ML23198A298
| ML23198A298 | |
| Person / Time | |
|---|---|
| Site: | 07201042 |
| Issue date: | 07/17/2023 |
| From: | Orano TN Americas, TN Americas LLC |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML23198A288 | List: |
| References | |
| E-62379 | |
| Download: ML23198A298 (11) | |
Text
Enclosure 4 to E-62379 Page 1 Biennial Report of 10 CFR 72.48 Evaluations Performed for CoC 1042 for the Period 02/01/2022 to 07/17/2023 LR No.
721042-Description of Change, Test, or Experiment Summary of Evaluation 032 Revision 1 A summary of Revision 0 of this Licensing Review (LR) was provided in a previous biennial summary report, E-53168, dated January 29, 2020, ML20035C941. Revision 0 was written against Certificate of Compliance (CoC) 1042 Amendment 2 ongoing provisions prior to Amendment 2 becoming effective and addressed improving the EOS HSM system, specifically to drawing EOS01-3109 for material changes, drawing notes and dimensional changes. The purpose of Revision 1 is to reconcile the Revision 0 conclusions with the final Amendment 2 provisions.
The evaluation summary and conclusions in Revision 0 of this LR remain unchanged and are applicable to Revision 1. All eight 72.48 evaluation criteria were met.
The associated UFSAR changes were incorporated into UFSAR Revision 2.
080 Revision 2 A summary of Revision 0 of this LR was provided in a previous biennial summary report, E-53168, dated January 29, 2020, ML20035C941. Revision 0 was written against CoC 1042 Amendment 2 ongoing provisions prior to Amendment 2 becoming effective. The change corrected fuel material and source term input errors in the EOS-89BTH Dry Shielded Canister (DSC) accident dose rates. The purpose of Revision 1 is to reconcile the Revision 0 conclusions with the final Amendment 2 provisions.
The evaluation summary and conclusions in Revision 0 of this LR remain unchanged and are applicable to Revision 1. All eight 72.48 evaluation criteria were met.
The associated UFSAR changes were incorporated into UFSAR Revision 2.
to E-62379 Page 2 LR No.
721042-Description of Change, Test, or Experiment Summary of Evaluation 098 Revision 3 A summary of Revision 0 through Revision 2 of this LR was provided in a previous biennial summary report, E-62082, dated January 31, 2022, ML22031A167. Revisions 0, 1, and 2 was written against CoC 1042 Amendment 2 ongoing provisions prior to Amendment 2 becoming effective. The change involves a review of the design of the MX-LC and Retractable Roller Tray (RRT) components and associated equipment against their applicable licensing bases. The purpose of Revision 3 is to reconcile the Revision 0 conclusions with the final Amendment 2 provisions as well as address a finding and an observation from the NRC Inspection 72-1004/2022-202.
Finding 72-1004/2022-202-01 states that the design of the MX-LC does not meet the criteria of ASME NOG-1 in its entirety, and that TN did not take any exceptions to that standard during the initial licensing process. The finding concludes that the change to the MX-LC design should have resulted in a license amendment, which would have afforded the opportunity for NRC review and approval.
The corrective action from CAR 2022-117 is incorporated, which addresses an observation in the above-mentioned inspection report. The observation states that the use of a different seismic damping factor for the design of the MX-LC and RRT components represents a change in methodology that should have screened in for a full 10 CFR 72.48 Evaluation.
The evaluation summary and conclusions from Revision 0 through Revision 2 have changed regarding the inspection report finding of the design of the MX-LC and use of the MX-LC above the lift height restriction of Technical Specifications (TS) 5.2.1. Several answers under 6.0 are YES, so that the change may not be implemented without an amendment to CoC 1042, and the MX-LC shall not be used for loading/unloading the upper compartments of the HSM-MX prior to obtaining a licensing amendment.
The associated UFSAR changes under Revision 0 through Revision 2 were incorporated into UFSAR Revision 4.
The associated UFSAR changes under Revision 3 are incorporated into UFSAR Revision 5.
