ML22180A266

Application for Amendment 3 to NUHOMS Eos Certificate of Compliance No. 1042, Revision 7 (Docket 72-1042, CAC No. 001028, EPID: L-2021-LLA-0055) - Clarification Regarding Annulus Temperatures During Vacuum Drying Operations

ML22180A266
Person / Time
Site:	07201042
Issue date:	06/29/2022
From:	Narayanan P Orano TN Americas, TN Americas LLC
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML22180A265	List: ML22180A266
References
CAC 001028, E-61137, EPID L-2021-LLA-0055
Download: ML22180A266 (13)

Text

June 29, 2022 E-61137 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 7 (Docket 72-1042, CAC No.

001028, EPID: L-2021-LLA-0055) - Clarification Regarding Annulus Temperatures During Vacuum Drying Operations

References:

[1] Letter E-58840 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 (New Scope) and Revised Responses to Request for Additional Information, dated June 23, 2021

[2] Letter from Christian Jacobs to Prakash Narayanan, TN Americas LLC Application for Certificate of Compliance No. 1042, Amendment No. 3, to NUHOMS EOS System (Docket No. 72-1042, CAC No. 001028, EPID: L-2021-LLA-0055) - Request for Supplemental Information, dated May 20, 2021

[3] Letter E-58329 from Prakash Narayanan, Application for Amendment 3 to NUHOMS EOS Certificate of Compliance No.

1042, Revision 0 (Docket 72-1042), dated March 31, 2021 This submittal provides further clarification regarding the issue of maintaining water in the annulus between the dry storage canister (DSC) and the transfer cask (TC) during loading operations. The issue was initially addressed in TN Americas LLCs (TN) response to Observation 4-9, in Reference [1]. However, based on a recent interaction with the NRC on the issue of maintaining water in the annulus between the DSC and the TC, TN is providing further clarification to address this issue.

Specifically, Chapter 4, Section 4.5.11 has been revised to address the issue of maintaining water in the annulus. There are no changes to Chapter 9, where there is an existing caution statement in Section 9.1.3, Section 9.1.4, and Section 9.2.2 to provide additional guidance on managing the TC/DSC annulus water level during loading and unloading operations.

Document Control Desk E-61137 Page 2 of 2 provides a listing of changed UFSAR pages resulting from this Revision 7 to the application for Amendment 3. provides the UFSAR changed pages associated with this Revision 7 to the application for Amendment 3. The changed pages include a footer annotated as "72-1042 Amendment 3, Revision 7, June 2022" with changes indicated by italicized text and revision bars. The changes are further annotated with gray shading or a gray box enclosing an added section , as well as a footer to distinguish the Amendment 3, Revision 7 changes from previous Amendment 3 changes. provides the public version of the Enclosure 7 UFSAR changed pages.

Certain portions of this submittal include proprietary information, which may not be used for any purpose other than to support the NRC staff's 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.

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, fl})~ 1<o.\...ee.\ \\a._<C>OY' 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. List of UFSAR Pages Involved in CoC 1042 Amendment 3, Revision 7

3. CoC 1042 Amendment 3, Revision 7 UFSAR Changed Pages (Proprietary)

4. CoC 1042 Amendment 3, Revision 7 UFSAR Changed Page (Public)

Enclosure I to E-61137 AFFIDAVIT PURSUANT TO 10 CFR 2.390 TN Americas LLC )

State of Maryland ) SS.

w County of /fo tJtf ~ )

I, Paul Oleyar, depose and say that I am Vice President of Business Operations 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 the following enclosure, as listed below:

