ML23283A249

Transmittal Letter and Affidavit, Submission of an Amendment Request for the NAC International Universal Storage System (Ums) Amendment No. 10 and Revisions to Amendments 5 to 9

ML23283A249
Person / Time
Site:	07201015
Issue date:	10/10/2023
From:	Baldner H NAC International
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
Shared Package
ML23283A248	List: ML23283A249 ML23283A250
References
ED20230124
Download: ML23283A249 (11)

Text

ED20230124 Atlanta Corporate Headquarters 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com October 10, 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 Universal Storage System (UMS) Amendment No. 10 Docket No. 72-1015

References:

1. U.S. Nuclear Regulatory Commission (NRC) Certificate of Compliance (CoC) No. 1015 for the NAC International Universal Storage System (UMS)

System, Amendment No. 9, July 22, 2022

2. NAC-UMS System Final Safety Analysis Report (FSAR), Revision 16, NAC International, November 14, 2022

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. ED20230127, Submission of Data Files to Support the Nuclear Regulatory Commission¶s (NRC) Review of NAC-UMS Amendment No. 10 (Submittal 23A),

October 10, 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. NAC-UMS FSAR Sections 11.2.16 has been revised to correct the error for the PWR &

BWR fuel evaluations. Additionally, the PWR end drop evaluation was updated using the methodology already approved for the BWR end drop evaluation.

NAC is requesting the changes being proposed via this amendment be included in those TS changes for Amendments 5 thru 9 via the issuance of a Certificate of Compliance (CoC) revisions.

Formal letters from all our current NAC-UMS users documenting their intent to adopt the revised CoCs shortly after they become effective in 10 CFR Part 72 are provided in Attachment 2.

ED20230124 Atlanta Corporate Headquarters 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com U.S. Nuclear Regulatory Commission October 10, 2023 Page 2 of 2 Consistent with NAC administrative practice, this proposed FSAR revision is numbered to uniquely identify the applicable changed pages. Revision bars mark the FSAR text changes on the Revision NAC-UMS FSAR pages (Enclosure 3) to the Reference 2 SAR pages. Enclosure 1 contains proprietary NAC calculations used to support the requested change. Enclosure 2 contains a summary of the changes to the SAR for Revision 23A. The data disk for the calculations listed in Enclosure 2 is provided via Reference 4.

The corrections to this error and additional clarifications to the fuel rod evaluations for non-mechanistic tip-over accident condition requested in this Amendment do not introduce any new components or materials that need to be evaluated for aging management.

Per Attachment 1 to this letter, NAC requests information in Enclosures 1 and 3 to be withheld from public disclosure per 10 CFR 2.390. In accordance with NAC¶s administrative practices, upon final acceptance of this application, 23A changed pages will be reformatted and incorporated into the next revision of the NAC-UMS 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 Baldner Director, Licensing Engineering

Attachment:

+/- NAC International Inc. Affidavit Pursuant to 10 CFR 2.390 +/- NAC-UMS Cask System Users Letters of Intent to Adopt CoC Revisions

Enclosures:

+/- Supporting Calculations for NAC-UMS FSAR, Amendment 10, Revision 23A - List of FSAR Changes for NAC-UMS FSAR, Amendment 10, Revision 23A +/- FSAR Changed Pages and LOEP for NAC-UMS FSAR, Amd. 10, Revision 23A

NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 ED20230124 Page 1 of 3 George Carver (Affiant), Vice President, Engineering and Support Services, of NAC International, hereinafter referred to as NAC, at 2 Sun Court, Suite 220, Peachtree Corners, 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 of NAC¶s Request for a Certificate of Compliance (CoC) (No.

1031) for the NAC International MAGNASTOR Cask System. +/- Supporting Calculations for NAC-UMS FSAR, Amendment 10, Revision 23A +/- FSAR Changed Pages and LOEP for NAC-UMS FSAR, Amd. 10, Revision 23A 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 of Information Act (³FOIA'); 5 USC Sec. 552(b)(4) and the Trade Secrets Act; 18 USC Sec. 1905; and NRC Regulations 10 CFR Part 9.17(a)(4), 2.390(a)(4), and 2.390(b)(1) for ³trade 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 ³confidential commercial information,' and some portions may also qualify under the narrower definition of ³trade secret,' within the meanings assigned to those terms for purposes of FOIA Exemption 4.