103 Revision 1 A summary of Revision 0 of this LR was provided in a previous biennial summary report, E-53168, dated January 29, 2020, ML20035C941. Revision 0 was written against CoC 1042 Amendment 2 ongoing provisions prior to Amendment 2 becoming effective. The change developed an acceptance criterion for the damaged coating area on the EOS-TC125/135 TC internal and external surfaces below which the effects on the thermal performance of the cask are insignificant. The purpose of Revision 1 is to reconcile the Revision 0 conclusions with the final Amendment 2 provisions.
The evaluation summary and conclusions in Revision 0 of this LR remain unchanged and are applicable to Revision 1. All eight 72.48 evaluation criteria were met.
The associated UFSAR changes were incorporated into UFSAR Revision 2.
to E-62379 Page 3 LR No.
721042-Description of Change, Test, or Experiment Summary of Evaluation 130 Revision 2 A summary of Revision 0 and Revision 1 of this LR was provided in a previous biennial summary report, E-62082, dated January 31, 2022, ML22031A167. Revision 0 was written against CoC 1042 Amendment 1 and Amendment 2 ongoing provisions prior to either amendment becoming effective. There were two changes.
The first addressed a revision to the HSM-MX thermal model with the EOS-37PTH DSC, and the second addressed the rebar configuration within the HSM-MX, which was optimized as a cost-saving measure. The purpose of Revision 1 was to reconcile the Revision 0 conclusions with the final Amendment 1 provisions.
The purpose of Revision 2 is to reconcile the Revision 1 conclusions with the final Amendment 2 provisions.
The evaluation summary and conclusions in Revision 0 and Revision 1of this LR remain unchanged and are applicable to Revision 2. All eight 72.48 evaluation criteria were met.
The associated UFSAR changes were incorporated into UFSAR Revision 4.
134 Revision 1 A summary of Revision 0 of this LR was provided in a previous biennial summary report, E-62082, dated January 31, 2022, ML22031A167. Revision 0 was written against CoC 1042 Amendment 2 ongoing provisions prior to Amendment 2 becoming effective. This change added ASME SA-517 grades A, B, E, F, and P material to basket grid plates (structural steel) for NUHOMS EOS-37PTH basket and NUHOMS EOS-37PTH damaged/failed fuel basket. The purpose of Revision 1 is to reconcile the Revision 0 conclusions with the final Amendment 2 provisions.
The evaluation summary and conclusions in Revision 0 of this LR remain unchanged and are applicable to Revision 1. All eight 72.48 evaluation criteria were met.
The associated UFSAR changes were incorporated into UFSAR Revision 4.
142 Revision 3 A summary of Revision 0 through Revision 2 of this LR was provided in a previous biennial summary report, E-62082, dated January 31, 2022, ML22031A167. Revision 0 was written against CoC 1042 Amendment 1 and Amendment 2 ongoing provisions prior to either amendment becoming effective. This change involved minor changes to the bottom chamfers on the inner top cover plate and outer top cover plate and reduce the top shield plug (TSP) overall diameter to a specified minimum diameter. The purpose of Revision 1 was for an editorial update to utilize Revision 2 of the CoC 1042 UFSAR. The purpose of Revision 2 was to reconcile the Revision 1 conclusions with the final Amendment 1 provisions. The purpose of Revision 3 is to reconcile the Revision 0 conclusions with the final Amendment 2 provisions.
The evaluation summary and conclusions in Revision 0 through Revision 2 of this LR remain unchanged and are applicable to Revision 3. All eight 72.48 evaluation criteria were met.
Portions of the associated UFSAR changes were incorporated into UFSAR Rev 3 and portions were incorporated into UFSAR Revision 4.
to E-62379 Page 4 LR No.
