ML22297A271
| ML22297A271 | |
| Person / Time | |
|---|---|
| Site: | 07201025 |
| Issue date: | 02/27/2023 |
| From: | Yoira Diaz-Sanabria Storage and Transportation Licensing Branch |
| To: | Cindy Bladey NRC/NMSS/DREFS |
| Shared Package | |
| ML22297A269 | List: |
| References | |
| Download: ML22297A271 (1) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 MEMORANDUM TO: Cindy Bladey, Chief Regulatory Analysis and Rulemaking Support Branch Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards FROM:
Yoira K. Diaz-Sanabria, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
USER NEED FOR RULEMAKING FOR CERTIFICATE OF COMPLIANCE RENEWAL, INITIAL ISSUE (AMENDMENT NUMBER 0),
AMENDMENT NUMBERS 1 THROUGH 8 TO THE NAC MULTI-PURPOSE CANISTER SYSTEM On December 18, 2019 (Agencywide Documents Access and Management System {ADAMS}
Accession No. ML19357A178), as supplemented on August 10, 2021 (ML21231A154),
March 18, 2022 (ML22077A831), July 22, 2022 (ML22203A127), and December 21, 2022 (ML22355A119), the applicant submitted an application to renew CoC No. 1025 for the NAC Multi-Purpose Canister (NAC-MPC) System, under the provisions of Title 10 of the Code of Federal Regulations (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: 1025.
Initial Certificate Effective Date: April 10, 2000, superseded by Renewed Initial Certificate Effective Date: Month DD, 2023.
Amendment Number 1 Effective Date: November 13, 2001, superseded by Renewed Amendment Number 1 Effective Date: Month DD, 2023.
Amendment Number 2 Effective Date: May 29, 2002, superseded by Renewed Amendment Number 2 Effective Date: Month DD, 2023.
CONTACT:
Christopher Markley, NMSS/DFM (301) 415-6293 February 27, 2023 Signed by Diaz-Sanabria, Yoira on 02/27/23
2 Amendment Number 3 Effective Date: Month DD, 2023.
Amendment Number 4 Effective Date: October 27, 2004, superseded by Renewed Amendment Number 4 Effective Date: Month DD, 2023.
Amendment Number 5 Effective Date: July 24, 2007, superseded by Renewed Amendment Number 5 Effective Date: Month DD, 2023.
Amendment Number 6 Effective Date: October 4, 2010, superseded by Renewed Amendment Number 6 Effective Date: Month DD, 2023.
Amendment Number 7 Effective Date: March 4, 2019, superseded by Renewed Amendment Number 7 Effective Date: Month DD, 2023.
Amendment Number 8 Effective Date: March 4, 2019, superseded by Renewed Amendment Number 8 Effective Date: Month DD, 2023.
SAR Submitted by: NAC International, Inc.
Renewal SAR submitted by: NAC International, Inc.
Title:
Final Safety Analysis Report for NAC Multi-Purpose Canister System (NAC-MPC System).
Docket Number: 72-1025.
Certificate Expiration Date: April 10, 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 No. 0) and Amendments Nos. 1-8:
FSAR UPDATE FOR RENEWED CoC The CoC holder shall submit an updated final safety analysis report (FSAR) to the Commission, in accordance with 10 CFR 72.4, within 90 days of the effective date of the CoC renewal. The updated FSAR shall reflect the changes resulting from the review and approval of the CoC renewal. The CoC holder shall continue to update the FSAR pursuant to the requirements of 10 CFR 72.248.
The CoC holder has indicated that changes will be made to the FSAR to address aging management activities resulting from the renewal of the CoC. This condition ensures that the FSAR 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.
The CoC holder proposed changes in FSAR Section 8.0, Operating Procedures that outlined administrative controls intended to clarify the approach to various short-term operations (ML22203A127). After additional consideration, in a subsequent supplement (ML22355A119) the CoC holder requested that those administrative controls no longer be included in the
3 renewal application. Staff confirms that these administrative controls are not considered to be included in this CoC condition.
2.
Added the following condition to the initial CoC (Amendment No. 0) and Amendments Nos. 1-8:
10 CFR 72.212 EVALUATIONS FOR RENEWED CoC USE Any general licensee that initiates spent fuel dry storage operations with the NAC-MPC System after the effective date of the CoC renewal and any general licensee operating a NAC-MPC 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 renewal of the CoC.
b.
As part of the document review required by 10 CFR 72.212(b)(6),
include a review of the FSAR changes resulting from the renewal of the CoC and the NRC safety evaluation report related to the renewal of the CoC.
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 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 a new NAC-MPC System after the CoC has been renewed either at a new or an existing general-licensed ISFSI. The renewal of the CoC is based on assumptions and analyses of the dry storage system and the sites where it is used. Licensees considering the use of the NAC-MPC System must evaluate it for use at their respective sites.