4. Examples of categories of information that fit into the definition 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.

NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 ED20230124 Page 2 of 3

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

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 ³controlled distribution' to individuals on a ³need 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 of NAC¶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.

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.

achtree Corners, Georgia, this / 0~ day of 0~

George Carver Vice President, Engineering and Support Services NAC International vl--

- (.

Subscribed and sworn before me this /0 day of ()~

, 2023.

ED20230124 Page 3 of3

, 2023.

ED20230124 Page 1 of 1 NAC-UMS Cask System Users Letters of Intent to Adopt CoC Revisions NAC-UMS, Amendment 10 (Docket No 72-1015)

NAC International September 2023

MAINE YANKEE 321 Old Ferry Ruad, Wiscasset, Maine 04578 Attn: Heath Baldner NAC International 2 Sun Court, Suite 220 Peachtree Comers, GA 30092 Maine Yankee Atomic Power Company September 18, 2023 OMY-23-016 Maine Yankee Independent Spent Fuel Storage Installation NRC License No. DPR-36 {NRC Docket Nos. 50-309 and 72-30)

Subject:

Intent to Adopt NAC-UMS Certificate of Compliance Amendment 6, Revision 1 The purpose of this letter is to inform you that the Maine Yankee Atomic Power Company (Maine Yankee) intends to adopt Revision 1 to Amendment 6 of the NAC-UMS Certificate of Compliance (CoC) (Docket No. 72.1025) following NRC approval and issuance.

This is based on our understanding that the changes do not technically affect the Maine Yankee Independent Spent Fuel Storage Installation, because Maine Yankee has a site-specific tip-over analysis. However, we understand the need to adopl lhe applicable changes Lu lhe NAC UMS FSAR given thut they provide the bases for the NAC-UMS CoC and Technical Specifications.

If you have any questions regarding this submittal, please contact me at (207) 882-1303.

Dan Laing ISFSI Manager

Palo Verde Nuclear Generating Station 5871 S. Wintersburg Rd Tonopah, AZ 85354 162-16980 October 7, 2023 Kurt Steger Project Manager NAC International 2 Sun Court +/- Suite 220 Peachtree Corners, GA 30092

Subject:

Palo Verde Adoption of CAR 23-01 Certificate of Compliance Amendments for UMS and MAGNASTOR

Dear Mr. Steger,

In March of 2023, NAC notified Palo Verde Generating Station (Arizona Public Service) after they had discovered an issue with a parameter used in the computation of bending stress in the finite element model for the fuel rod 30-foot side drop analysis (NAC CAR 23-01). The parameter was incorrectly specified resulting in the non-conservative calculation of stresses. The input in question was incorrectly set to half of the correct value. Use of the correct value effectively doubles the computed bending stress. The analysis is used in the non-mechanistic cask tip-over accident presented in Section 11.2.12 of the NAC-UMS FSAR and Section 12.2.12 of the NAC-MAGNASTOR FSAR. This letter is being written to document Palo Verde¶s position with respect to the identified condition.

Upon receipt of NAC CAR 23-01, condition report (CR) 23-02117 was initiated at Palo Verde to evaluate and generate needed actions to address the condition. The impacted analysis is limited to fuel assemblies with unsupported fuel assembly rod lengths up to 60' (e.g., slipped/missing or damaged structural grids). This permits such fuel assemblies to be classified as ³undamaged' for loading per NAC-MAGNASTOR TS 1.1. No additional NAC-UMS systems are being loaded at Palo Verde. To avoid loading fuel affected by the impacted analysis, procedure 72DP-9NF02 (Fuel Assembly Selection for Dry Cask Storage) has been revised to require any fuel assembly with missing or damaged grid straps to be classified as DAMAGED. Palo Verde does have NAC-UMS systems containing fuel assemblies with damaged grid straps. No fuel assemblies with damaged grid straps have been loaded in NAC-MAGNASTOR systems.