721042-Description of Change, Test, or Experiment Summary of Evaluation 143 Revision 1 A summary of Revision 0 of this LR was provided in a previous biennial summary report, E-62082, dated January 31, 2022, ML22031A167. Revision 0 was written against CoC 1042 Amendment 2 ongoing provisions prior to Amendment 2 becoming effective. This change to the EOS DSC lifting lugs involves modifying the lifting lug plate geometry (for reduced area) and reconfiguring its weld to the DSC shell by reducing the weld size and changing the weld configuration. The purpose of Revision 1 is to reconcile the Revision 0 conclusions with the final Amendment 2 provisions.
The evaluation summary and conclusions in Revision 0 of this LR remain unchanged and are applicable to Revision 1. All eight 72.48 evaluation criteria were met.
The associated UFSAR changes were incorporated into UFSAR Revision 3.
146 Revision 3 A summary of Revision 0 and Revision 1 of this LR was provided in a previous biennial summary report, E-62082, dated January 31, 2022, ML22031A167. Revision 0 and Revision 1 were written against CoC 1042 Amendment 2 ongoing provisions prior to Amendment 2 becoming effective. This change provided an update to Section 4.5.11 of the EOS UFSAR and to UFSAR Sections 9.1.3, 9.1.4, and 9.2.2 to provide additional guidance on managing the TC/DSC annulus water level during loading and unloading operations. The purpose of Revision 2 is to reconcile the Revision 0 and Revision 1 conclusions with the final Amendment 2 provisions. Revision 3, based on TNs Corrective Action Report (CAR) 2022-076, required that the proposed activities required NRC approval. Therefore, the proposed activities were reverted back to be consistent with the licensing basis in Amendments 0, 1, and 2. Amendment 3 to CoC 1042 incorporated the proposed activities into the amendment application.
There is no evaluation summary for Revision 3. The associated UFSAR changes under Revision 3 were superseded by the changes under Amendment 3 and are incorporated into UFSAR Revision 5.
to E-62379 Page 5 LR No.
721042-Description of Change, Test, or Experiment Summary of Evaluation 147 Revision 1 A summary of Revision 0 of this LR was provided in a previous biennial summary report, E-53168, dated January 29, 2020, ML20035C941. Revision 0 was written against CoC 1042 Amendment 1 and Amendment 2 ongoing provisions prior to Amendment 1 and Amendment 2 becoming effective. Revision 0 addressed draining some water out of the annulus below the top edge of the DSC, while maintaining the thermal and shielding design functions during loading operations. The purpose of Revision 1 is to reconcile the Revision 0 conclusions with the final Amendment 1 and Amendment 2 provisions.
The evaluation summary and conclusions in Revision 0 of this LR remain unchanged and are applicable to Revision 1. All eight 72.48 evaluation criteria were met.
No associated UFSAR changes were required.
148 Revision 3 A summary of Revision 2 of this LR was provided in a previous biennial summary report, E-53168, dated January 29, 2020, ML20035C941. Revision 2 was written against CoC 1042 Amendment 1 and Amendment 2 ongoing provisions prior to Amendment 1 and Amendment 2 becoming effective. Revision 2, similar to LR 721042-147 Revision 0, addressed draining some additional water out of the annulus below the top edge of the DSC, while maintaining the thermal and shielding design functions during loading operations. The purpose of Revision 1 is to reconcile the Revision 0 conclusions with the final Amendment 1 and Amendment 2 provisions.
The evaluation summary and conclusions in Revision 2 of this LR remain unchanged and are applicable to Revision 3. All eight 72.48 evaluation criteria were met.
No associated UFSAR changes were required.
155 Revision 1 A summary of Revision 0 of this LR was provided in a previous biennial summary report, E-53168, dated January 29, 2020, ML20035C941. Revision 0 was written against CoC 1042 Amendment 1 and Amendment 2 ongoing provisions prior to Amendment 1 and Amendment 2 becoming effective. Revision 0 provided operational guidance on implementing TS 3.1.1 regarding vacuum drying operations.
The evaluation summary and conclusions in Revision 0 this LR remain unchanged and are applicable to Revision 1. All eight 72.48 evaluation criteria were met.
No associated UFSAR changes were required.
to E-62379 Page 6 LR No.
