ML23046A179

Tn Americas LLC, Application for Revision 8 of Certificate of Compliance No. 9358 for the Model No. TN-LC

ML23046A179
Person / Time
Site:	07109358
Issue date:	02/15/2023
From:	Shaw D TN Americas LLC
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
Shared Package
ML23046A178	List: ML23046A179
References
E-61863
Download: ML23046A179 (1)

Text

February 15, 2023 E-61863 Orano TN 7160 Riverwood Drive Suite 200 U. S. Nuclear Regulatory Commission Columbia, MD 21046 Attn: Document Control Desk USA One White Flint North Tel: 410-910-6900 Fax: 434-260-8480 11555 Rockville Pike Rockville, MD 20852

Subject:

Application for Revision 8 of Certificate of Compliance No. 9358 for the Model No. TN-LC, Docket No. 71-9358

References:

(1) NRC Certificate of Compliance for the Model No. TN-LC, USA/9358/B(U)F-96, Rev 7 (2) TN-LC Transportation Package Safety Analysis Report, Revision No. 10 In accordance with 10 CFR 71.38, TN Americas LLC (TN) submits this application to revise Certificate of Compliance (CoC) No. 9358 for the TN-LC packaging. The current CoC, Revision 7 [1], references the TN Americas consolidated application dated April 2022 [2].

Changes to the Safety Analysis Report (SAR) [2] are summarized in Enclosure 1, and preliminary changed pages are provided as Revision 11A in Enclosure 2. A consolidated SAR Revision 11 will be submitted upon completion of the NRC review.

The changed pages are indicated by Revision 11, 02/23 in the header of the page.

Each changed page includes a revision bar adjacent to the changed content. A public version of the Revision 11A SAR changed pages with proprietary information redacted is provided for public availability as Enclosure 3.

The NRC Electronic Information Exchange (EIE) system is used for submission of this application.

Certain portions of this submittal include proprietary information. In accordance with 10 CFR 2.390, TN Americas is providing an affidavit (Enclosure 4) requesting that this proprietary information be withheld from public disclosure.

A revised CoC is requested by September 2023 to support ongoing use of the TN-LC.

Should the NRC staff require additional information to support review of this application, please contact Peter Vescovi at 336-420-8325, or by email at peter.vescovi@orano.group.

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

E-61863 Document Control Desk Page 2 of 2 Sincerely, Digitally signed by Donis Shaw Donis Shaw Date: 2023.02.15 08:08:51 -05'00' Don Shaw Licensing Manager TN Americas LLC

Enclosures:

1. Summary of Changes to TN-LC SAR Revision 10.

2. TN-LC Transportation Package Safety Analysis Report Revision 11A Changed Pages (Proprietary)

3. TN-LC Transportation Package Safety Analysis Report Revision 11A Changed Pages (Public)

4. Affidavit Pursuant to 10 CFR 2.390 cc: Pierre Saverot, Senior Project Manager, U.S. Nuclear Regulatory Commission Peter Vescovi, Licensing Engineer, TN Americas LLC Kamran Tavassoli, Project Manager, TN Americas LLC

Enclosure 1 to E-61863 Summary of Changes to TN-LC SAR Revision 10 This enclosure provides a summary of the proposed changes to assist in understanding the revision of the affected sections of the safety analysis report (SAR). The changes are described, a justification for the change is provided, and the sections of the SAR that are impacted are identified. All pages with changes are included as a list of SAR pages at the end of this summary. Changed pages are annotated with revision markings.

Some items in the summary below corresponds to a description and justification of changes that affect one or more sections in the SAR. Design changes made to the package design are subject to design control measures commensurate with the original design as previously approved. The TN Americas (TNA) Quality Assurance program implementing procedures require the review of design changes for impact on the SAR. A TNA record of the SAR change is noted for these items as Licensing Transportation Licensing Change (TLC) 719358-0020.

1. Use of Damaged Fuel End Caps (TLC 719358-0020)

==

Description:==

The SAR is changed to use top and bottom damaged fuel end caps in lieu of a Fuel Assembly Can (FAC).

Justification:

During fabrication and during fit-up operations it was discovered that the required dimensions for the FAC are so close to the compartment opening dimensions that the FAC will not reasonably fit into the basket. Therefore, end caps are used instead. The end caps are sufficient to fulfill the intended function.

Impact:

The following SAR areas have been revised:

Appendix 1.4.1 Drawing 65200-71-91 is replaced by new Drawing 65200-71-92.

Appendix 1.4.5 Sections 2.1.1.3 and 2.1.1.7 Appendix 2.13.10, Section 2.13.10.2 Tables 2.13.10-1 through 2.13.10-4, 2.13.10-7 through 2.13.10-10, and 2.13.10-13 Section 7.1.1 Appendix 7.7.4, Sections 7.7.4.1 through 7.7.4.4 Section 8.2.2 Page 1 of 4

Enclosure 1 to E-61863

2. Correction to change failed to damaged (TLC 719358-020)

==

Description:==

Change the term failed to damaged in Appendix 6.10.5.

Justification:

There is no failed fuel in the TN-LC, only damaged fuel. This was an editorial mistake.

Impact:

Appendix 6.10.5 has been revised.

3. Table Values Corrections (TLC 719358-0020)

==

Description:==

Certain values in Tables 2.13.10-7 and 2.13.10-13 have been changed.

Justification:

Certain values initially reported in these SAR tables did not exactly match the original calculation and are being corrected.

Impact:

SAR Tables 2.13.10-7 and 2.13.10-13 have been revised.

4. Misaligned Notes / Notes Numbers in a Drawing (TLC 719358-0020)

==

Description:==

Fix misaligned notes / notes numbers in Drawing 65200-71-90.

Justification:

Editorial correction.

Impact:

Appendix 1.4.1 SAR Drawing 65200-71-90 has been revised.

5. Editorial Correction

==

Description:==

SAR Table 2.13.8-7 Note 1, regarding the frame evaluation and the sleeve and the hold-down ring, refers to SAR Section 2.13.8.1.2, which does not exist. The note has been corrected to reference SAR Section 2.13.8.5.1.2.

Page 2 of 4

Enclosure 1 to E-61863 Justification:

Considering the context of Table 2.13.8-7 Note 1, and the information in SAR Sections 2.13.8.5.1.1, Frame, and 2.13.8.5.1.2, BWR Sleeve and Hold-down Ring, it is obvious that Note 1 should have referred to Section 2.13.8.5.1.2.

Impact:

SAR Table 2.13.8-7 has been revised.

6. Editorial Correction

==

Description:==

The last column heading of SAR Table 2.13.9-2, addressing DLF values, with all values 1.10, refers to SAR Figure 2.13.9-21, but SAR Figure 2.13.9-21 does not exist. SAR Figure 2.13.9-19, the final figure of SAR Appendix 2.13.9, provides DLF values, with a graph showing 1.1 as the final value. SAR Table 2.13.9-2 has been corrected to refer to SAR Figure 2.13.9-19.

Justification:

Considering the context of SAR Table 2.13.9-2, and the information in SAR Figure 2.13.9-19, it is obvious that the DLF column heading of SAR Table 2.13.9-2 should have referred to SAR Figure 2.13.9-19.

Impact:

SAR Table 2.13.9-2 has been revised.

7. Editorial Change

==

Description:==

On SAR Page 7-8, in Step 13 and has been replaced with a comma.

Justification:

This corrects the grammar.

Impact:

SAR Page 7-8 has been revised.

8. Editorial Change

==

Description:==

On SAR Page 1.4.5-1, in the first paragraph, a period is inserted after transport cask in order to properly end the sentence.

Page 3 of 4

Enclosure 1 to E-61863 Justification:

This corrects the grammar.

Impact:

SAR Page 1.4.5-1 has been revised.

List of SAR Pages and Drawings Involved in CoC 9358 SAR Revision 11A SAR Pages 1.4.1-1 2.13.10-13 Dwg. 65200-71-90 2.13.10-15 Dwg. 65200-71-92 2.13.10-16 1.4.5-1 2.13.10-17 1.4.5-2 6.10.5-6 1.4.5-2a 7-1 1.4.5-5 7-2 1.4.5-26 7-3 2-3 7-8 2-4 7.7.4-1 2.13.8-48 7.7.4-1a 2.13.9-10 7.7.4-2 2.13.10-2 7.7.4-3 2.13.10-4 7.7.4-4 2.13.10-5 7.7.4-5 2.13.10-5a 7.7.4-6 2.13.10-12 8-14 Page 4 of 4

Enclosure 2 to E-61863 TN-LC Transportation Package Safety Analysis Report Revision 11A Changed Pages (Proprietary)

Withheld Pursuant to 10 CFR 2.390

Enclosure 3 to E-61863 TN-LC Transportation Package Safety Analysis Report Revision 11A Changed Pages (Public)

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Appendix 1.4.1 TN-LC Transport Package Drawings Drawing Number Title 65200-71-01 Revision 10 TN-LC Cask Assembly (11 sheets)

TN-LC 65200-71-20 Revision 5 Impact Limiter Assembly (2 sheets)

TN-LC Transport Packaging 65200-71-21 Revision 2 Transport Configuration (1 sheet)

Drawing Number Title TN-LC-NRUX Basket 65200-71-40 Revision 4 Basket Assembly (5 sheets)

