, EPID L-2021-LLA-0055
Download: ML21246A136 (15)

Text

Columbia Office 7160 Riverwood Drive Columbia, MD 21046 Tel: (410) 910-6900

@Orano_USA Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.

September 3, 2021 E-59394 U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852

Subject:

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

001028, EPID: L-2021-LLA-0055) - Revised Response to OBS 4-5 and Revised UFSAR Pages

References:

[1] Letter E-59227, dated August 4, 2021, from Prakash Narayanan, 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

[2] 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

[3] 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

[4] 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 [2] above, resulting from a clarification call on August 12, 2021 between the Nuclear Regulatory Commission (NRC) and TN Americas LLC (TN) for the purpose of discussing clarifications questions specific to Observations (OBS) 4-1, 4-4, 4-5, 4-8, and 4-11, forwarded by Reference [3] above. This submittal provides a revised response to OBS 4-5, a revision to UFSAR Sections 2.4.3.1 and 4.9.8.3.6, and a revision to the Graded Approach Evaluation forwarded by Reference [2] above. herein provides a proprietary version of the response to OBS 4-5. provides a public version of this response. The OBS response has a section stating the impact of the response on the application, both Technical

Document Control Desk E-59394 Page 2 of 2 Specifications (TS) and updated final safety analysis report (UFSAR), indicating which sections, tables, etc., have been changed. provides a list of changed UFSAR pages. Enclosure 5 provides the UFSAR changed pages associated with this Revision 3 to the application for Amendment 3. Enclosure 6 provides the public version of the Enclosure 5 UFSAR changed pages.

Amendment 3 proposes a graded approach for certain changes, which had been submitted as an entirely proprietary document in the initial application, identified as Enclosure 10, titled Graded Approach Evaluation. Based on the August 12, 2021 clarification call, a revised version of the Graded Approach Evaluation is provided as Enclosure 7. This document is no longer considered Proprietary.

For the UFSAR, replacement and new Amendment 3, Revision 3 pages are provided. The pages include a footer on each replacement or new page annotated as 72-1042 Amendment 3, Revision 3, August 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 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 Fuel Management

Enclosures:

1. Affidavit Pursuant to 10 CFR 2.390

2. RSIs and Responses (Proprietary)

3. RSIs and Responses (Public)

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

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

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

7. Graded Approach Evaluation

TN America~ LLC State of Marylafld County of Baltimore

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AFFIDAVIT PURSUANT TO 10 CFR 2.390 Enclosure I to E-59394 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 5, as listed below:

• - RSis and Responses

• - 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.

I) 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 NUHOMS EOS 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 t-A before me this~ day of September, 2021.

~

My Commission Expires !2}_; 30 I 2 0 2.. 3 Page 1 of 1 to E-59394 RSIs and Responses Withheld Pursuant to 10 CFR 2.390

RSIs and Responses - Public to E-59394 Page 1 of 3 Proprietary Information on Pages 1 through 3 Withheld Pursuant to 10 CFR 2.390.

to E-59394 List of UFSAR Pages Involved in CoC 1042 Amendment 3, Revision 3 Page 1 of 1 UFSAR Pages 2-22 2-23 4.9.8-18 to E-59394 CoC 1042 Amendment 3, Revision 3 UFSAR Changed Pages Withheld Pursuant to 10 CFR 2.390 to E-59394 CoC 1042 Amendment 3, Revision 3 UFSAR Changed Pages (Public)

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 September 2021 Revision 3 72-1042 Amendment 3 Page 2-22 Methodology for Evaluating Additional HLZCs in EOS-89BTH DSC 2.4.3.1 This section provides the detailed methodology to qualify a new HLZC for EOS-89BTH DSC. HLZCs evaluated for use with the EOS-89BTH shall 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 shall 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:

1. HLZCs shall satisfy the maximum per DSC and per zone/compartment heat loads listed in Figure 11 of the TS.

a) Similar to HLZC 5 and 6, a HLZC may require the total decay heat load per DSC to be adjusted to meet the requirements specified in Figure 11 of the TS. For these types of HLZCs, the same approach as presented in Section 4.9.8.1 and Appendix A.4 for HLZCs 5 and 6 shall be utilized to ensure the bounding temperatures and maximum internal pressure are determined.