721042-Description of Change, Test, or Experiment Summary of Evaluation 228 Revision 2 A summary of Revision 0 and Revision 1 of this LR was provided in a previous biennial summary report, E-62082, dated January 31, 2022, ML22031A167. Revision 0 and Revision 1 were written against CoC 1042 Amendment 2 ongoing provisions prior to Amendment 2 becoming effective. This change under Revision 0 determined the transfer time limit for the EOS-TC125 loaded with the EOS-37PTH DSC with 30 kW maximum heat load in heat load zone configurations (HLZCs) numbers 4, 5, and 6. The revision 1 change determined the transfer time limits for the EOS-TC125 loaded with the EOS-37PTH DSC with maximum heat load of 34.4 kW in HLZC number 8 and 31.2 kW in HLZC number 9. The purpose of Revision 2 is to reconcile the Revision 0 and Revision 1 conclusions with the final Amendment 2 provisions.
The evaluation summary and conclusions in Revision 0 and Revision 1 of this LR remain unchanged and are applicable to Revision 2. All eight 72.48 evaluation criteria were met.
The associated UFSAR changes were incorporated into UFSAR Revision 4.
242 Revision 1 A summary of Revision 0 of this LR was provided in a previous biennial summary report, E-62082, dated January 31, 2022, ML22031A167. Revision 0 was written against CoC 1042 Amendment 2 ongoing provisions prior to Amendment 2 becoming effective. This change evaluated correction to the lower inlet shield block in the lower compartment of the HSM-MX that was modeled as air instead of concrete in the thermal CFD model. The purpose of Revision 1 is to reconcile the Revision 0 conclusions with the final Amendment 2 provisions.
The evaluation summary and conclusions in Revision 0 of this LR remain unchanged and are applicable to Revision 1. All eight 72.48 evaluation criteria were met.
The associated UFSAR changes were incorporated into UFSAR Revision 4.
248 Revision 2 A summary of Revision 0 and Revision 1 of this LR was provided in a previous biennial summary report, E-62082, dated January 31, 2022, ML22031A167. This change evaluated a fabrication non-conformance documenting an under-thickness measurement on the outer shell of the EOS TC (EOS-TC125). Revision 1 to this evaluation provides additional information as to why ASME code requirements are not violated and expands the discussion regarding the methods of evaluation described in the UFSAR, used in the safety analyses or to establish design bases. Revision 2 of this Evaluation uses the TIP 3.5 Revision 29 forms, which changed Form 3.5-2 Screening and Form 3.5-3 Evaluation, based on the 2022 NRC triennial inspection, as documented in CAR 2022-059.
The evaluation summary and conclusions in Revision 0 and Revision 1 of this LR remain unchanged and are applicable to Revision 2. All eight 72.48 evaluation criteria were met.
No associated UFSAR changes were required.
to E-62379 Page 7 LR No.
721042-Description of Change, Test, or Experiment Summary of Evaluation 254 Revision 2 A summary of Revision 0 of this LR was provided in a previous biennial summary report, E-62082, dated January 31, 2022, ML22031A167. Revision 0 was written against CoC 1042 Amendment 2 ongoing provisions prior to Amendment 2 becoming effective. This change was for an evaluation of an alternative bottom forging single piece assembly for the EOS DSCs, the EOS-37PTH and the 89BTH. The purpose of Revision 1 is to reconcile the Revision 0 conclusions with the final Amendment 2 provisions. The purpose of Revision 2 revised Screening Question C based on the 2022 NRC triennial inspection, as documented in TN CAR 2022-059.
The evaluation summary and conclusions in Revision 0 of this LR remain unchanged and are applicable to Revision 1 and to Revision 2. All eight 72.48 evaluation criteria were met.
The associated UFSAR changes were incorporated into UFSAR Revision 4.
273 Revision 1 A summary of Revision 0 of this LR was provided in a previous biennial summary report, E-62082, dated January 31, 2022, ML22031A167. Revision 0 was written against CoC 1042 Amendment 2 ongoing provisions prior to Amendment 2 becoming effective. This change was for various fabrication improvements to the EOS-TS 125 transfer cask. The purpose of Revision 1 is to reconcile the Revision 0 conclusions with the final Amendment 2 provisions and to revise Screening Question C based on the 2022 NRC triennial inspection, as documented in TN CAR 2022-059.
