ML22209A079

NAC, Supplement to the Nuclear Regulatory Commission'S (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No. 1015

ML22209A079
Person / Time
Site:	07201015
Issue date:	07/28/2022
From:	Fowler W NAC International
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML22209A078	List: ML22209A079 ML22209A080
References
CAC 001028, ED20220071, EPID L-2020-RNW-0031
Download: ML22209A079 (6)

Text

July 28, 2022 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Attn: Document Control Desk

Subject:

Supplement to the Nuclear Regulatory Commissions (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No. 1015 Docket No. 72-1015 CAC/EPID Nos. 001028/L-2020-RNW-0031

References:

1. ED2020120, NAC International, NAC-UMS System, 72-1015 Certificate of Compliance (CoC) Renewal Application, October 13, 2020

2. Request for Additional Information for the Technical Review of the Application for Renewal of the Certificate of Compliance No. 1015 (CAC/EPID Nos. 001028/L-2020-RNW-0031), December 21, 2021

3. ED20220022, Submittal of Responses to the Nuclear Regulatory Commissions (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No. 1015, March 3, 2022

4. ED20220036, Replacement Page for Responses to the Nuclear Regulatory Commissions (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No.

1015, March 18, 2022 NAC International Inc. (NAC) herein submits a supplement to the request to renew the NAC-UMS Cask System Certificate of Compliance (CoC). Since the initial submittal of the Renewal Application in October 2020, the NRC has approved NAC-UMS Amendments 8 and 9. Amendment 8 added the storage of damaged boiling-water reactor (BWR) spent fuel, including higher enrichments and higher burnup spent fuel, changes to the allowable fuel burnup range, expanded the boiling-water reactor class 5 fuel inventory that could be stored in the cask, and revised definitions in the Technical Specifications (TS).

The amendment also included a new design for a BWR damaged fuel can which introduced the use of XM-19 plate material, which has not been previously used in NAC-UMS designs. Since the approval of Amendment 8, NAC approved changes to the BWR damaged fuel transportable storage canister via 72.48s, which permits the use of 316/316L material on the following components: Shell, Bottom, Shell Lid, Location Lug, Cover Port, Lid Support, Spacer Ring, Key, Structural lid, Shield Lid Plug, Structural Lid Plug and Shied Lid-GTCC. The changes described above resulted in revisions to the CoC Renewal Application and Appendices B, C, and F.

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U.S. Nuclear Regulatory Commission July 28, 2022 Page 2 of 3 These changes resulted in changes to Renewal Application Tables 2.2-1, 2.5-1, and 3.2-1 to account for the new drawings, components, and materials. There were no new Storage Environments, Aging Mechanisms, Aging Effects, or Aging Management Activities created or identified. Amendment 9 corrected the effective thermal properties for PWR fuel assemblies used in the licensing basis ANSYS thermal models and updated modeling assumptions. The revised analyses did not exceed thermal limits or alter any operational time limits. Therefore, there were no changes to the CoC Renewal Application or its Appendices due to this amendment request.

Appendix C of the Renewal application, which contains FSAR changes, is being updated to include provisions for general licensees which addresses NRCs Enforcement Guidance Memo (EGM)22-001 issued on April 15, 2022 for the potential scenario of adverse weather events during ISFSI handling operations conducted outside. Administrative controls were added to FSAR Chapter 8, which include actions that may be used prior to and during ISFSI handling operations conducted outside. This will place important to safety structures, systems, and components in an analyzed condition should there be a severe weather hazard (e.g., weather advisory, warning, or watch) predicted or issued for the area. Only the new changes to Chapter 8 are being submitted no other FSAR pages or chapters are being resubmitted.

Appendix D contains our proposed CoC and TS changes, which have been revised to clarify the timeframe allowed for general licensees to establish and implement aging management programs.

NAC has prepared a supplement to Appendix F, NAC-UMS Design Basis Documents Review to include those design basis documents generated since its initial issue in December 2018. The NAC-UMS design basis documents reviewed as part of the NAC-UMS CoC Renewal Application include design drawings, specifications, calculations, non-conforming condition reports, 10 CFR 72.48 evaluations, and FSAR.

The documents were evaluated using the criteria established in NUREG-1927 to identify if any Time Limited Aging Analyses (TLAAs) were generated. The supplement provided in Enclosure 7 only includes the newly reviewed design basis documents. None of the documents reviewed met all six NUREG-1927 TLAA criteria. Therefore, it was concluded that there were no TLAAs generated in the original NAC-UMS design.

Only those Enclosures with changes are being resubmitted. The CoC Renewal Application (Enclosure 1) is being submitted in its entirety and changes are identified by revision bars. Enclosure 3 contains proprietary NAC calculation 30013-2001, Revision 3. Enclosure 4 contains a summary of the changes to the FSAR. The headers of the FSAR pages indicate Revision 22B and the submittal month and year and revision bars mark the FSAR text changes. Enclosure 5 contains the Proposed Certificate of Compliance and Technical Specification Changes. Enclosure 7 contains changes to the NAC-UMS Design Basis Document Review.

Per Attachment 1 to this letter, NAC requests information in Enclosure 3 to be withheld from public disclosure per 10 CFR 2.390. In accordance with NACs administrative practices, upon final acceptance of this application, the 21A, 22A and 22B changed pages will be reformatted and incorporated into the next revision of the NAC-UMS FSAR.