4 This condition also makes it clear that general licensees that currently use an NAC-MPC System will need to update their 10 CFR 72.212 reports, even if they do not put additional dry storage systems 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 No. 0) and Amendments Nos. 1-8:
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 they remain adequate for any changes to SSCs within the scope of the CoC renewal.
The applicant proposed the above CoC condition in appendix D to the renewal application. The staff recognizes that the CoC may continue to be amended after it has been renewed. This condition ensures that future amendments to the CoC address the renewed design bases for the CoC, including aging management considerations that may arise from the changes to the system in proposed future amendments.
- 4.
Revised initial CoC (Amendment No. 0) and Amendments Nos. 1-8 to address change to language in 10 CFR 72.210 and other updates to the regulations:
This change is made for consistency with the language currently in 10 CFR 72.210 and other cited regulations and is not pertinent to the safety review conducted for the renewal application.
Changes to the text are in bold, which only involves adding new text.
AUTHORIZATION The NAC-MPC System, which is authorized by this certificate, is hereby approved for general use by holders of 10 CFR Part 50 and 10 CFR Part 52 licenses for nuclear reactors at reactor sites under the general license issued pursuant to 10 CFR 72.210, subject to the conditions specified by 10 CFR 72.212, and the attached Appendix A and Appendix B.
Any CoC and technical specification language that discusses licensees under 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, was modified to also include licensees under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants. In addition, updates to the regulation citations referenced in the applicable CoC and technical specifications have been changed to reflect citations currently in the regulations.
5 CHANGES TO TECHNICAL SPECIFICATIONS 1.
Added Section A.5.X to appendix A to the technical specifications associated with the initial CoC (Amendment No. 0) and Amendments Nos. 1-8:
Added the new technical specification [A.5.X]:
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 procedure, and that reference shall be maintained even if the procedure 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 NAC-MPC 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 supplement to the FSAR. This specification ensures that programs or procedures address AMP activities required for extended storage operations.
Docket No.: 72-1025
6 ADAMS
References:
1.
Memo to REFS requesting Rulemaking (ML22297A271).
2.
Preliminary Renewed Certificate of Compliance No. 1025, Renewed Initial Certificate (ML22297A272) 3.
Preliminary Conditions for Cask Use and Technical Specifications, Renewed Initial Certificate, (ML22297A281) 4.
Preliminary Renewed Certificate of Compliance No. 1025, Renewed Amendment No. 1 (ML22297A273) 5.
Preliminary Conditions for Cask Use and Technical Specifications, Renewed Amendment No. 1, (ML22297A282) 6.
Preliminary Renewed Certificate of Compliance No. 1025, Renewed Amendment No. 2 (ML22297A274) 7.
Preliminary Conditions for Cask Use and Technical Specifications, Renewed Amendment No. 2 (ML22297A283) 8.
Preliminary Renewed Certificate of Compliance No. 1025, Renewed Amendment No. 3 (ML22297A275) 9.
Preliminary Conditions for Cask Use and Technical Specifications, Renewed Amendment No. 3 (ML22297A284)
- 10. Preliminary Renewed Certificate of Compliance No. 1025, Renewed Amendment No. 4 (ML22297A276)
- 11. Preliminary Conditions for Cask Use and Technical Specifications, Renewed Amendment No. 4 (ML22297A285)
- 12. Preliminary Renewed Certificate of Compliance No. 1025, Renewed Amendment No. 5 (ML22297A277)
- 13. Preliminary Conditions for Cask Use and Technical Specifications, Renewed Amendment No. 5 (ML22297A286)
- 14. Preliminary Renewed Certificate of Compliance No. 1025, Renewed Amendment No. 6 (ML22297A278)
- 15. Preliminary Conditions for Cask Use and Technical Specifications, Renewed Amendment No. 6 (ML22297A287)
- 16. Preliminary Renewed Certificate of Compliance No. 1025, Renewed Amendment No. 7 (ML22297A279)
- 17. Preliminary Conditions for Cask Use and Technical Specifications, Renewed Amendment No. 7 (ML22297A288)
- 18. Preliminary Renewed Certificate of Compliance No. 1025, Renewed Amendment No. 8 (ML22297A280)
- 19. Preliminary Conditions for Cask Use and Technical Specifications, Renewed Amendment No. 8 (ML22297A289)
7 20.
Preliminary Final Safety Evaluation Report for Renewal of Initial Certificate and Amendments Nos. 1 through 8, of CoC No. 1025 for the NAC Multi-Purpose Canister (ML22297A270)
Memo ML22297A271 OFFICE NMSS/DFM/STLB NMSS/DFM/STLB*
NMSS/DFM/STLB NAME CMarkley CMarkley YDiaz-Sanabria DATE Oct 25, 2022 Feb 22, 2023 Feb 27, 2023