TN-LC-NRUX Basket 65200-71-50 Revision 4 Basket Tube Assembly (5 sheets)

Drawing Number Title TN-LC-MTR Basket 65200-71-60 Revision 4 General Assembly (4 sheets)

TN-LC-MTR Basket 65200-71-70 Revision 4 Fuel Bucket (2 sheets)

Drawing Number Title 65200-71-80 Revision 4 TN-LC-TRIGA Basket (5 sheets)

Enclosure 1 Item 4 Drawing Number Title 65200-71-90 Revision 8 TN-LC-1FA Basket (5 sheets)

TN-LC-1FA PWR Basket 65200-71-92 Revision 0 Damaged Fuel End Caps (1 sheet)

TN-LC-1FA BWR 65200-71-96 Revision 5 Sleeve and Hold-Down Ring (2 sheets)

TN-LC-1FA 65200-71-102 Revision 7 21 Pin Can Basket (4 sheets)

Enclosure 1 Item 1 TN-LC-0100 1.4.1-1

Proprietary and Security Related Information for Drawing 65200-71-90, Rev. 8 Withheld Pursuant to 10 CFR 2.390

Proprietary and Security Related Information for Drawing 65200-71-92, Rev. 0A Withheld Pursuant to 10 CFR 2.390

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Appendix 1.4.5 TN-LC-1FA Basket NOTE: References in this Appendix are shown as [1], [2], etc. and refer to the reference list in Section 1.4.5.3.

1.4.5.1 TN-LC-1FA Basket Description The TN-LC cask is designed to contain the TN-LC-1FA basket assembly, with either (a) one fuel assembly (PWR or BWR) or (b) one pin can with up to 21 fuel rods (and spacers) while remaining completely supported by the transport cask. 25 pin can or pin can refers to the 1FA basket pin can that is designed to hold 21 fuel pins. Evaluations done with the 25 pin can bound the pin can design. Enclosure 1 Item 8 The basket structure is designed, fabricated and inspected in accordance with ASME B&PV Code Subsection NG [1]. Alternatives to the code are provided in Chapter 2. The overall length of the basket is 181.5 in. and has a diameter of 17.5 in. The details of the TN-LC-1FA basket are shown on drawing 65200-71-90, 65200-71-96 and 65200-71-102 in Chapter 1, Appendix 1.4.1.

The PWR basket structure consists of a thick square-shaped welded or bolted tube assembly which is attached to the solid aluminum support rails. The poison plate is sandwiched between each rail and frame on all four sides of the compartment. The BWR compartment, which slides inside the PWR compartment (to accommodate the smaller cross section of a BWR assembly), is comprised of a 17.5 inch long hold-down ring and a 164 inch long BWR sleeve. The hold-down ring is designed for BWR fuel assembly loading to provide lateral clearance for a fuel grapple, if necessary. After fuel loading, the hold-down ring is installed to provide continuous transfer of basket loads to the cask.

The minimum B-10 areal density of the poison plate is 16.7 mg/cm2 if boron aluminum alloy or metal matrix composite (MMC) is used. The minimum B-10 areal density of the poison plate is 20.0 mg/cm2 if Boral is used.

The basket structure is open at each end. Therefore, longitudinal fuel assembly or fuel pin can loads are applied directly to the cask body and not the fuel basket structure. The fuel assembly or fuel pin can is supported laterally by the stainless steel tube assembly. The basket is supported laterally by the basket rails and the cask shell. The solid aluminum basket rails are oriented parallel to the axis of the cask and are attached to the periphery of the basket to provide support and to establish and maintain basket orientation.

The pin can is a welded 5x5 square array of stainless steel 1 in. tubes which are wrapped in a stainless steel plate and slides inside the BWR basket. The top of the pin can has a bolted closure lid, and the four corner tubes are shortened at the top to install four solid rods: two with threads for the lid bolts and two with locating pins to facilitate installation of the lid underwater.

The closure lid has threads to attach a lifting handle to allow handling of the pin can.

A shear key, welded to the inner wall of the cask, mates with a notch in a basket support rail to prevent the basket from rotating during normal operations.

TN-LC-0100 1.4.5-1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 The maximum allowable heat load for the TN-LC cask with TN-LC-1FA basket is 3.0 kW.

1.4.5.2 TN-LC-1FA Basket Contents The TN-LC-1FA basket has three different types of intact or damaged payload: PWR fuel assemblies, BWR fuel assemblies, and fuel rods from PWR, BWR, MOX, and EPR fuel assemblies. Intact payloads are fuel assemblies or fuel rods with no known or suspected cladding defects greater than hairline cracks or pinhole leaks. Damaged PWR fuel assembly and damaged fuel rods are allowed payload in the TN-LC-1FA.

A damaged fuel (DF) assembly is defined as a fuel assembly containing missing fuel rods (including dummy fuel rods), or partial-length fuel rods, or fuel rods with known or suspected cladding defects greater than hairline cracks or pinhole leaks. The extent of cladding damage is to be limited such that the fuel assembly can be handled by normal means. Damaged fuel assemblies shall also contain top and bottom end fittings or nozzles or tie plates depending on the fuel type.

A DF rod is defined as a complete or partial-length fuel rod with known or suspected cladding defects greater than hairline cracks or pinhole leaks. The extent of cladding damage in the fuel rod is to be limited such that it can be handled by normal means and that a fuel pellet is not able to pass through the gap created by the cladding opening.

Damaged fuel assemblies shall be transported using damaged fuel end caps, shown on Drawing 65200-71-92 and described in Section 1.4.5.2.1.

1.4.5.2.1 PWR Fuel Assemblies The TN-LC-1FA basket is designed to transport one intact or damaged PWR fuel assembly, as specified in Table 1.4.5-1. The PWR fuel qualification table (FQT) is provided in Table 1.4.5-8 and Table 1.4.5-8a. The fuel to be transported is limited to a maximum assembly average initial enrichment of 5.0 wt. % 235U except for CE 15x15 class assemblies (maximal assembly initial enrichment of 3.6 wt. % 235U). The maximum assembly average burnup is limited to 62 GWd/MTU. The maximum allowable heat load for the TN-LC-1FA basket loaded with a PWR fuel assembly is 3.0 kW.

In addition to the poison plates provided in the basket, Poison Rod Assemblies (PRAs) may be used while transporting PWR fuel assemblies in order to ensure that the maximum reactivity is subcritical and below the Upper Subcritical Limit (USL). The PRAs consist of a cluster of absorber rods containing B4C pellets inserted into the guide tubes of the fuel assembly. A typical PRA is illustrated in Figure 1.4.5-5. The minimum required B4C content of the absorber rods in the PRA is 40 percent Theoretical Density (TD) (75 percent credit is taken in the criticality analysis, or 30 percent TD). A summary of the number of absorber rods required in the PRA for each PWR fuel class is shown in Table 1.4.5-4. PRA loading configurations are also illustrated in Figure 1.4.5-1 through Figure 1.4.5-4. The use of PRAs is optional.

TN-LC-0100 1.4.5-2 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Alternatively, in the absence of PRAs, burnup credit restrictions, as shown in Table 1.4.5-4a or Table 1.4.5-4b are required for 1FA PWR fuel transportation. The burnup/enrichment/cooling times are determined using PWR burnup credit approach and are required while transporting intact or damaged PWR fuel assembly in order to ensure that the maximum reactivity is subcritical and below the upper subcritical limit (USL). Note that burnup credit is not applicable to BW 15x15 fuel class.

The top and bottom damaged fuel end caps are stainless steel square-section structures, each made of a short sheet metal liner, and a closure plate welded to this liner (see Figure 1.4.5-7).

The top end cap assembly simply sits within the recess at the top of the basket, above the fuel assembly, which itself sits on top of the bottom end cap assembly, which rests on the bottom of the cask. Both end cap assemblies can freely slide along the axis of the cask but are captured by the basket compartment in any direction perpendicular to the axis of the cask cavity: neither end cap can come off of the basket compartment once the cask is closed because the axial gap between the basket and the cask cavity is smaller than either the thickness of the top end cap plate, or the combined thickness of the bottom end cap plate and its spacers. The liners are not required to fulfill this function but cover the slots through the basket walls and help the end caps remain straight as they slide within the compartment.

The total cross-sectional gap between the end caps and basket walls is limited to 0.13 inch maximum. As a result, once both end caps are installed above and below the damaged fuel assembly and the cask has been closed, they prevent any eventual small debris from escaping outside of the basket compartment.

The end caps plates have multiple drain holes to allow for efficient draining of the water during operations.

1.4.5.2.2 BWR Fuel Assemblies The TN-LC-1FA basket is designed to transport one intact BWR fuel assembly as specified in Table 1.4.5-6. Basket cell sleeves are used to reduce the area within the 1FA basket for BWR fuel. The BWR FQT is provided in Table 1.4.5-9. The fuel to be transported is limited to a maximum assembly average initial enrichment of 5.0 wt. % 235U. The maximum allowable assembly average burnup is limited to 62 GWd/MTU. The maximum allowable heat load for the TN-LC-1FA basket loaded with a BWR fuel assembly is 2.0 kW.