• Enclosure 3 - 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 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.

~~~ ~

Paul Oleyar Vice President of Business Operations

~ :nbOO a day of June 2022.

/ tary 't1biic My Commission Expires l___;/1;~ . 3 Page I of 1

Enclosure 2 to E-61137 List of UFSAR Pages Involved in CoC 1042 Amendment 3, Revision 7 UFSAR Pages 4-100 4-101 4-102 4-103 4-104 4-121 4-234 Page 1 of 1

Enclosure 3 to E-61137 CoC 1042 Amendment 3, Revision 7 UFSAR Changed Pages Withheld Pursuant to 10 CFR 2.390

Enclosure 4 to E-61137 CoC 1042 Amendment 3, Revision 7 UFSAR Changed Pages (Public)

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 Thermal Evaluation for Loading/Unloading Conditions All fuel loading operations occur when the EOS-37PTH/EOS-89BTH DSCs and EOS-TC125/TC135/TC108 are in the spent fuel pool. The fuel is always submerged in free-flowing pool water permitting heat dissipation. After completion of the fuel loading, the TC and DSC are removed from the pool and the DSC is drained, dried, sealed, and backfilled with helium. These operations occur when the annulus between the TC and DSC remains filled with water.

During loading operations, part of the heat generated within the DSC is dissipated to the water within the annulus which may result in evaporation or boiling of the water.

To compensate the water lost due to evaporation or boiling, the water in the annulus is monitored and replenished with fresh water to maintain the water level about 12 inches from the top of the DSC shell, as noted in the fuel loading operation procedures in Section 9.1.

To provide an estimate of the boiling within the annulus, it is assumed that the total heat load from the DSC dissipates to the water in the annulus and no heat dissipation to ambient occurs. If the DSC shell is in contact with water, the decay heat will be used to evaporate and eventually boil the water in the annulus. The water bulk temperature remains constant at the saturated temperature if water starts to boil.

Observations show that the hot surface temperature in contact with boiling water is typically 10 to 15 °C (18 to 27 °F) higher than the boiling temperature for a heterogeneous nucleation process as noted in Chapter 15, Heterogenous Nucleation

[4-25]. The temperature difference between the heated surface and the boiling water is defined as Tsat.

Tsat. = (Tw - Tsat) 10 to 15 °C (18 to 27 °F)

Tw = hot surface temperature Tsat = saturated water temperature = 100 °C (212 °F) at atmospheric pressure For nucleate boiling water conditions, Tsat can be calculated using the following correlation from Equation 15.81 of [4-25].

0.33 q " l ilg Tsat = CSF DSC l ilg g ( l g ) kl CSF = liquid/surface constant = 0.013 (Table 15.1 of [4-25])

qDSC " = heat flux from DSC = 1,878 W/m2 (see below) l = dynamic viscosity of saturated water = 2.79E-4 N.s/m2 (See Table 2.15 of [4-25])

ilg = latent heat of vaporization = 970.3 Btu/lbm (Page E-21 of Reference [4-31]) =

2.257E6 J/kg

= surface tension of water = 0.059 N/m (Interpolated from Table 2.21 of [4-25])

g = gravity constant = 9.8 m/s2 June 2022 Revision 7 72-1042 Amendment 3 Page 4-100 All Indicated Changes are in support of the clarification of maintaining water in the annulus

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 l = density of saturated water = 958 kg/m3 (Page F-6 of [4-31])

g = density of saturated steam= 0.598 kg/m3 (Page E-21 of [4-31])

kl = conductivity of saturated water = 0.68 W/m-K (Page E-11 of [4-31])

All the properties are at 100 °C (212 °F).

The heat flux from DSC outer shell ( qDSC " ) is calculated as follows.

Q qDSC " = = 1,878 W / m2

( ODDSC Lann )

Q = maximum heat load per DSC = 50 kW ODDSC = Outer DSC shell diameter = 75.5 = 1.9177 m Lann = water height in annulus = DSC height - 12 = 186 - 12 = 174 = 4.4196 m Using qDSC " in Equation 15.81 of [4-25] listed above gives the Tsat for annulus.

Tsat,ann =2.4 C (4.3 F)

Tsat,ann is much lower than the required temperature gradient of 10 to 15 °C (18 to 27 °F) for heterogenous nucleation. This indicates that there would be limited boiling of water within the TC/DSC annulus. In addition, due to the large diameter of the DSC, the heat flux of 1,878 W/m2 at the DSC outer shell is significantly lower than the critical heat flux of about 106 W/m2 required for water to transition from nucleate boiling regime to transition boiling regime as noted in Section 10.2.1 of [4-32].

Therefore, the TC/DSC annulus water would always remain within the natural convection or nucleate boiling regime which enhances the heat dissipation.

In addition, since the TC/DSC annulus is open to atmosphere, the water temperature will not exceed the saturation temperature of water prior to draining. Therefore, assuming the temperature of water within the TC/DSC annulus as the saturation temperature is conservative.

Water in the DSC cavity is forced out of the cavity (blowdown operation) before the start of vacuum drying. Helium is used as the medium to remove water and subsequent vacuum drying occurs with a helium environment in the DSC cavity.