The evaluation summary and conclusions in Revision 0 of this LR remain unchanged and are applicable to Revision 1 and to Revision 2. All eight 72.48 evaluation criteria were met.
The associated UFSAR changes were incorporated into UFSAR Revision 4.
284 Revision 1 This change involved the acceptance of a nonconforming condition for basket hardware on certain EOS-37PTH DSCs.
Specifically, the mechanical test results for the screws used to attach the R45 and R90 rails to the basket were suspect with respect to the minimum ultimate tensile strength (Su) and yield strength (Sy) requirements of the material specifications.
Revision 1 reconciled the Revision 0 conclusions with the final Amendment 2 provisions and revised Screening Question C based on the 2022 NRC triennial inspection, as documented in TN CAR 2022-059. Revision 1 also edited Evaluation Questions 2 and 4 for clarification with respect to malfunctions.
The evaluation summary and conclusions in Revision 0 of this LR remain unchanged and are applicable to Revision 1. All eight 72.48 evaluation criteria were met.
No associated UFSAR changes were required.
to E-62379 Page 8 LR No.
721042-Description of Change, Test, or Experiment Summary of Evaluation 285 Revision 1 A summary of Revision 0 of this LR was provided in a previous biennial summary report, E-62082, dated January 31, 2022, ML22031A167. Revision 0 was written against CoC 1042 Amendment 2 ongoing provisions prior to Amendment 2 becoming effective. This change was for the addition of optional dose reduction features for use with the EOS-HSMS-FPS (flat plate support). Revision 1 reconciled the Revision 0 conclusions with the final Amendment 2 provisions and revised Screening Question C based on the 2022 NRC triennial inspection, as documented in TN CAR 2022-059.
The evaluation summary and conclusions in Revision 0 of this LR remain unchanged and are applicable to Revision 1. All eight 72.48 evaluation criteria were met.
The associated UFSAR changes were incorporated into UFSAR Revision 4.
286 Revision 1 A summary of Revision 0 of this LR was provided in a previous biennial summary report, E-62082, dated January 31, 2022, ML22031A167. Revision 0 was written against CoC 1042 Amendment 2 ongoing provisions prior to Amendment 2 becoming effective. This change was for use of the shield bell, which will be placed on top of the EOS-TC125 top ring and the single piece composite lid shield, which will be placed on top of the inner top cover plate (ITCP) of the EOS-37PTH DSC. Revision 1 reconciled the Revision 0 conclusions with the final Amendment 2 provisions and revised Screening Question C and Evaluation Question 8, based on the 2022 NRC triennial inspection, as documented in TN CAR 2022-059.
The evaluation summary and conclusions in Revision 0 of this LR remain unchanged and are applicable to Revision 1. All eight 72.48 evaluation criteria were met.
No associated UFSAR changes were required.
to E-62379 Page 9 LR No.
721042-Description of Change, Test, or Experiment Summary of Evaluation 302 Revision 0 The change determines the transfer time limit for the EOS-TC125 loaded with the EOS-37PTH DSC with a maximum heat load of 44.42 kW for both heat load zone configurations (HLZCs) 1 and 4.
The thermal analysis was performed in Calculation EOS01-0455 and resulted in extending the time limit for transfer to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> total (15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> for the actual transfer and 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for recovery). All the component maximum temperatures remain below the current calculated design temperature limits for the EOS-TC125 neutron shield and gamma shield for the adjusted HLZCs 1 and 4. The average temperature of the neutron shield at 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> increased by 4 °F and the maximum temperature of the gamma shield at 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> increased by 2 °F. However, these minor increases maintain significant margins to the component temperature design limits.