2. Thermal evaluations based on the storage and transfer configuration described above shall be performed for each new HLZC to demonstrate that:

a) Thermal design criteria specified in Section 4.2, Chapter 4 are satisfied.

b) The minimum blocked vent accident condition durations specified in Section 5.1.3.1 of the TS for EOS-HSM and Section 5.1.3.2 of the TS for HSM-MX are satisfied.

c) The minimum transfer time limit required per LCO 3.1.3 of the TS are satisfied at the maximum heat load allowed per each HLZC.

All Indicated Changes are in response to OBS 4-4 and revised Observation 4-5

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 September 2021 Revision 3 72-1042 Amendment 3 Page 2-23

3. If design changes of the system result in updating the thermal evaluations of the storage or transfer configuration as described in Step 2, the impact of these design changes shall be evaluated separately. The design changes can be evaluated either based on the 10 CFR 72.48 process, or through an amendment submitted to NRC for review and approval.

4. Based on the thermal evaluation in Step 2 and Step 3 (if applicable), the impact of temperature changes on structural design functions shall be considered based on the methodology in Chapter 3.

HLZCs for EOS-89BTH DSC 2.4.3.2 HLZCs 1 through 6 that are qualified for use with the EOS-89BTH DSC based on the methodology presented in Section 2.4.3.1 are presented in Figure 2-2a through Figure 2-2f. In addition to these HLZCs, additional HLZCs may be qualified based on the methodology presented in Section 2.4.3.1. Note that HLZCs 1-3 were previously approved by the NRC in Amendment 0.

2.4.4 Shielding/Confinement/Radiation Protection As described earlier, the DSC shells are a welded stainless or duplex steel pressure vessel that includes thick shield plugs at both ends to maintain occupational exposures as low as reasonably achievable (ALARA). The top end of the DSC has nominally 10 inches of steel shielding and the bottom eight inches of steel shielding. The confinement boundary is designed, fabricated, and tested to ensure that it is leaktight in accordance with [2-15]. Section 2.4.2.1 provides a summary of the features of the DSCs that ensure confinement of the contents.

All Indicated Changes are in response to OBS 4-4 and revised Observation 4-5

NUHOMS EOS System Updated Final Safety Analysis Report Rev. TBD, TBD September 2021 Revision 3 72-1042 Amendment 3 Page 4.9.8-18 Appendix 4.9.8 is newly added in Amendment 3.

All Indicated Changes are in response to OBS 4-1 Proprietary Information on This Page Withheld Pursuant to 10 CFR 2.390

Graded Approach Evaluation to E-59394 Page 1 of 4 Background and Technical Discussion For the NUHOMS systems, Heat Load Zoning Configurations (HLZCs) are typically provided in the Technical Specifications (TS). This ensures that the maximum temperatures evaluated within the system remain within the allowable limits as approved by the U.S. NRC (NRC). Due to the large number of HLZCs proposed for each system and the repetitive nature of adding HLZCs, TN is proposing a graded approach to consolidate the key safety parameters with respect to the heat load of the dry shielded canister (DSC) into one Figure within the TS. This maximum heat load configuration (MHLC) is presented as Figure 11 in the TS, and individual HLZCs are relocated to Chapter 2 of the Updated Safety Analysis Report (UFSAR) for the EOS-89BTH when transferred in the EOS-TC125.

In developing this, TN utilized the graded approach from the Application for Amendment 16 to Certificate of Compliance (CoC) No. 1004. The graded approach in Amendment 16 to CoC 1004 considered various criteria to determine whether an item remains within the CoC, Inspections, Tests, and Examinations (ITE), or TS. However, no technical changes or methodology improvements were to be considered in that pilot application. This application proposes a combination of both, i.e., it utilizes the Graded Approach (based on criteria for Section 2, Approved Contents and the three risk insight questions), along with a new methodology to simplify the amount of information within the TS while ensuring the same level of safety assurance. Based on this approach,

1.

Figure 11 replaces the individual EOS-89BTH HLZCs within the TS while retaining three key limitations, as discussed below, to define the thermal performance of the system.

2.

Individual HLZCs are described in Chapter 2 of the UFSAR based on Figure 11 of the TS.

The following three conditions serve as guidelines to achieve the same intended objective (i.e.,

ensure the maximum component temperatures remain within the allowable limits as approved by NRC while also providing flexibility to TN and it users to customize HLZCs based on customer needs). The three conditions retained within Figure 11 of the TS include:

1.

A limit on the maximum allowable heat load within the DSC as required per 10 CFR 72.236(a).

