ML22355A120

Request to Withdraw Administrative Controls for Adverse Weather Events During Operations from NAC-MPC CoC Renewal Application

ML22355A120
Person / Time
Site:	07201025
Issue date:	12/21/2022
From:	Baldner H NAC International
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
EPID L-2020-RNW-0031, CAC 001028, ED20220185
Download: ML22355A120 (1)

Text

Atlanta Corporate Headquarters 3930 East Jones Bridge Road, Suite 200 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com December 21, 2022 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Attn: Document Control Desk

Subject:

Request to Withdraw Administrative Controls for Adverse Weather Events During Operations from NAC-MPC CoC Renewal Application Docket No. 72-1025 CAC/EPID Nos. 001028/L-2020-RNW-0031

References:

1. ED20190141, Submission of a Request to Renew the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1025 for the NAC-MPC Cask System, December 18, 2019

2. Request for Additional Information for the Technical Review of the Application for Renewal of the Certificate of Compliance No. 1025 (CAC/EPID NOS. 001028/L-2019-RNW-0029), March 23, 2021

3. Submission of Responses to the Nuclear Regulatory Commissions (NRC)

Request for Additional Information for the Request to Renew the NRC Certificate of Compliance No. 1025 for the NAC-MPC Cask System, August 10, 2021

4. 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

5. ED20220034, Submission of Responses to the Nuclear Regulatory Commissions (NRC) Request for Additional Information for the Request to Renew the NRC Certificate of Compliance No. 1025 for the NAC-MPC Cask System, March 18, 2022

6. ED20220100, Supplement to the Submission of Responses to the Nuclear Regulatory Commissions (NRC) Request for Additional Information for the Request to Renew the NRC Certificate of Compliance No. 1025 for the NAC-MPC Cask System, July 22, 2022 ED20220185

U.S. Nuclear Regulatory Commission December 21, 2022 Page 2 of 2 NAC International Inc. (NAC) supplemented our NAC-MPC CoC renewal application on July 22, 2022 (Reference 6) with provisions for our general licensees to addresses NRCs Enforcement Guidance Memo (EGM)22-001, Enforcement Discretion for Noncompliance of Tornado Hazards Protection Requirements at Independent Spent Fuel Storage Installations. The administrative controls we proposed in FSAR Chapter 8 would have placed NAC-MPC important to safety structures, systems, and components in an analyzed condition should there have been a severe weather hazard predicted or issued for the area during operations as required by EGM 22-001. After discussions with NRC staff on a proposed Regulatory Guide to be issued in late 2023, endorsing Nuclear Energy Institute NEI 22-02 Guidelines for Weather-related Administrative Controls for Short Duration Outdoor Dry Cask Storage Operations, NAC has decided to withdraw the portion of Reference 6 dealing with administrative controls (Chapter 8, pages 8-2 and 8.A-2). Upon final approval of the NAC-MPC CoC renewal application, changes to FSAR pages 8-2 and 8.A-2 will not be incorporated into the next revision of the NAC-MPC FSAR.

If you have any comments or questions, please contact me on my direct line at 678-328-1252.

Sincerely, Heath M. Baldner Digitally signed by Heath M. Baldner Date: 2022.12.21 10:11:20 -05'00' Heath Baldner Director, Licensing ED20220185