Since the DSC is filled with helium after drainage of water and water is maintained in the annulus between the DSC and TC, there is no time limit for completion of the vacuum drying process.

The vacuum drying of the DSC does not reduce the pressure sufficiently to reduce the thermal conductivity of the helium in the DSC cavity. Section 10-5 of [4-29] reviews the impact of low pressures on thermal conductivity of gases and concludes that when pressure is above 10-3 bar (0.75 Torr), there is a negligible change in the thermal conductivity with pressure.

June 2022 Revision 7 72-1042 Amendment 3 Page 4-101 All Indicated Changes are in support of the clarification of maintaining water in the annulus

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 With helium being present during vacuum drying operations and the TC/DSC annulus water temperature equal to water boiling temperature of 223 °F, the EOS-37PTH and EOS-89BTH DSC models described in Sections 4.5.2 and 4.5.7, respectively, are used in a steady-state analysis to determine the maximum fuel cladding temperatures for vacuum drying operations in the EOS-37PTH and EOS-89BTH DSCs. The maximum fuel cladding temperatures for vacuum drying operations in the EOS-37PTH and EOS-89BTH DSCs are, respectively, 648 °F at 50 kW decay heat load and 637 °F at 43.6 kW decay heat load, as noted in Table 4-32.

June 2022 Revision 7 72-1042 Amendment 3 Page 4-102 All Indicated Changes are in support of the clarification of maintaining water in the annulus

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 For the EOS-89BTH DSC with HLZC 4, 5, and 6 with a maximum heat load of 48.2 kW, the maximum fuel cladding temperature for vacuum drying operations is 653 °F based on the initial conditions for LC 1 as shown in Table 4.9.8-9.

The presence of helium during blowdown and vacuum drying operations and the cooling provided by water in the annulus between the DSC and TC eliminate the thermal cycling of fuel cladding during helium backfilling of the DSCs subsequent to vacuum drying. Therefore, the thermal cycling limit of 65 °C (117 °F) for short-term operations set by NUREG-1536 [4-1] is satisfied for vacuum drying operation.

June 2022 Revision 7 72-1042 Amendment 3 Page 4-103 All Indicated Changes are in support of the clarification of maintaining water in the annulus

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 The bounding unloading operation considered is the reflood of the EOS-37PTH/EOS-89BTH DSCs with water. For unloading operations, the DSC is filled with the spent fuel pool water through its drain port. During this filling operation, the EOS-37PTH/EOS-89BTH DSC vent port remains open with effluents routed to the plants off-gas monitoring system.

The maximum fuel cladding temperature during the reflood event is significantly less than the vacuum drying condition, owing to the presence of water/steam in the DSC cavity. Based on the above rationale, the maximum cladding temperature during unloading operation is bounded by the maximum fuel cladding temperature for vacuum drying operation.

June 2022 Revision 7 72-1042 Amendment 3 Page 4-104 All Indicated Changes are in support of the clarification of maintaining water in the annulus

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 TN Americas LLC, Updated Final Safety Analysis Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 16, USNRC Docket No. 72-1004.

Transnuclear, Inc., Updated Final Safety Analysis Report for NUHOMS HD Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 3, USNRC Docket No. 72-1030.

Not used.

Transnuclear Inc., Safety Analysis Report for the NUHOMS -MP197 Transport Packaging, dated January 10, 2014, with supplements dated March 12 and April 22, 2014, USNRC Docket No. 71-9302.

Rohsenow, Hartnett, Handbook of Heat Transfer Fundamentals, 2nd Edition, 1985.

CoC 1042 Appendix A, NUHOMS EOS System Generic Technical Specifications, Amendment 2.

W. Rohsenow, J. Hartnett and Y. Cho, Handbook of Heat Transfer, 3rd Edition, McGraw-Hill, 1998.

ANSYS FLUENT Theory Guide, Version 14.00, ANSYS Inc.

Ohio Gratings Product Catalog (http://www.ohiogratings.com/Content/pdfs/product/OGI_product_catalog.pdf)

Solar Absorptance and Thermal Emittance of Some Common Spacecraft Thermal-Control Coatings", NASA Reference Publication, 1121, April 1984.

B. E. Poling, etc., The Properties of Gases and Liquids, 5th Edition, McGraw Hill, 2001.

Ryerson Plastics, Edition 26.

Weast, Astle, CRC Handbook of Chemistry and Physics, 61st Edition, 1980-1981.

Kreith, Bohn, Principles of Heat Transfer, 4th Edition, 1986.

June 2022 Revision 7 72-1042 Amendment 3 Page 4-121 All Indicated Changes are in support of the clarification of maintaining water in the annulus

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 Figure 4-47 DSC Shell Temperature Profile for Initial Condition of Load Case 1 in Table 4-23 for EOS-37PTH DSC in EOS-TC125 June 2022 Revision 7 72-1042 Amendment 3 Page 4-234 All Indicated Changes are in support of the clarification of maintaining water in the annulus