This limit on the maximum heat load is based on the combined thermal performance of the DSC and the transfer cask (TC) during loading/transfer operations and in EOS-HSM/HSM-MX during storage operations. It is directly tied to the physical characteristics of the combined EOS-89BTH/HSM or TC thermal performance.

2.

A limit on the maximum allowable heat load within each fuel compartment/zone.

The DSC basket relies only on the physical characteristics (i.e., conduction and radiation) of the system to dissipate heat to DSC shell. It conservatively ignores internal convection which could be impacted by the heat load in each location.

Graded Approach Evaluation to E-59394 Page 2 of 4 These limits are based on the physical resistance encountered to dissipate heat (i.e., the internal assemblies encounter a greater thermal resistance to dissipate heat compared to the assemblies located in the peripheral locations). Therefore, the inner zones are limited to lower heat loads compared to the outer zones.

These limits also serve as an important function in establishing the limitations and bounds on the thermal models to simulate the various HLZCs.

3.

Limitations on the methodology to evaluate new HLZCs:

Use the same methodology as described in the UFSAR for Amendment 3 for EOS-89BTH HLZCs 4, 5, and 6.

Utilize the existing temperature and internal pressure criteria for EOS-89BTH DSC as identified in the UFSAR.

Maintain a minimum time limit for transfer operations as specified in LCO 3.1.3 of the TS.

Meet the Blocked Vent durations for the thermal monitoring requirements in Section 5.1.3 of the TS.

Graded Approach Evaluation to E-59394 Page 3 of 4 Graded Approach Assessment Form The following table presents the graded approach criteria based on Amendment 16 to CoC 1004.

CoC Condition/TS Identifier: TS Section 2.2

• All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),

Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.

• • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

CoC Requirement TS 2.0: Functional and Operating Limits 2.2 Fuel to be Stored in the EOS-89BTH DSC THERMAL PARAMETERS:

Heat load zoning configurations (HLZCs) enveloped by the maximum heat load configuration (MHLC) presented in Figure 11 of the TS for the EOS-89BTH are allowed for transfer in the EOS-TC125 and storage in the EOS-HSM or HSM-MX. Chapter 2, Section 2.4.3.2 of the UFSAR provides the specific HLZCs.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B -

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Maximum heat designed to be dissipated is a required parameter of the TS to meet the requirements of 10 CFR 236 (a).

To meet this requirement, the maximum allowable decay heat load for the EOS-89BTH DSC when transferred in the EOS-TC125 is specified in the MHLC (See Figure 11 in Technical Specification for Application to Amendment 3 of CoC 1042).

A2 Section 2.2 along with Figure 11 of the TS will require the qualification of HLZCs based on approved methodology. In addition, the internal pressure criteria during transfer accident condition and the minimum blocked vent duration criteria that is part of the TS will also require compliance. This will ensure the design limits related to confinement are satisfied.

A3 See responses to risk insight questions below.

Graded Approach Evaluation to E-59394 Page 4 of 4 Section 3 Limiting Conditions for Operation (LCOs)* and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will retaining or removing this requirement from the CoC result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No, since the key parameters, i.e., the total heat load of the DSC and the maximum heat load in each compartment are retained within the TS and any new HLZCs beyond HLZC 1-6 shall be qualified based on the approved methodology specified in the UFSAR per the TS.

It should also be noted that the shielding evaluation is conservatively based on the total heat load specified in Figure 11 of the TS.

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for independent spent fuel storage installation (ISFSI) or cask operation?

No, HLZC 1, 2 and 3 were reviewed and approved by NRC in Amendments 0 and 1 to CoC 1042. Similarly HLZC 4, 5 and 6 will be reviewed as part of application for Amendment 3 to CoC 1042.

For any HLZCs qualified based on Figure 11 of the TS beyond HLZC 1-6, the key parameters, i.e., the total heat load of the DSC and the maximum heat load in each compartment are retained within the TS.

In addition, the methodology to qualify the new HLZCs will be based on the same thermal models from Amendment 3 application utilized for HLZC 4, 5 and 6. This will ensure that no additional uncertainties are introduced when evaluating a new HLZC. It will also require that the various design criteria related to fuel cladding/component temperature limits and internal pressure limits are satisfied.

Apart from this, indirect constraints within the TS related to operations such as LCO 3.1.3 Transfer Time Limits and the blocked vent durations that are part of the Administrative Controls in Section 5.1.3 ensure that the same level of safety margin is maintained during operations.

Evaluation Summary Figure 11 the TS includes the key limitations such that the HLZCs can be relocated to Chapter 2 of the UFSAR.