1.4.5.2.3 Fuel Rods in the Pin Can The TN-LC-1FA basket is designed to transport up to 21 intact or damaged light water reactor fuel rods in the pin can. This includes irradiated PWR, BWR, MOX, and EPR fuel rods. The maximum peak burnup for fuel rods is 90 GWd/MTU. Two designs are available, with cavity lengths of 180.24 in. (4,578.1 mm) or 169.55 in. (4,306.6 mm). The pin can with the shorter cavity length is heavily shielded with lead at the ends, while the pin can with the longer cavity length does not feature axial lead shielding. The longer cavity pin can is used only for EPR pins, which are much longer than a standard fuel rod (an EPR rod is approximately 179.24 in. long).

All other rods are transported in the shorter cavity pin can with heavy axial shielding.

TN-LC-0100 1.4.5-2a All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Table 1.4.5-1 PWR Fuel Specification for the Fuel to be Transported in the TN-LC-1FA Basket PHYSICAL PARAMETERS:

Fuel Class (1)(2) Intact or damaged unconsolidated B&W 17x17, WE 17x17, CE 16x16, B&W 15x15, WE 15x15, CE 15x15, WE 14x14, WE 16x16, and CE 14x14 class PWR assemblies (without control components) that are enveloped by the fuel assembly design characteristics listed in Table 1.4.5-2. Reload fuel manufactured by the same or other vendors but enveloped by the design characteristics listed in Table 1.4.5-2 is also acceptable.

Maximum Assembly + PRA + damaged fuel end caps 1850 lbs (839 kg)

(as applicable) Weight Assemblies are PWR assemblies containing fuel rods with known or suspected cladding defects greater that hairline cracks or pinhole leaks. The extent of damage in the fuel assembly, including non-cladding Damaged Fuel damage, is to be limited so that a fuel assembly maintains its configuration for normal conditions.

Damaged fuel assemblies shall also contain top and bottom end fittings. Damaged fuel assemblies may also contain missing or partial fuel rods.

Fissile Material UO2 Maximum Initial Uranium Content(4) 490 kg/assembly Maximum Unirradiated Assembly Length 178.3 inches (4,528.8 mm)

THERMAL/RADIOLOGICAL PARAMETERS:

Fuel Assembly Average Burnup, Enrichment and Per Table 1.4.5-8 and Table 1.4.5-8a (applicable to Minimum Cooling Time TN-LC Unit 01)

Maximum Planar Average Initial Enrichment 5.0(3) wt.% U-235 Maximum Decay Heat(5) 3.0 kW per Assembly

• 16.7 mg/cm2 (Natural or Enriched Boron Aluminum Alloy / Metal Matrix Composite Minimum B-10 content in poison plates loading (MMC))

• 20.0 mg/cm2 (Boral)

Minimum number of absorber rods per PRA as a Per Table 1.4.5-4 (Note that the use of PRAs is function of assembly class optional)

Burnup Credit Restriction in the absence of PRAs Per Table 1.4.5-4a or Table 1.4.5-4b TN-LC-0100 1.4.5-5 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Figure 1.4.5-7 Damaged Fuel End Caps TN-LC-0100 1.4.5-26 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 The impact limiter stainless steel cylinders, gussets, and end plates are designed to position and confine the balsa and redwood blocks to minimize the impact forces and to prevent excessive deformation of the limiters. The stainless steel shell is also designed to support and isolate the wood blocks from ambient moisture and pressure during normal operation.

The impact limiter and attachments are designed to withstand the impact loads and to prevent separation of the limiters from the cask during an impact. The design of the impact limiters and attachments is specified in Appendix 2.13.12.

2.1.1.3 TN-LC Cask Basket Assemblies The TN-LC cask will accommodate several different basket assemblies each containing a unique payload. The TN-LC-NRUX and TN-LC-MTR baskets consist of a base basket assembly that holds fuel buckets which, in turn, support the spent fuel assemblies. The TN-LC-TRIGA basket is comprised of a stack of basket segments that support the fuel assemblies/elements. The TN-LC-1FA basket has three modes of use. The base TN-LC-1FA basket may be loaded with a single PWR fuel assembly (which may be placed between the top and bottom damaged fuel end caps) or, with the addition of an internal sleeve, a single BWR fuel assembly. LWR fuel pins may be loaded into the pin can which is placed within the base TN-LC-1FA basket. A detailed description of each basket configuration is provided in Chapter 1, Appendices 1.4.2 through 1.4.5.

The details of each basket are shown on drawings provided in Appendix 1.4.1.

2.1.1.4 TN-LC-NRUX Basket Assembly The TN-LC-NRUX basket is designed to accommodate up to 26 fuel assemblies. The TN-LC-NRUX basket structure consists of two removable subassemblies. Those subassemblies are comprised of 13 stainless steel tubes welded together, wrapped in a stainless steel plate and capped on the bottom with a perforated stainless steel plate. The two basket tube subassemblies are centered in the basket assembly with a series of guide plates and guide plate supports. Two aluminum basket assembly tube caps are used to confine the contents of each tube and to limit axial motion of the fuel and tube subassemblies with respect to the cask.

The TN-LC-NRUX basket tube assembly bottom covers and tube caps, combined with top and bottom cask spacers, are designed to transmit longitudinal fuel assembly loads to the cask body.

The fuel assemblies are supported laterally by the stainless steel tubes, tube wraps, guide plates, guide plate supports, and basket assembly tube. The complete basket assembly is supported laterally by the cask shell. The basket structure is oriented parallel to the axis of the cask and establishes and maintains fuel assembly orientation.

2.1.1.5 TN-LC-MTR Basket Assembly The TN-LC-MTR basket is designed to accommodate up to 54 MTR fuel elements. The TN-LC-MTR basket is designed to accommodate eighteen fuel buckets. The fuel buckets are fabricated from stainless steel plates that are welded together to form three compartments and a perforated bottom plate. Three stacks of six fuel buckets each are centered in the basket assembly with two stainless steel divider plates and four thick outer plates. The thick outer plates have aluminum rails bolted onto the outside which provide the transition to the cask inside shell.

TN-LC-0100 2-3 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 The basket structure combined with the fuel buckets and top caps is designed to transfer longitudinal fuel assembly and bucket loads to the cask body. The fuel assemblies and buckets are supported laterally by the stainless steel outer plates and aluminum rails. The basket assembly is supported laterally by the cask shell. The basket structure and fuel buckets are oriented parallel to the axis of the cask and establish and maintain fuel orientation.

2.1.1.6 TN-LC-TRIGA Basket Assembly The TN-LC-TRIGA basket structure is comprised of five stacked TN-LC-TRIGA basket segments and a cask spacer to limit axial cask to basket gaps.

The TN-LC cask is designed to contain and support the TN-LC-TRIGA basket assembly, cask spacer, and up to 180 TRIGA fuel assemblies/elements.

Each of the basket structures consist of a welded assembly of stainless steel tubes (fuel compartments) separated by poison plates and surrounded by a larger stainless steel box or wrap and aluminum support rails.

Longitudinal fuel element loads are applied through the stack of baskets and then to the cask body. The fuel elements are supported laterally by the stainless steel structural boxes. The baskets are supported laterally by the aluminum basket rails. The basket rails are oriented parallel to the axis of the cask and are attached to the periphery of the basket to provide support as well as to establish and maintain basket orientation.

2.1.1.7 TN-LC-1FA Basket Assembly The TN-LC-1FA basket is comprised of the basket assembly, a pin can (when transporting loose fuel pins), damaged fuel end caps (when transporting damaged PWR fuel), fuel spacers, and cask spacers to limit axial cask-to-basket gaps.

The TN-LC cask is designed to contain the TN-LC-1FA basket assembly, one fuel assembly or pin can with up to 21 fuel pins, damaged fuel end caps (when transporting damaged PWR fuel),

and spacers while remaining completely supported by the transport cask.

The basket structure consists of a thick square-shaped welded or bolted tube assembly surrounded by poison plates and solid aluminum support rails.

The basket structure is open at each end. Therefore, longitudinal fuel assembly (with or without damaged fuel end caps) or pin can loads are applied directly to the cask body and not the fuel basket structure. The fuel assembly (with or without damaged fuel end caps) or pin can is supported laterally by the stainless steel tube assembly. The basket is supported laterally by the basket rails and the cask shell. The solid aluminum basket rails are oriented parallel to the axis of the cask and are attached to the periphery of the basket to provide support and to establish and maintain basket orientation.

A hold down ring is designed for BWR fuel assembly loading to provide lateral clearance for a fuel grapple, if necessary. After fuel loading, the hold down ring is installed to provide continuous transfer of basket loads to the cask.

The pin can is a welded 5x5 square array of stainless steel 1 in. tubes which are wrapped in a stainless steel plate. The top of the pin can has a bolted closure lid. The closure lid has threads to attach a lifting interface to allow handling of the pin can.