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ANAC Ffftl INTERNATIONAL U.S. Nuclear Regulatory Commission July 28, 2022 Page 3 of 3 If you have any comments or questions, please contact me on my direct line at 678-328-1236.

Wren Fowler Director, Licensing Engineering

Attachment:

- NAC International Affidavit Pursuant to 10 CFR 2.390

Enclosures:

Note, enclosure numbers are out of sequence in order to match the original renewal submittal (i.e.,

Reference 1)

1. Application for Renewal of the NAC-UMS System CoC (22B)

3. Appendix B -Time-Limited Aging Analyses (22B)

4. Appendix C - Final Safety Analysis Report Changed Pages, NAC-UMS FSAR, (22B)

5. Appendix D - Proposed Certificate of Compliance and Technical Specification Changes (22B)

7. Appendix F - NAC-UMS Design Basis Document Review (22B)

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NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 George Carver (Affiant), Vice President, Engineering and Support Services, of NAC International Inc.,

hereinafter referred to as NAC, at 3930 East Jones Bridge Road, Peachtree Corners, Georgia 30092, being duly sworn, deposes and says that:

1. Affiant has reviewed the information described in Item 2 and is personally familiar with the trade secrets and privileged information contained therein and is authorized to request its withholding.

2. The information to be withheld includes the following NAC Proprietary Information that is being provided to support the technical review of NACs Request to Renew the Certificate of Compliance (CoC) (No. 1015) for the NAC International UMS Cask System.

• Enclosure 3, Appendix B, 30013-2001, Fatigue Evaluation of MPC and UMS Storage System Components for Extended Storage, Rev. 3

3. NAC makes this application for withholding of proprietary information based upon the exemption from disclosure set forth in: the Freedom of Information Act (FOIA); 5 USC Sec. 552(b)(4) and the Trade Secrets Act; 18 USC Sec. 1905; and NRC Regulations 10 CFR Part 9.17(a)(4), 2.390(a)(4), and 2.390(b)(1) for trade secrets and commercial financial information obtained from a person, and privileged or confidential (Exemption 4). The information for which exemption from disclosure is herein sought is all confidential commercial information, and some portions may also qualify under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4.

4. Examples of categories of information that fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by competitors of NAC, without license from NAC, constitutes a competitive economic advantage over other companies.

b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product.

c. Information that reveals cost or price information, production capacities, budget levels or commercial strategies of NAC, its customers, or its suppliers.

d. Information that reveals aspects of past, present or future NAC customer-funded development plans and programs of potential commercial value to NAC.

e. Information that discloses patentable subject matter for which it may be desirable to obtain patent protection.

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NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 The information that is sought to be withheld is considered to be proprietary for the reasons set forth in Items 4.a, 4.b, and 4.d.

5. The information to be withheld is being transmitted to the NRC in confidence.

6. The information sought to be withheld, including that compiled from many sources, is of a sort customarily held in confidence by NAC, and is, in fact, so held. This information has, to the best of my knowledge and belief, consistently been held in confidence by NAC. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements, which provide for maintenance of the information in confidence. Its initial designation as proprietary information and the subsequent steps taken to prevent its unauthorized disclosure are as set forth in Items 7 and 8 following.

7. Initial approval of proprietary treatment of a document/information is made by the Vice President, Engineering, the Project Manager, the Licensing Specialist, or the Director, Licensing - the persons most likely to know the value and sensitivity of the information in relation to industry knowledge.

Access to proprietary documents within NAC is limited via controlled distribution to individuals on a need to know basis. The procedure for external release of NAC proprietary documents typically requires the approval of the Project Manager based on a review of the documents for technical content, competitive effect and accuracy of the proprietary designation. Disclosures of proprietary documents outside of NAC are limited to regulatory agencies, customers and potential customers and their agents, suppliers, licensees and contractors with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

8. NAC has invested a significant amount of time and money in the research, development, engineering and analytical costs to develop the information that is sought to be withheld as proprietary. This information is considered to be proprietary because it contains detailed descriptions of analytical approaches, methodologies, technical data and/or evaluation results not available elsewhere. The precise value of the expertise required to develop the proprietary information is difficult to quantify, but it is clearly substantial.

9. Public disclosure of the information to be withheld is likely to cause substantial harm to the competitive position of NAC, as the owner of the information, and reduce or eliminate the availability of profit-making opportunities. The proprietary information is part of NACs comprehensive spent fuel storage and transport technology base, and its commercial value extends beyond the original development cost to include the development of the expertise to determine and apply the appropriate evaluation process. The value of this proprietary information and the competitive advantage that it provides to NAC would be lost if the information were disclosed to the public. Making such information available to other parties, including competitors, without their having to make similar investments of time, labor and money would provide competitors with an unfair advantage and deprive NAC of the opportunity to seek an adequate return on its large investment ED20220071 Page 2 of 3

NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF GEORGIA, COUNTY OF GWINNETT Mr. George Carver, being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated herein are true and correct to the best of his knowledge, information and belief.

Executed at Peachtree Comecs, Georgia, this ~ day of ~ , 2022.

George Carver Vice President, Engineering and Support Services NAC International Subscribed and sworn before me this g;jfli day of fy: , 2022.

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