ML23205A238

Submittal of an Amendment Request for the NAC International Magnastor Cask System Amendment No. 14

ML23205A238
Person / Time
Site:	07201031
Issue date:	07/24/2023
From:	Baldner H NAC International
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
Shared Package
ML23205A237	List: ML23205A238 ML23207A112
References
ED20230100
Download: ML23205A238 (1)

Text

I NAC INTERNATIONAL Atlanta Corporate Headquarters 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com July 24, 2023 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Attn:

Document Control Desk

Subject:

Submission of an Amendment Request for the NAC International MAGNASTOR Cask System Amendment No. 14

References:

Docket No. 72-1031

1. U.S. Nuclear Regulatory Commission (NRC) Certificate of Compliance (CoC)

No. 1031 for the NAC International MAGNASTOR Cask System, Amendment No. 10, January 18, 2023

2. MAGNASTOR Cask System Final Safety Analysis Report (FSAR),

Revision 13, NAC International, January 2023

3. ED20230029, 10 CFR 72.242 Reportable Licensing Basis Non-Mechanistic Tip-over Evaluation Deficiency for the NAC-UMS and MAGNASTOR Dry Cask Storage Systems, March 10, 2023

4. ED20230102, Submission of Data Files to Support the Nuclear Regulatory Commission's (NRC) Review of Amendment No. 14 (Submittal 23C), July 24, 2023 NAC International (NAC) hereby submits a request to amend Reference 1. The changes contained herein in part correct a licensing basis deficiency initially reported to the NRC on March 10, 2023 (Reference 3).

The report identified that a parameter used in the computation of bending stress in the finite element model used to structurally evaluate a fuel rod under the non-mechanistic tip-over accident condition was incorrectly specified resulting in the non-conservative calculation of stresses. MAGNASTOR FSAR Sections 1.1, 3.8, and 8.3 have been revised to correct this error and provide additional clarification to the fuel rod evaluations. The Technical Specification definitions are also updated to provide clarification regarding the applicability of the PWR grid damage allowance to be consistent with fuel rod evaluations in FSAR Section 3.8. Additionally, NAC is requesting that LCO 3.1.2 and the associated FSAR Bases be revised to provide system users clarification on inlet and outlet vent blockage and surveillance requirements. NAC is requesting the changes being proposed via this amendment be included in those TS changes for Amendments O thru 12 via the issuance of a Certificate of Compliance (CoC) revisions.

Formal letters from all our current MAGNASTOR users documenting their intent to adopt the revised CoCs shortly after they become effective in 10 CFR Part 72 will be provided in a separate submittal. of this letter provides the proposed changes to the TS in tracked changes format. Note, the proposed changes to the Technical Specifications, Appendix A, are based on the MAGNASTOR Amendment 12 Technical Specifications currently in rulemaking. Consistent with NAC administrative practice, this proposed SAR revision is numbered to uniquely identify the applicable changed pages.

Revision bars mark the SAR text changes on the Revision MAGNASTOR-23C pages (Enclosure 4) to the ED20230100

I NAC INTERNATIONAL U.S. Nuclear Regulatory Commission July 24, 2023 Page 2 of2 Atlanta Corporate Headquarters 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com Reference 2 SAR pages. Enclosure 1 contains a summary of the changes to the SAR for Revision 23C. contains proprietary NAC calculations used to support the requested change. The data disk for the calculations listed in Enclosure 2 is provided via Reference 4.

Per Attachment 1 to this letter, NAC requests information in Enclosures 2 and 4 to be withheld from public disclosure per 10 CFR 2.390. In accordance with NAC' s administrative practices, upon final acceptance of this application, 23C changed pages will be reformatted and incorporated into the next revision of the MA GNAS TOR SAR.

NAC has recently moved its corporate headquarters and requests that upon the issuance of the CoC for this amendment our address be updated as follows; NAC International 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 If you have any comments or questions, please contact me on my direct line at 678-328-1252.

Sincerely, Heath Heath Baldner Director, Licensing Engineering Attachment Digitally signed by Heath M.

M. Baldner Baldner Date: 2023.07.24 15:46:03 -04'00' - NAC International Affidavit Pursuant 10 CFR 2.390

Enclosure:

-List of Changes for MAGNASTOR FSAR, Revision 23C - Supporting Calculations for MAGNASTOR FSAR Amendment 14, Initial Submittal, Revision 23C - Proposed Technical Specification Changes - FSAR Changed Pages and LOEP for MAGNASTOR FSAR Amendment 14 Initial Submittal Revision 23C ED20230100

I NAC INTERNATIONAL NACINTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 George Carver (Affiant), Vice President, Engineering and Support Services, of NAC International, hereinafter referred to as NAC, at 2 Sun Court, Suite 220, Peachtree Comers, Georgia 30092, being duly sworn, deposes and says that:

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

2. The information to be withheld includes the following NAC Proprietary Information that is being provided to support the technical review ofNAC's Request for a Certificate of Compliance (CoC) (No.

1031) for the NAC International MAGNASTOR Cask System.

• - Supporting Calculations for MAGNASTOR FSAR Amendment 14, Initial Submittal, Revision 23C o 71160-2026 Revision 1 o

71160-2049 Revision 3 o 30076-3001 Revision 7

• - FSAR Changed Pages and LOEP for MAGNASTOR FSAR Amendment 14 Initial Submittal Revision 23C NAC is the owner of the information contained in the above documents. Thus, all of the above identified information is considered NAC Proprietary Information.

3. NAC makes this application for withholding of proprietary information based upon the exemption from disclosure set forth in: the Freedom oflnformation Act ("FOIA"); 5 USC Sec. 552(b)(4) and the Trade Secrets Act; 18 USC Sec. 1905; and NRC Regulations 10 CFR Part 9.l 7(a)(4), 2.390(a)(4), and 2.390(b )(1) for "trade secrets and commercial financial information obtained from a person, and privileged or confidential" (Exemption 4). The information for which exemption from disclosure is herein sought is all "confidential commercial information," and some portions may also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4.

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

a.

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

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

c.

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

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

e.

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

The information that is sought to be withheld is considered to be proprietary for the reasons set forth in Items 4.a, 4.b, and 4.d.

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

ED20230100 Page 1 of3

I NAC INTERNATIONAL NACINTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390

6.

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

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

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

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

9. Public disclosure of the information to be withheld is likely to cause substantial harm to the competitive position of NAC, as the owner of the information, and reduce or eliminate the availability of profit-making opportunities. The proprietary information is part ofNAC's comprehensive spent fuel storage and transport technology base, and its commercial value extends beyond the original development cost to include the development of the expertise to determine and apply the appropriate evaluation process.

The value of this proprietary information and the competitive advantage that it provides to NAC would be lost if the information were disclosed to the public. Making such information available to other parties, including competitors, without their having to make similar investments of time, labor and money would provide competitors with an unfair advantage and deprive NAC of the opportunity to seek an adequate return on its large investment.

ED20230100 Page 2 of3

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

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

~

Executed at P ch.tree Comers, Georgia, this

/

} tr' day of ~

George Carver Vice President, Engineering and Support Services NAC International

• 2023.

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