TN-LC-0100 2-4 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Proprietary Information on This Page Withheld Pursuant to 10 CFR 2.390 TN-LC-0100 2.13.8-48

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Table 2.13.9-2 Enclosure 1 Item 6 TN-LC-Dynamic Load Factor Results Summary Impulse Duration, Natural (t-Sec) from DLF Natural TN-LC Transport Packaging Time Appendix 2.13.12 Ratio From Frequencies DLF Period (reproduced in t/T Figure (Hz)

(T-Sec) Figure 2.13.9-17 and 2.13.9-19 Figure 2.13.9-18)

TN-LC-NRUX Basket End Drop 778.31 0.0013 0.025 19.46 1.10 TN-LC-MTR Basket End Drop 620.00 0.0016 0.025 15.50 1.10 TN-LC-TRIGA Basket End Drop 1005.27 0.0010 0.025 25.13 1.10 TN-LC-1FA Basket End Drop 665.53 0.0015 0.025 16.64 1.10 TN-LC-NRUX Basket Side Drop 560.03 0.0018 0.025 14.10 1.10 TN-LC-MTR Basket Side Drop 1105.00 0.0009 0.025 27.63 1.10 TN-LC-TRIGA Basket Side Drop 457.71 0.0022 0.025 11.44 1.10 TN-LC-1FA Basket Side Drop 490.00 0.0020 0.025 12.25 1.10 Note: For frequencies >100 Hz, a DLF value of 1.1 is used.

TN-LC-0100 2.13.9-10

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 2.13.10.2 Methodology The thermal analysis of the payload for NCT is described in Chapter 3. This analysis is performed to determine the transport cask components temperatures for the condition with maximum solar heating, maximum decay heat from the basket contents, and 100 °F ambient temperature. The results of the thermal analysis are used to evaluate the effects of axial and radial thermal expansion in the transport cask components.

Maximum temperatures of the TN-LC components and payload are obtained using ANSYS [1]

from 100°F ambient NCT thermal analysis results from Chapter 3. The maximum temperatures of the basket components are conservatively used as average basket component temperatures during hot NCT evaluations. For cold NCT evaluations, the average basket component temperature is conservatively assumed to be 250 °F, which bounds the maximum basket temperature from Chapter 3. It is conservatively assumed that the TN-LC cask inner shell does not thermally expand, except for the hot NCT 1FA pin can and damaged fuel end caps cases, and a reference temperature of 70 °F is used.

To verify that adequate clearance exists between the fuel and basket components and the cask cavity for free thermal expansion, the thermal expansions between various components were calculated and maximum fuel lengths were determined.

A 182.10" minimum cavity length is conservatively considered for TN-LC Unit #1 and 1FA contents.

Damaged fuel assemblies have the same configuration as intact fuel assemblies, except they contain missing or partial length or dummy fuel rods with cladding defects greater than hairline cracks or pinhole leaks, but not so great that a pellet could escape; therefore, the average temperature of a damaged fuel assembly between damaged fuel caps is assumed to be the same as the average temperature of an intact fuel assembly.

The average temperature of the damaged fuel end caps is conservatively based on the maximum average 1FA basket temperature for intact fuel under NCT.

TN-LC-0100 2.13.10-2 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 2.13.10.2.1 Maximum Allowable Irradiated Fuel Assembly Length The maximum fuel assembly length allowed in a fuel basket is calculated based on zero clearance between the cold cask cavity and the fuel assembly except for the damaged fuel case where the hot cask cavity length is considered.

For fuel loaded in fuel basket (TN-LC-NRUX/TN-LC-MTR/TN-LC-TRIGA) listed in Table 2.13.10-1, conservatively assume aluminum as fuel cladding material for the entire fuel assembly to calculate thermal expansion.

For PWR/BWR fuel assemblies or rods loaded in the TN-LC-1FA basket, the cladding materials are considered as Zircaloy-4 for the active fuel length and remaining fuel assembly components (including fuel fittings) are assumed to be SA-240, Type 304 stainless steel.

The maximum length of a hot irradiated fuel assembly (including irradiation growth), L FA ,Hot ,Max for PWR/BWR fuel assemblies or rods is determined as:

LFA, Hot ,Max = LFA,Cold ,Max + LFuel ,Cold ,Min x [1.26 x 10 5 x (Tavg,FA + 459.67)/1.8 3.78 x 10 3 ]

+ ( LFA,Cold ,Max LFuel ,Cold ,Min ) x Fitting x (Tavg , FA Tref )

= LFA,Cold ,Max x [1 + Fitting x (Tavg , FA Tref )]

+ LFuel ,Cold ,Min x [1.26 x 10 5 x (Tavg,FA + 459.67)/1.8 3.78 x 10 3 ]

LFuel ,Cold ,Min x Fitting x (Tavg , FA Tref )

The maximum length of a hot irradiated fuel element or assembly (including irradiation growth),

L FA ,Hot ,Max for research reactor fuel is determined as:

LFA,Hot ,Max = LFA,Cold ,Max x [1 + FA x (Tavg , FA Tref )]

Where:

L FA ,Cold ,Max = Maximum length of the irradiated fuel assembly or fuel elements at room temperature, in.,

L Fuel,Cold ,Min = Minimum length of the active fuel length at room temperature, in.,

Tavg,FA = Average fuel temperature, °F, FA = Co-efficient of Thermal Expansion of active fuel or fuel assembly at Tavg,FA,1/°F, Fitting = Co-efficient of Thermal Expansion of fuel assembly excluding active fuel region at Tavg,FA, 1/°F, Tref = Room temperature = 70 °F.

TN-LC-0100 2.13.10-4 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 The minimum hot length of the TN-LC fuel cavity ( LIC , FCav , Hot , Min ) needed to load hot fuel assemblies or fuel elements is characterized by the following formula:

LIC , FCav , Hot , Min LIC , FCav ,Cold LFA, Hot , Max Where:

LIC , FCav ,Cold = Minimum length of the fuel cavity at room temperature, in.,

For TN-LC NRUX/MTR/TRIGA fuel:

LFA,Cold ,Max LIC ,FCav ,Cold /[1 + FA x (Tavg ,FA Tref )]

For intact PWR/BWR fuel assemblies or rods:

{

LFA,Cold ,Max LIC ,FCav ,Cold LFuel ,Cold ,Min x [1.26 x 10 5 x (Tavg,FA + 459.67)/1.8 3.78 x 10 3 ]

}

+ LFuel ,Cold ,Min x Fitting x (Tavg ,FA Tref ) /[1 + Fitting x (Tavg ,FA Tref )]

For Damaged PWR Fuel Assembly using damaged fuel end caps:

The minimum hot length of the cask cavity (including top and bottom damaged fuel end caps) to allow the damaged FA thermal expansion, LIC ,DFC ,Hot ,Min is determined as:

LIC ,DFC= ,Hot ,Min LIC ,TC ,Cold ,Min x [1 + TC x (Tavg ,TC ,Shell Tref )] LLid ,Cold ,Max x [1 + DFC x (Tavg ,DFC Tref )]

= 182.10 x [1 + 8.50 x 10 6 x (210.5 -70)] 2.59 x [1 + 9.2 x 10 6 x (298 70)]

= 182.317 2.595= 179.722in

where, LIC ,TC ,Cold ,Max = Minimum cold length of the TC inner cavity (including top and bottom damaged fuel end caps lids) at room temperature = 182.10 in. (Table 2.13.10-1),

Tavg,TC,Shell = Minimum average temperature of TC inner shell = 210.5 °F (Table 2.13.10-2),

TC = CTE of TC inner shell (SA-240 Type XM-19) at Tavg,TC, Shell = 8.5x10-6/°F (see page 2.13.10-3),

LLid ,Cold ,Max = Maximum top and bottom damaged fuel end caps lid thickness at room temperature

= 2.59 in. (Table 2.13.10-1),

Tavg,DFC = Maximum average basket temperature for PWR FA = 298 °F (Table 2.13.10-2),

DFC = CTE of end caps lids (SA-240 Type 304) at Tavg,DFC = 9.2x10-6/°F (see page 2.13.10-3),

Tref = Room temperature = 70 °F.

Table 2.13.10-7 presents the maximum irradiated cold lengths of the various fuel assemblies, fuel rods or fuel elements that are allowed for transport in a fuel basket.

TN-LC-0100 2.13.10-5 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 2.13.10.2.2 Axial Clearance for Basket in the TN-LC Transport Cask Cavity The maximum hot length of a fuel basket ( L Basket ,Hot ) is:

L Basket ,Hot = L Basket ,Cold x [1 + SS,Basket x (Tavg,Basket Tref )]

Where:

L Basket ,Cold = Length of the basket assembly at room temperature, in .,

Tavg,Basket = Average temperature of basket, °F, SS,Basket = Thermal expansion coefficient of stainless steel basket at Tavg,Basket , 1/°F Tref = Room temperature = 70 °F.

The minimum hot length of the transport cask inner cavity ( L IC,TC ,Hot ) is conservatively assumed to be the minimum inner cavity length at room temperature ( L IC,TC ,Cold ) except for the TN-LC-1FA pin can basket and the damaged fuel case under hot NCT. The lengths of transport cask inner cavity at room temperature for various baskets are shown in Table 2.13.10-2.