APS/Palo Verde intends to implement the revised Certificate of Compliance (CoC) for the NAC-MAGNASTOR system, CoC No. 1031 Amendment 7 Revision 2. For the NAC-UMS system, APS/Palo Verde will adopt the CoC revision described in UMS Amendment 10 once approved.

162-16980 October 7, 2023 Please contact me at 480-369-6595 or via email with any questions.

Regards, Luke McIntyre Nuclear Fuel Management CC:

D. J. Buth 7693 H. Wahlstrom 7693 D. Zimmerly 7693 H. Baldner NAC E. Shewbridge NAC

526 South Church Street:

Mail Code EC08H Charlotte, NC 28202 Sep. 13, 2023 Eric Shewbridge NAC International 2 Sun Court, Suite 220 Peachtree Corners, GA 30092

Subject:

Duke Energy Compliance with NAC MAGNASTOR & UMS Tip-Over Analysis Issue (CAR 23-01)

Dear Mr. Shewbridge:

In March of2023, NAC notified Duke Energy after discovering an issue with a parameter used in the computation of bending stress in the finite element model for the fuel rod 30-ft Side Drop analysis. The parameter was incorrectly specified resulting in the nonconservative calculation of stresses. The input code in question incorrectly set the height real constant using a parameter equal to the outer radius of the rod, which is half of the correct value. Use of the correct value effectively doubles the computed bending stress. The analysis is used in the non-mechanistic cask tip-over accidents presented in Section 11.2.12 of the NAC-UMS FSAR and Section 12.2.12 of the NAC-MAGNSATOR FSAR. This letter is being written to document the current Duke Energy position with respect to the identified condition.

NAC Engineering issued memo ED20230026 and noted: The calculational error presented is specific to the non-mechanistic tip-over analysis. Both the MAGNASTOR FSAR and UMS FSAR provide evaluations which determine the loaded systems on the ISFSI pad do not tip-over within licensed conditions. The 72.242(d)(1) abstract also noted:.the safety functions of the VCC and TSC (e.g., passive heat rejection, environmental protection, TSC confinement, fuel geometry control) are unaffected by the error in fuel rod geometric modeling. NAC found there to be no impact to safety for the storage systems in operation due to this error.

The impacted analysis is limited to fuel assemblies with unsupported fuel assembly rod lengths up to 60 (e.g., slipped/missing or damaged structural grids). This permits such fuel assemblies to be classified as undamaged for loading per NAC-MAGNASTOR TS 1.1. No additional NAC-UMS systems are being loaded at Catawba or McGuire. To avoid loading fuel affected by the impacted analysis, Duke procedure TE-NF-NGO-0602 (Selection of Fuel for Storage in the MAGNASTOR Dry Fuel Storage System) has been revised adding the statement Any fuel assembly with grid damage or slippage resulting in any additional unsupported length shall NOT be loaded as "UNDAMAGED". Assemblies in this condition may be loaded as "DAMAGED", requiring a "Damaged Fuel Canister".

Both Catawba and McGuire intend to implement the revised certificate of compliance (CoC) for the MAGNASTOR system, CoC No. 1031 Amendment 7 Revision 2. Instead of adopting a revision to the UMS amendment, Catawba and McGuire will be adopting the latest amendment for the UMS system, CoC No. 1015 Amendment 10 after approval from the NRC has been received.

Until MAGNASTOR CoC revisions are issued and adopted by Catawba and McGuire, each station will continue its current loading schedule excluding the loading of fuel with additional unsupported lengths into undamaged fuel locations.

Sincerely, Matthew L Cameron Manager, Fuel Supply and Storage, Nuclear Fuels Engineering CC:

N.E. Davis (Duke Energy)

R.S. Edwards (Duke Energy)

P. Washington (Duke Energy)

H. Baldner (NAC International)