Therefore, the minor temperature increases for the neutron shield and gamma shield have an insignificant impact on UFSAR design functions of both the neutron shield and the gamma shield and are well below the component temperature design limits. Since these minor temperature increases are below their limits with an insignificant impact on the thermal design functions compared to the design basis evaluation, the transfer time limit of 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> is acceptable for normal and off-normal transfer operations for EOS-37PTH DSC with a maximum heat load of 44.42 kW in HLZCs 1 and 4.
All eight 72.48 evaluation criteria were met.
No associated UFSAR changes were required.
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721042-Description of Change, Test, or Experiment Summary of Evaluation 303 Revision 0 The change revises the design of the variable spacer block and DSC stop plate used in the flat plate support (FPS) option of the EOS-HSM System DSC support structure. Specifically, this change incorporates the alternate variable spacer block used in conjunction with the alternate DSC stop plate as an option to the existing design, which is limited to the variable spacer block used in conjunction with the DSC stop plate.
The structural analysis for the alternate variable spacer block concluded that the change to incorporate the alternate variable spacer block has no effect on the structural design function of the FPS DSC support structure as described in the UFSAR. The structural analysis for the alternate DSC stop plate concluded that the change to incorporate the alternate DSC stop plate has no effect on the structural design function of the FPS DSC support structure as described in the UFSAR.
Based on the discussion above for the changes incorporating the alternate DSC stop plate and alternate variable spacer block, the structural design function of the FPS DSC support structure continues to be satisfied.
All eight 72.48 evaluation criteria were met.
The associated UFSAR changes are incorporated into UFSAR Revision 5.
305 Revision 0 The change is to reflect the design for the lifting lug slots in the shielding models of the top shield plug (TSP). This is for the EOS-37PTH DSC and EOS-89BTH DSC. The change does not involve any physical changes to the TSP.
The evaluation concluded that the dose increase is localized in the region near the TSP gap, and the effect on maximum dose rates and occupational exposure during the loading and transfer operations is < 5%. The dose rates and exposure provided for the loading and transfer operations are as low as reasonably achievable (ALARA) and are not governed by the TS.
Additionally, since there is no effect on the storage dose rates, the design remains well within the 72.104 and 72.106 limits. The change has a negligible effect on accident dose rates and does not increase the radiological consequences.
All eight 72.48 evaluation criteria were met.
The associated UFSAR changes were incorporated into UFSAR Revision 5.
to E-62379 Page 11 LR No.
721042-Description of Change, Test, or Experiment Summary of Evaluation 317 Revision 0 The change incorporates a high seismic design option for the EOS-HSM System. Specifically, the implementing document incorporates a high seismic option for the EOS-HSM (hereafter referred to as the EOS-HSM-HS) in new UFSAR drawing, consisting of the medium length segmented base HSMS option, with the Flat Plate Support (FPS) option for the DSC support structure, and the single-piece bottom forging option for the EOS DSC shell (medium length only).
The evaluation concluded that the changes incorporating the high seismic option of the EOS-HSM-HS, the applicable structural and thermal design criteria described in UFSAR sections 3.9.4 and 4.9.5, respectively, as well as the confinement design criteria for the DSC described in UFSAR Chapter 5 continue to be satisfied.
All eight 72.48 evaluation criteria were met.
The associated UFSAR changes are incorporated into UFSAR Revision 5.
319 Revision 0 The change involves a design change to the outlet vent vertical plate (OVVP) dose reduction hardware (DRH) option for the EOS segmented HSM with FPS (EOS-HSMS-FPS). Specifically, the change provides an option (referred to as OVVP Configuration 2) to use the standard OVC component, which has an overall height of 18 inches in lieu of the taller OVC component specified in the original OVVP DRH of 26 inches. Additionally, the limitation on the fresh concrete density of 148 pounds per cubic foot (pcf) is replaced by the reinforced concrete density of 150 +/-10 pcf used for standard EOS-HSM components.
The structural evaluation concluded this change was bounded by the structural analyses provided in the UFSAR.
All eight 72.48 evaluation criteria were met.
The associated UFSAR changes are incorporated into UFSAR Revision 5.