The minimum hot length of the transport cask inner cavity with TN-LC-1FA pin can basket is calculated as:

L IC,TC ,Hot = L IC,TC ,Cold [1 + TC (Tavg,TC ,Shell Tref )]

TN-LC-0100 2.13.10-5a All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Table 2.13.10-1 Dimensions and Average Temperatures Used in Calculating Fuel Assembly Axial Thermal Expansion in the TN-LC Transport Cask TN-LC Basket in LIC,FCav,Cold, Tavg,FA, Cladding Operation Condition Transport Cask inches °F Materials NRUX 115.70 196 MTR-S 27.42 245 MTR-M 33.25 245 Aluminum (1)

MTR-L 42.00 245 TRIGA (Option 1) 31.00 250 TRIGA (Option 2) 48.05 250 Hot NCT 1FA (BWR) 182.10(2) 396 (100 °F Ambient) 1FA (PWR) 182.10(2) 401 1FA w/ end caps (Damaged PWR) 179.51(3) 401 1FA (Pin Can Options 1 Zircaloy-4 and 2) 180.24 456 1FA (Pin Can Option 3) 169.55 456 1FA (Pin Can Options 1 Cold NCT and 2) 180.24 335

(-40 °F Ambient) 1FA (Pin Can Option 3) 169.55 335 Notes:

1. [ ]

2. Conservatively considering TN-LC Unit #1 minimum as-built cavity length.

3. Based on the minimum cask cavity length (182.10) minus the maximum total thicknesses of the top and bottom lids of the end caps (1.27+1.32=2.59).

Table 2.13.10-2 Dimensions and Average Temperatures Used in Calculating Basket Assembly Axial Thermal Expansion in the TN-LC Transport Cask TN-LC Basket in Tavg,Basket, Tavg,TC,Shell, Operation Condition LBasket,Cold, in. LIC,TC,Cold, in.

Transport Cask °F °F NRUX 181.5 181.75 199 MTR 182.0 182.5 256 TRIGA 179.5 182.5 255 n/a Hot NCT 1FA (BWR) 181.5 182.10(3) 298 1FA (PWR) 181.5 182.10(3) 278 1FA pin can 181.91 182.10(3) 283(1) 210.5(2)

Cold NCT 1FA pin can 181.91 182.10(3) 185(1) n/a Notes:

1. Based on the average value among pin can, cask top and bottom maximum temperatures from Chapter 3.

2. Average temperature based on TN-LC transport cask temperature plot in Chapter 3. Thermal expansion for the transport cask is considered for this basket considering the higher heat load and the lower initial clearance.

3. Conservatively considering TN-LC Unit #1 minimum as-built cavity length.

TN-LC-0100 2.13.10-12 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Table 2.13.10-3 Dimensions and Average Temperatures Used in Calculating Basket Rail Axial Thermal Expansion in the TN-LC Transport Cask TN-LC Basket in Operation Condition LRail,Cold, LIC,Rail,Cold, Tavg,Rail, Transport Cask In. In. °F MTR 176.5 177 220 TRIGA 47.3 1 48.3 231 Hot NCT 1FA (BWR) 180.5 182.10(3) 261 1FA (PWR) 180.5 182.10(3) 268 1FA (Pin Can) 180.5 182.10(3) 268 Cold NCT 1FA (Pin Can) 180.5 182.10(3) 250 2 Notes:

1. At least 1 in. space among basket rail segments for thermal growth based on Chapter 1 drawings.

2. Based on the bounding maximum basket temperature for cold NCT.

3. Conservatively considering TN-LC Unit #1 minimum as-built cavity length.

4. The end caps case with damaged fuel is covered by the 1FA with intact FA.

Table 2.13.10-4 Dimensions and Average Temperatures Used in Calculating Basket Assembly Radial Thermal Expansion in the TN-LC Transport Cask Operation TN-LC Basket IDTC,Cold ODBasket,Cold WSS,Basket,Cold WRail,Cold Tavg,Basket Tavg,Rail Condition in Transport Cask In. In. In. In. o F o F

NRUX 18 17.55 n/a n/a 191 n/a MTR 18 17.55 12.94 2.305 256 220 TRIGA 18 17.55 12.12 2.715 255 231 Hot NCT 1FA (BWR) 18 17.55 11.375 3.0875 267 261 1FA (PWR) 18 17.55 11.375 3.0875 278 268 1FA (Pin Can) 18 17.55 11.375 3.0875 277 268 Cold NCT 1FA (Pin Can) 18 17.55 11.375 3.0875 250 1 250 1 Notes:

1. Based on the bounding maximum basket temperature for cold NCT.

2. The end caps case with damaged fuel is covered by the 1FA with intact FA.

TN-LC-0100 2.13.10-13 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Table 2.13.10-7 Maximum Allowable Irradiated FA Length in a Fuel Basket Operating Tavg,FA LIC,FCan,Cold LFA,Cold,Max TN-LC Basket Type Condition °F in. in.

NRUX 196 (1) 115.70 115.51 MTR-S 245 (1) 27.42 27.36 MTR-M 245 (1) 33.25 33.17 MTR-L 245 (1) 42.00 41.90 TRIGA (Option 1) 250 (1) 31.00 30.93 TRIGA (Option 2) 250 (1) 48.05 47.94 Hot NCT (100ºF Ambient) 1FA (BWR) 396 (2) 182.10(3) 181.67 1FA (PWR) 401 (2) 182.10(3) 181.66 1FA w/ end caps (Damaged 401 (2) 179.51 179.14 Enclosure 1 Item 1 PWR) 1FA (Pin Can Options 1 456 (2) 180.24 179.73 Enclosure 1 Item 3 and 2) 1FA (Pin Can Option 3) 456 (2) 169.55 169.08 1FA (Pin Can Options 1 Cold NCT 335 (2) 180.24 179.89 and 2)

(-40°F Ambient) 1FA (Pin Can Option 3) 335 (2) 169.55 169.23 Notes:

1. Fuel cladding material based on aluminum cladding.

2. Zircaloy assumed for 144 active fuel region and SA-240 type 304 for fuel assembly components excluding active fuel region.

3. Conservatively considering TN-LC Unit #1 minimum as-built cavity length.

Table 2.13.10-8 Minimum Axial Clearance for the Basket in Transport Cask Operating TN-LC Basket SS,Basket TC LBasket,Hot LIC,TC,Hot Bask_Axi_Hot_Gap Condition Type °F-1 °F-1 in. in. in.

NRUX 8.90E-06 n/a 181.71 181.75 0.04 MTR 9.11E-06 n/a 182.31 182.50 0.19 TRIGA 9.11E-06 n/a 182.31 182.50 0.19 Hot NCT 1FA (BWR) 9.20E-06 n/a 181.88 182.10 0.22 1FA (PWR) 9.16E-06 n/a 181.85 182.10 0.25 1FA (Pin Can) 9.17E-06 8.52E-06 182.27 182.32 0.05 Cold NCT 1FA (Pin Can) 8.97E-06 n/a 182.098 182.100 0.002 TN-LC-0100 2.13.10-15

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Table 2.13.10-9 Minimum Axial Clearance for the Basket Rail in TN-LC Transport Cask Operating TN-LC Basket Al,Rail LRail,Hot LIC,Rail,Hot Rail_Axi_Hot_Gap Condition Type °F-1 in. in. in.

MTR 1.30E-05 176.85 177.00 0.15 TRIGA 1.31E-05 47.40 48.30 0.90 NCT 1FA (BWR) 1.31E-05 180.95 182.10 1.15 1FA (PWR) 1.32E-05 180.97 182.10 1.13 1FA (Pin Can) 1.32E-05 180.97 182.10 1.13 Cold NCT 1FA (Pin Can) 1.24E-05 180.93 182.10 1.17

1. The end caps case with damaged fuel is covered by the 1FA with intact FA.

Table 2.13.10-10 Minimum Radial Clearance for the Basket in the TN-LC Transport Cask Operating TN-LC Basket SS,Basket Al,Rail ODBasket,Hot IDTC,Hot Bask_Rad_Hot_Gap Condition Type 1/°F 1/°F in. in. in.

NRUX 8.88E-06 1.28E-05 17.569 18.000 0.216 MTR 9.11E-06 1.30E-05 17.581 18.000 0.210 TRIGA 9.11E-06 1.31E-05 17.582 18.000 0.209 Hot NCT 1FA (BWR) 9.13E-06 1.31E-05 17.586 18.000 0.207 1FA (PWR) 9.16E-06 1.32E-05 17.588 18.000 0.206 1FA (Pin Can) 9.15E-06 1.32E-05 17.588 18.000 0.206 Cold NCT 1FA (Pin Can) 9.10E-06 1.31E-05 17.583 18.000 0.208

1. The end caps case with damaged fuel is covered by the 1FA with intact FA.

Table 2.13.10-11 Minimum Clearance for the Poison Plate Thermal Expansion in a Fuel Basket Hot NCT Cold NCT WWrap,Cold, in. 11.875 11.875 WPoison,Cold, in. 11.845 11.845 Tavg,Wrap, °F n/a n/a Tavg,Poison, °F 255 250 SS,Wrap, 1/°F n/a n/a Al,Poison, 1/°F 1.31E-05 1.31E-05 WWrap,Hot, in. 11.875 11.875 WPoison,Hot, in. 11.874 11.873 Poison Hot Gap, in. 0.001 0.002 TN-LC-0100 2.13.10-16 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Table 2.13.10-12 Minimum Axial Clearance for the Poison Plate Thermal Expansion in a Fuel Basket Basket Type TRIGA (Option 1) TRIGA (Option 2) 1FA Insert_End,Cold, in. 28.76 45.81 181 LPoison,Cold, in. 28.31 45.36 180.5 Tavg,Poison, °F 255 255 275 Poison, 1/°F 1.31E-05 1.31E-05 1.32E-05 LInsert_End,Hot, in. 28.760 45.810 181.000 LPoison,Hot, in. 28.379 45.470 180.988 Poison_Axi_Hot_Gap, in. 0.381 0.340 0.012 Table 2.13.10-13 Maximum Irradiated Lengths of Fuel Assemblies, Rods and Fuel Elements for TN-LC Transport Cask Operating LIC,FCan,Cold LFA,Cold,Max TN-LC Basket Type Condition in. (mm) in. (mm)

NRUX 115.70 (2,938.8) 115.51 (2,934.0)

MTR-S 27.42 (696.5) 27.36 (695.0)

MTR-M 33.25 (844.5) 33.17 (842.5)

MTR-L 42.00 (1,066.8) 41.90 (1,064.3)

TRIGA (Option 1) 31.00 (787.4) 30.93 (785.6)

TRIGA (Option 2) 48.05 (1,220.5) 47.94 (1,217.7)

Hot NCT (100 °F Ambient) 1FA (BWR) 182.10 (4,625.3) 181.67 (4,614.4) 1FA (PWR) 182.10 (4,625.3) 181.66 (4,614.4) 1FA w/ end caps (Damaged 179.51 (4,559.5) 179.14 (4,550.2)

PWR) Item 1 1FA (Pin Can Options 1 180.24 (4,578.1) 179.73 (4,565.1) and 2) 1FA (Pin Can Option 3) 169.55 (4,306.6) 169.08 (4,294.6) 1FA (Pin Can Options 1 Cold NCT 180.24 (4,578.1) 179.89 (4,569.2) and 2)

(-40 °F Ambient) 1FA (Pin Can Option 3) 169.55 (4,306.6) 169.23 (4,298.4)

Enclosure 1 Item 3 TN-LC-0100 2.13.10-17

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 A total of 28 isotopes are included in the material description of the burned FA, which includes 12 actinides and 16 fission products, listed Table 6.10.5-3. Loading curves show the acceptable combinations of average burnup and initial fuel enrichment for any cooling period after fuel assembly discharge. The acceptable combinations of average burnups and initial fuel enrichments for intact and damaged fuel are developed using the STARBUCS module with ORIGEN-ARP libraries generated using TRITON simulations. The ORIGEN-ARP libraries for the WE 17x17 and WE 14x14 are developed in Section 6.10.5.6, which are used in the STARBUCS models. The loading curves are developed for cooling periods of 5, 10, 15 and 20 years. The maximum initial fuel enrichment is determined for burnups 5, 10, 15, 20, 25, 30, 35, 40, 45, 50, 55 and 60 GWd/MTU. For each assembly type, the averaged burnup value, and the initial enrichment value satisfying the USL and all applicable biases and bias uncertainties associated with burnup credit are determined. The USL and all applicable biases and bias uncertainties are discussed in Section 6.10.5.4.2.1 and Section 6.10.5.4.2.2.

Computer Codes The evaluations are performed using SCALE 6.1.3 [3] and the ENDF/B-VII nuclear data. The burnup credit criticality analysis for intact fuel is performed using the STARBUCS module, the burnup credit criticality analysis for damaged fuel is performed using CSAS5 module (material composition using STARBUCS) and the fresh fuel criticality analysis is performed using CSAS5 control module of SCALE 6.1.3 [3].

The STARBUCS sequence provides a burnup credit loading curve search capability in addition to its initial capability of performing criticality safety analysis employing burnup credit. STARBUCS uses ORIGEN-ARP sequence to deplete the FA with given irradiation history and assigned ORIGEN-ARP libraries. The spent fuel compositions obtained after depletions are applied in the given KENO V.a models for criticality safety calculations.

The CSAS5 control module is used to calculate the effective neutron multiplication factor (keff) of the fuel in the TN-LC cask. The CSAS5 control module allows simplified data input to the functional modules BONAMI, CENTRM and KENO V.a. These modules process the required cross sections and calculate the keff of the system. BONAMI performs resonance self-shielding calculations for nuclides that have Bondarenko data associated with their cross sections. CENTRM provides the neutron spectra for processing self-shielded multigroup cross sections. Finally, KENO V.a calculates the keff of a three-dimensional system. A sufficiently large number of neutron histories are run so that the standard deviation is below 0.0005 for all evaluations.

Physical and Nuclear Data The criticality analysis uses the 238-group ENDF/B-VII cross-section library. The material definitions for fuel, cladding, 1FA PWR basket and TN-LC cask structural material are available in the SCALE 6.1.3,

[3], standard composition library. Details of materials of fuel and component design are included in Table 6.10.5-1. A cross-sectional view of the TN-LC basket is shown in Figure 6.10.5-1.

TN-LC-0100 Page 6.10.5-6 All indicated changes on this page are related to Enclosure 1 Item 2

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Chapter 7 Package Operations NOTE: References in this Chapter are shown as [1], [2], etc., and refer to the reference list in Section 7.5. A glossary of terms used in this Chapter is provided in Section 7.6.

This Chapter contains TN-LC cask loading and unloading procedures that are intended to show the general approach to cask operational activities. The procedures in this chapter are intended to show the types of operations that will be performed and are not intended to be limiting. Site-specific conditions and requirements may require the use of different equipment and ordering of steps to accomplish the same objectives or to meet acceptance criteria to ensure the integrity of the package.

A separate operations manual (OM) will be prepared for the TN-LC cask to describe the operational steps in greater detail. The OM, along with the information in this chapter, will be used to prepare the site-specific procedures that will address the particular operational considerations related to the cask.

7.1 TN-LC Package Loading The use of the TN-LC cask to transport fuel offsite involves (1) preparation of the empty cask for use; (2) verification that the fuel assemblies or fuel rods to be loaded in the TN-LC cask with the appropriate fuel-specific basket meet the criteria set forth in this document; (3) installation of a basket into the cask; and (4) loading fuel or placing loaded fuel buckets or pin cans in an empty TN-LC cask with the appropriate fuel-specific basket.

Offsite transport involves (1) preparation of the loaded cask for transport; (2) assembly verification leakage-rate testing of the package containment boundary; (3) placement of the cask onto a transportation vehicle; (4) installation of the impact limiters and (5) closure of the transportation container.

During shipment, the package contains any one of the TN-LC basket designs with its authorized contents as described in Chapter 1, Appendices 1.4.2 through 1.4.5. TN-LC Unit 01 shall only be loaded with the TN-LC-1FA basket with one PWR fuel assembly (Table 1.4.5-4a or Table 1.4.5-4b) (including top and bottom damaged fuel end caps if transporting a damaged PWR fuel assembly) or one pin can with up to 21 PWR fuel rods (Table 1.4.5-10a). Procedures are provided in this section for (1) transport of the cask directly from a site spent fuel pool and (2) transport of the cask directly from a site hot cell. Appendix 7.7 contains a sub-appendix for each basket design detailing its loading procedures.

7.1.1 TN-LC Cask Preparation for Loading Procedures for preparing the cask for use after receipt at the loading site are provided in this section and are applicable for shipment of casks loaded with any one of the basket designs and its respective approved contents.

1. Upon arrival of the empty TN-LC Package at the receiving site, perform receipt inspection. Inspect for damage, verify tamper-indicating seal is intact and perform radiation survey.

2. Open the transport container, and remove the empty TN-LC package.

TN-LC-0100 7-1 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23

3. Remove the tamper-indicating seals.

4. Remove the impact limiters from the cask.

5. Prior to removing the lid, sample the cask cavity atmosphere. If removing the lid at this stage, inspect the lid seals and sealing surfaces and verify that the O-ring seals have been replaced within the last 12 months.

6. Remove the skid tie-down assembly.

7. Take contamination smears on the outside surfaces of the cask. If necessary, decontaminate the cask.

8. The lid, bottom plug and all drain/vent/test ports incorporate O-ring seals. O-ring seals may be reused. Prior to installation, the seals and sealing surfaces shall be inspected.

Verify that the seals have been replaced within the last 12 months.

9. Remove the trunnion and pocket trunnion plugs.

10. Install the two lifting trunnions in place of the front trunnions plugs. Install the trunnion bolts and torque them to the torque specified on drawing 65200-71-01, Appendix 1.4.1, following the torquing sequence shown in Figure 7-1.

11. For the specific payload to be transported as part of the TN-LC package, verify that the basket type (TN-LC-NRUX, TN-LC-MTR, TN-LC-TRIGA, or TN-LC-1FA) and spacers, if required, are appropriate for the fuel to be transported.

NOTE: TN-LC Unit 01 shall only be loaded with TN-LC-1FA basket.

12. The candidate fuel assemblies/elements or fuel rods to be transported in a specific basket must be evaluated to verify that they meet the fuel qualification requirements of the applicable fuel specification as listed in Table 7-1. For the transportation of fuel within the TN-LC-1FA where burnup credit is employed for criticality safety, additional administrative controls to prevent misloading are also outlined in Appendix 7.7.4.

NOTE: TN-LC Unit 01 shall only be loaded with TN-LC-1FA basket (equipped with top and bottom damaged fuel end caps if loading a damaged PWR fuel assembly) with one PWR fuel assembly or one fuel rod pin can with up to 21 PWR or BWR intact or damaged fuel rods.

13. Prior to being placed in service, the cask is to be cleaned or decontaminated, as necessary.

14. Remove the bottom plug assembly, inspect the seals and sealing surfaces, verify that the O-ring seals have been replaced within the last 12 months, lubricate and reinstall the bottom plug assembly, torquing the bolts to the torque specified on drawing 65200-71-01, Appendix 1.4.1.

15. Remove the two test ports, the drain port and the vent port, inspect the seals and sealing surfaces, verify that the O-ring seals have been replaced within the last 12 months, reinstall each port (hand tight). The vent port on the lid may be left partially threaded to facilitate draining operations in step 14 of Section 7.1.2. The ports covers may be reinstalled over the two test ports at this time.

16. Engage the cask trunnions with the cask lifting yoke.

17. Rotate the cask to a vertical orientation, lift the cask, and place the cask in the designated preparation area.

TN-LC-0100 7-2 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 NOTE: Alternatively, the cask may be lifted in a horizontal orientation and placed on an onsite transfer trailer or upending frame; or the cask/transportation skid may be lifted together and placed in the appropriate location.

18. Install the shear key plug assembly and the pocket trunnion plugs.

19. If the cask lid has not already been removed, remove the bolts from the lid and lift the lid from the cask. Inspect the seals and sealing surfaces and verify that the O-ring seals have been replaced within the last 12 months,

20. Depending on the basket design being loaded, verify that a cask spacer of appropriate height is placed at the bottom of the cask cavity and/or bolted to the underside of the lid.

21. Insert the basket appropriate for the fuel to be transported into the cask, as listed in Table 7-2.

Notes:

• Install a bottom spacer in the basket if required by Chapter 1, Appendix 1.4.1 basket drawings.

• If loading a BWR fuel assembly in a TN-LC-1FA basket, place a BWR sleeve with a BWR hold down ring in the basket as shown in Drawing 65200-71-96.

• If loading fuel rods in a TN-LC-1FA basket, place a pin can inside the BWR sleeve with a hold down ring in the basket as shown in Drawing 65200-71-102.

• If loading a damaged PWR fuel assembly in a TN-LC-1FA basket, place the bottom damaged fuel end cap, as shown on Drawing 65200-71-92 at the bottom of the basket.

If using a bottom fuel spacer, the bottom end cap may be placed either under or on top of the bottom fuel spacer.

7.1.2 TN-LC Cask Wet Loading NOTE: The wet loading procedure described in this section is applicable only when using the TN-LC cask for loading fuel from a fuel pool into any one of the baskets listed in Chapter 1, Table 1-2.

Site-specific conditions or procedures may require the use of different equipment and ordering of steps than those described below to accomplish the same objectives or to meet acceptance criteria which ensure the integrity of the package.

CAUTION: Radioactive particulate matter may float to the surface of the water during underwater loading of the cask. Precautionary measures (filters, etc.) should be considered to minimize the radiation dose to personnel during these operations.

1. Fill the cask cavity with fuel pool water.

2. Lift the cask and position it over the cask loading area of the fuel pool.

3. Lower the cask into the fuel pool.

4. Place the cask in the fuel pool cask loading area.

5. Disengage the lifting yoke from the cask trunnions and move the yoke clear of the cask.

TN-LC-0100 7-3 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 7.2.2 Removal of Contents from TN-LC Cask 7.2.2.1 Unloading the TN-LC Cask in a Fuel Pool The procedure for unloading the cask in a fuel pool is summarized in this section. Site-specific conditions and requirements may require the use of different equipment and ordering of steps than those descried below to accomplish the same objectives or to meet acceptance criteria to ensure the integrity of the package.

CAUTION: Radioactive particulate matter may float to the surface of the water during underwater unloading of the cask. Precautionary measures (filters, etc.) should be considered to minimize the radiation dose to personnel during these operations.

1. Verify that the TN-LC cask receipt process in Section 7.2.1 has been completed.

2. Using the cask port tool, install a pressure gauge, isolation valve and vent line to the site radwaste system on the vent port. Open the cask cavity vent to the site radwaste system and sample the cask cavity atmosphere. Flush the cask cavity if necessary.

3. Remove the drain port plug and install an appropriate fitting in the drain port.

Alternatively, a cask port tool may be used to perform flooding and draining activities.

4. Install a pressure gauge, isolation valve, check valve, and a supply of clean water to the drain port/fitting.

5. Slowly feed water to enter the cask cavity.

6. Maintain the pressure in the cask cavity below 20 psig.

7. When the cask is filled with water, remove the vent and supply lines.

8. Loosen the lid bolts, leaving the threads engaged. Reverse the torquing sequence shown in Figure 7-1.

9. Slowly lower the cask into the pool until the lid is just above the surface.

10. Remove the lid bolts and lower the cask to its unloading position in the pool.

11. Detach the yoke from the trunnions and lift the lid from the cask.

12. Follow the fuel-specific unloading procedure as listed in Table 7-3 and described in Appendix 7.7.1 through 7.7.4.

Enclosure 1 Item 7

13. Following removal of the fuel assemblies or fuel rods, lift the cask from the spent fuel pool.

14. Open the drain and drain the pool water from the cavity. Continue draining the cavity until no appreciable water is noted. Optionally, the cavity may be drained after securing the cask body in the site work area.

TN-LC-0100 7-8

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 Appendix 7.7.4 TN-LC-1FA Basket Wet and Dry Loading and Unloading NOTE: References in this chapter are shown as [1], [2], etc., and refer to the reference list in Section 7.5. A glossary of terms used in this chapter is provided in Chapter 7, Section 7.6.

Site-specific conditions and requirements may require the use of different equipment and ordering of steps than those described below to accomplish the same objectives or to meet acceptance criteria to ensure the integrity of the package.

7.7.4.1 TN-LC-1FA Basket Wet Loading The starting condition for the following steps assumes completion of the preparation steps in Section 7.1.1 and steps 1-6 of Section 7.1.2 of Chapter 7.

The wet loading procedure described in this section is applicable only when using the TN-LC cask for loading LWR spent fuel assemblies (SFA) or fuel rods from a fuel pool into the TN-LC cask with TN-LC-1FA basket, which is submerged in a fuel pool.

A TN-LC cask with a TN-LC-1FA basket may be configured in one of four configurations:

• A TN-LC-1FA basket for transporting a PWR SFA,

• A TN-LC-1FA basket and top and bottom damaged fuel end caps placed inside the TN-LC-1FA basket when transporting a damaged PWR fuel assembly, or

• A BWR sleeve and hold-down ring placed inside the TN-LC-1FA basket when transporting a BWR SFA, or

• A TN-LC-1FA pin can placed inside the BWR sleeve when transporting individual LWR fuel rods.

Spacers may be required for shorter SFAs/rods. The TN-LC-1FA pin can may be loaded prior to placement in the cask or loaded while in the cask.

1. Verify that the TN-LC-1FA basket is configured appropriately for one of the payloads as listed above.

2. The potential for fuel misloading is essentially eliminated through the implementation of procedural and administrative controls. The controls instituted to ensure that acceptable SFAs or rods are placed into the TN-LC cask consist of the following:

• A package loading plan is developed to verify that candidate SFAs or rods meet the fuel qualification requirements of the applicable sections as listed in step 12 of Section 7.1.1.

• The loading plan, including the number of locations of PRAs if required, is independently verified and approved before fuel load.

TN-LC-0100 7.7.4-1 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23

• Additional Administrative Controls for Burnup Credit When burnup credit is employed for demonstration of criticality safety, additional administrative controls are required for verification of fuel assembly burnup and to prevent misloading. Fuel loading plans developed above shall also include these additional requirements:

A requirement to compare the reactor operating parameters for the irradiation period of the fuel assembly against those shown in Table 6.10.5-27 to ensure compliance with the isotopic depletion analysis A requirement for no fresh fuel in pool at time of loading, or verification that fuel being loaded into the cask is not fresh, either visually or by qualitative measurement A pool audit prior to loading, including visual verification of assembly identification numbers Identification of highly underburned and high reactivity (Table 6.10.5-28 and Table 6.10.5-29) fuel assemblies in the pool both prior to and after loading. Alternatively, the licensee can perform a misload evaluation using the methodology and criteria described in Section 6.10.5.8 to identify these highly underburned and high reactivity fuel assemblies. This evaluation will be subject to NRC review and approval A requirement that assemblies without visible identification number must have a quantitative confirmatory measurement prior to loading.

As described by the procedures above, multiple barriers are included to preclude misloading events.

• A fuel movement schedule is then written, verified, and approved based upon the loading plan. All fuel movements from any rack location are performed under strict compliance with the fuel movement schedule.

• If loading damaged fuel assemblies, verify that damaged fuel end caps are installed in the TN-LC-1FA Basket.

TN-LC-0100 7.7.4-1a All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23

3. Prior to loading SFAs or fuel rods into a TN-LC-1FA basket, the identity of the spent fuel is to be verified by two individuals using a video camera or other means. Read and record the identification number from the SFA/fuel rods, if applicable, and check this identification number against the site loading plan which indicates which SFAs/fuel rods are acceptable for transport.

4. Position the SFA or fuel rod for insertion into the TN-LC-1FA basket compartment:

• If loading an SFA, Load the PWR or BWR SFA as applicable into the TN-LC-1FA basket.

Record the identity of the SFA.

Install the top damaged fuel end cap if loading a damaged PWR fuel assembly.

• If loading fuel rods, Place a fuel can spacer as required.

Load the fuel rods to be transported into the TN-LC-1FA pin can.

After the TN-LC-1FA pin can has been loaded, check and record the identity of the fuel rods.

Install the pin can lid.

Following completion of above listed steps, the TN-LC cask is ready for draining as described in step 7, Section 7.1.2 of Chapter 7.

TN-LC-0100 7.7.4-2 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 7.7.4.2 TN-LC-1FA Basket Dry Loading The starting condition for the TN-LC-1FA basket assumes completion of the preparation steps in Section 7.1.1 and steps 1-4 of Chapter 7, Section 7.1.3.

A TN-LC cask with a TN-LC-1FA basket may be configured in one of four configurations:

• A TN-LC-1FA basket for transporting a PWR SFA,

• A TN-LC-1FA basket and top and bottom damaged fuel end caps placed inside the TN-LC-1FA basket when transporting a damaged PWR fuel assembly, or

• A BWR sleeve and hold-down ring placed inside the TN-LC-1FA basket when transporting a BWR SFA, or

• A TN-LC-1FA pin can placed inside the BWR sleeve when transporting individual LWR fuel rods.

Dry loading of a PWR/BWR fuel assembly must be conducted in a helium environment. Spacers may be required for shorter SFAs/rods. The TN-LC-1FA pin can may be loaded prior to placement in the cask or loaded while in the cask. This procedure assumes the TN-LC-1FA pin can is loaded with fuel rods prior to loading the can into the TN-LC cask.

1. Verify that the TN-LC-1FA basket is configured appropriately for one of the payloads as listed above.

2. The potential for fuel misloading is essentially eliminated through the implementation of procedural and administrative controls. The controls instituted to ensure that acceptable SFAs or rods are placed into the TN-LC cask consist of the following:

• A package loading plan is developed to verify that candidate SFAs or rods meet the fuel qualification requirements of the applicable sections as listed in step 12 of Section 7.1.1.

• The loading plan is independently verified and approved before fuel load.

• A fuel movement schedule is then written, verified, and approved based upon the loading plan. All fuel movements from any rack location are performed under strict compliance with the fuel movement schedule.

TN-LC-0100 7.7.4-3 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23

• If loading an SFA, Load the PWR or BWR SFA as applicable into the TN-LC-1FA basket.

Record the identity of the SFA.

Install the top damaged fuel end cap if loading a damaged PWR fuel assembly.

• If loading a TN-LC-1FA pin can, Place a fuel can spacer as required.

Load the fuel rods to be transported into the TN-LC-1FA pin can.

After the TN-LC-1FA pin can has been fully loaded, check and record the identity of the fuel rods.

Install the pin can lid.

Position the TN-LC-1FA pin can for insertion into the TN-LC cask. Note that this step is done with the TN-LC cask oriented horizontally.

The TN-LC-1FA pin can is inserted into the cask cavity using site transfer equipment.

Assemble the loaded TN-LC cask as required prior to upending.

Upend the TN-LC cask.

Following completion of the above listed steps, the TN-LC-1FA basket dry loading is continued in step 5, Section 7.1.3 of Chapter 7.

TN-LC-0100 7.7.4-4 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 7.7.4.3 TN-LC-1FA Basket Wet Unloading The starting condition for the following steps assumes completion of the unloading preparation steps in Section 7.2.1 and steps 1-12 of Section 7.2.2.1 of Chapter 7.

The TN-LC-1FA contents may be unloaded directly from the cask or the TN-LC-1FA basket may be removed from the cask, staged, and unloaded away from the cask. The sequence below assumes that the contents are unloaded directly from the cask.

1. If unloading BWR or PWR SFAs:

• If necessary, remove fuel spacer and top damaged fuel end cap.

• Remove TN-LC-1FA BWR hold-down ring if unloading a BWR SFA.

• Unload the PWR or BWR SFA as applicable using the appropriate grapple.

• Place the SFA in the appropriate location in the pool.

• Replace the BWR hold-down ring, if necessary.

2. If unloading fuel rods:

• Remove TN-LC-1FA BWR hold-down ring if necessary to gain access to the TN-LC-1FA pin can lid.

• Remove the TN-LC-1FA pin can lid.

• Unload the fuel rods from the TN-LC-1FA pin can using the appropriate handling tool.

• After all fuel rods have been removed, replace the TN-LC-1FA pin can lid.

• Replace the TN-LC-1FA BWR hold-ring if necessary.

Following completion of the above steps, the TN-LC-1FA basket wet unloading is continued in step 13, Section 7.2.2.1 of Chapter 7.

TN-LC-0100 7.7.4-5 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 7.7.4.4 TN-LC-1FA Basket Dry Unloading The starting condition for the following steps assumes completion of the unloading preparation steps in Section 7.2.1 and steps 1-6 of Section 7.2.2.2 or Section 7.2.2.3 of Chapter 7 for SFA or fuel rod unloading, respectively.

1. If unloading BWR or PWR SFAs:

• If necessary, remove fuel spacer and top damaged fuel end cap.

• Remove the TN-LC-1FA BWR hold-down ring if unloading a BWR SFA.

• Unload the PWR or BWR SFA as applicable using the appropriate grapple.

• Place the SFA in the appropriate location in the hot cell.

• Replace the BWR hold-down ring, if necessary.

Following completion of the above listed steps, the TN-LC-1FA dry unloading is continued in step 7, Section 7.2.2.2 of Chapter 7.

2. If unloading fuel rods from the TN-LC-1FA pin can:

Note that the TN-LC-1FA pin is unloaded while the TN-LC cask is horizontal.

• Install temporary shielding around the bottom plug and remove the bottom plug.

• Attach the transfer system ram to the base of the TN-LC-1FA pin can and push the TN-LC-1FA pin can out of the TN-LC cask.

• Stage the TN-LC-1FA pin can as required for removal of the fuel rods.

• Retract the TN-LC-1FA pin can back into the TN-LC cask. Alternately, the ram may be disconnected, and the TN-LC-1FA pin can may be left in the hot cell work area.

• Remove the transfer system ram as necessary to allow reattachment of the bottom plug.

• Reattach the bottom plug.

Following completion of the above listed steps, the TN-LC-1FA dry unloading is continued in step 7 Section 7.2.2.3 of Chapter 7.

TN-LC-0100 7.7.4-6 All indicated changes on this page are related to Enclosure 1 Item 1

TN-LC Transportation Package Safety Analysis Report Revision 11, 02/23 8.2 Maintenance Program 8.2.1 Structural and Pressure Tests Within 14 months prior to any lift of a TN-LC package, the trunnions shall be subject to either of the following:

• A test load equal to 300% of the maximum service load per ANSI N14.6 [3], paragraph 7.3.1(a) for single failure proof trunnions.

• Dimensional testing, visual inspection and nondestructive examination of accessible critical areas of the trunnions including the bearing surfaces in accordance with Paragraph 6.3.1(b) of ANSI N14.6 [3].

8.2.2 Leakage Tests The following containment boundary components shall be subject to periodic maintenance, and preshipment leakage testing in accordance with ANSI N14.5 [4]:

• Lid and seals

• Bottom Plug and seals

• Vent Port Plug Seal

• Drain Port Plug Seal The personnel performing the leakage test are qualified in accordance with SNT-TC-1A [2] or, alternatively, ISO 9712 [18].

Leakage Tests for NRUX, TRIGA, MTR MOX fuel (assembly or pins) and Damaged Fuel in 1FA basket Typical Method (ANSI N14.5 Test Frequency Acceptance Criteria TABLE A.1 [4])

(He)

Within 12 months prior to Each component individually Periodic A.5.3 shipment 1x10-7 ref cm3/s A.5.4 A.5.1 Before each shipment, after No detected leakage, sensitivity A.5.2 Pre-shipment the contents are loaded and of 10-3 ref cm3/s or better, unless A.5.8 the package is closed seal is replaced.

A.5.9 After maintenance, repair, (He) or replacement of Each component individually Maintenance A.5.3 containment components, 1x10-7 ref cm3/s A.5.4 including inner seals TN-LC-0100 8-14 All indicated changes on this page are related to Enclosure 1 Item 1

Enclosure 4 to E-61863 AFFIDAVIT PURSUANT TO 10 CFR 2.390 TN Americas LLC )

State of Mary land ) ss.

County of Howard

)

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 which 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 listed below:

• Enclosure 2 - Portions of certain chapters and appendices of the Safety Analysis Report (SAR) for Certificate of Compliance No. 9358 TN-LC, Revision 1 lA, Docket 71-9358 (Proprietary Version)

This document has 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, inctuded in the above referenced document, should be withheld.

1) The information sought to be withheld from public disclosure involves certain design details associated with the SAR analyses and SAR drawings for the TN-LC 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 a radioactive material transportation system, 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 AmericaLLC' 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

-th Subscribed and sworn before me this /3 day of February, 2023.

~~

Notary Public My Commission Expires ~_d_/J(Jd.\ KHYNESYA TAYLOR Notary Public Howard County Maryland My Commission Expires Oct. 5, 2025 Page 1 of 1