ML23284A064

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Supplement to Submittal of Biennial Reports of 72.48 Evaluations Performed for the Standardized NUHOMS System, Certificate of Compliance (CoC) 1004, for the Periods 07/26/2016 to 07/25/2018 and 7/28/2020 to 7/27/2022, Docket 72-1004
ML23284A064
Person / Time
Site: 07201004
Issue date: 10/11/2023
From: Shaw D
TN Americas LLC
To:
Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
E-62842
Download: ML23284A064 (1)


Text

Orano TN 7160 Riverwood Drive Suite 200 Columbia, MD 21046 USA Tel: 410-910-6900 Fax: 434-260-8480 October 11, 2023 E-62842 U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852

Subject:

Supplement to Submittal of Biennial Reports of 72.48 Evaluations Performed for the Standardized NUHOMS System, Certificate of Compliance (CoC) 1004, for the Periods 07/26/2016 to 07/25/2018 and 7/28/2020 to 7/27/2022, Docket 72-1004

Reference:

(1)

Letter from Jayant Bondre (TN) to Document Control Desk, Submittal of Biennial Report of 10 CFR 72.48 Evaluations Performed for the Standardized NUHOMS System, CoC 1004, for the Period 07/26/2016 to 07/25/2018, Docket 72-1004, July 25, 2018 (2)

Letter from Donis Shaw (TN) to Document Control Desk, Submittal of Biennial Report of 10 CFR 72.48 Evaluations Performed for the Standardized NUHOMS System, CoC 1004, for the Period 7/28/2020 to 7/27/2022, Docket 72-1004, July 27, 2022 Pursuant to the requirements of 10 CFR 72.48(d)(2), the submittals referenced above provided 72.48 evaluations performed for the CoC 1004 Standardized NUHOMS System, for the periods indicated. Enclosure 1 provides additional 72.48 evaluation summaries that were inadvertently omitted for LRs 721004-1572, Revision 0, approved on 3/8/2017; 721004-1591, Revision 0, approved on 2/20/2017; and 721004-1856, Revision 0, approved on 9/8/2020. The summaries include indication as to whether the evaluations had associated Updated Final Safety Analysis Report (UFSAR) changes that were incorporated into the UFSAR for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Fuel, NUH003.0103.

This situation has been entered into TN Americas LLCs (TNs) corrective action program and actions are in progress to prevent recurrence.

E-62842 Document Control Desk Page 2 of 2 Should you or your staff require additional information, please do not hesitate to contact me at 410-910-6878 or Doug Yates at 434-832-3101.

Sincerely, Don Shaw Licensing Manager cc:

Christian J. Jacobs (NRC DFM/STLB)

Enclosure:

1.

Supplemental Report of 10 CFR 72.48 Evaluations Performed for CoC 1004 for the Periods 07/26/2016 to 07/25/2018 and 7/28/2020 to 7/27/2022 Don Shaw Digitally signed by Don Shaw Date: 2023.10.11 08:18:16

-04'00' to E-62842 Page 1 Supplemental Report of 10 CFR 72.48 Evaluations Performed for CoC 1004 for the Periods 07/26/2016 to 07/25/2018 and 7/28/2020 to 7/27/2022 LR No.

721004-Description of Change, Test, or Experiment Summary of Evaluation 1572 Rev. 0 The licensing review evaluates the storage of fuel assemblies (FAs) containing debris/foreign material within a NUHOMS 32PTH1 Type 2-W DSC. The utility has provided a list of all foreign material identified in the associated spent fuel assemblies.

This material is not readily retrievable before loading into a NUHOMS DSC under CoC 1004 Amendment 14 in a future loading campaign. The data identified instances of debris in 293 fuel assemblies. The foreign material has been identified as metal, plastic, fiber, rubber, or unknown.

A review shows that there are two categories of debris present within the FAs which required evaluation: (1) stainless steel or carbon steel metal debris in various geometries and (2) rubber, plastic, fiber, or unknown debris (cloth strings, string mesh, plastic, plastic tape, and nylon wrap). The loading plan that was provided would be enveloped by the analysis evaluated in this LR. The conservative option (worst case) was to determine the highest amount of non-metal debris that could be loaded in one single DSC. Plastic, rubber, fiber, and unknown debris provided by the utility shows the maximum cumulative weight of the pieces of debris in a single DSC to be 0.113 lbs. However, this is conservative as the loading plan shows not all of these fuel assemblies will be loaded in a single DSC.

The metal debris (stainless steel, carbon steel, or a combination) shows the maximum cumulative weight of all listed metal debris of 1.32 lbs. The debris is split between many DSCs and the total weight of metal debris in a single DSC is 0.18 lbs. The tentative loading plan shows the maximum cumulative weight per any single DSC for plastic, rubber, fiber, and unknown debris is 0.013 lbs. In addition, LR 721004-1074 [ML13196A04] previously evaluated up to 0.17 lb of metal debris and 0.0331 lb of plastic/fiber debris to be acceptable for storage in a single 32PT DSC with Westinghouse 14X14 fuel.

The evaluation concluded that the overall form, fit and function of the DSC remains unchanged due to the potential addition of this small amount of debris. All eight 72.48 evaluation criteria were met.

No associated UFSAR changes were required.

to E-62842 Page 2 LR No.

721004-Description of Change, Test, or Experiment Summary of Evaluation 1591 Rev. 0 This change evaluates a non-conforming condition where the 61BTH Type 1 DSC aluminum outer basket plates between the basket and the rails were fabricated below the required thickness resulting in the basket to shell gap requirement being exceeded.

The basket structure consists of assemblies of stainless steel fuel compartments held in place by basket rails and the hold down ring. The overall design function of the basket assembly is to provide structural support for the fuel assemblies, to form a rigid structure to ensure criticality control, and to provide a heat transfer path from the fuel assemblies to the DSC Shell. The bounding under-thickness aluminum rails were evaluated in a thermal calculation that showed that the underthickness plates and thinner shims caused the temperature of internal DSC components to rise because the gap between the basket and shell affects heat transfer. The larger gap reduces heat transfer from the basket to the shell which in turn increases the temperature of the basket structural components and the fuel cladding. However, the increased temperature is bounded for normal, off-normal, and accident conditions by the current evaluation in the UFSAR. All eight 72.48 evaluation criteria were met.

No associated UFSAR changes were required.

1856 Rev. 0 The change deletes the specific code and edition (i.e., ACI 318-

95) to be applied for the design and construction of the ISFSI basemat and approach slab from a horizontal storage module (HSM) Model HSM-H SAR drawing. Use of ACI 318 and or ACI 349 codes for the design and construction of the basemat and approach slab are appropriate and acceptable per NUREG-1536.

ACI 318 is a commercial building code for reinforced concrete structures. ACI 349 is a more specific code intended to address the design and construction of nuclear safety-related structures, where design conditions for nuclear containment building structures such as elevated temperatures and pressures are considered. Such conditions do not apply to the design of the ISFSI basemat and approach slab. The drawing is revised to state that the basemat and approach slab shall be designed and constructed in accordance with ACI 318 and/or ACI 349 with no specific code editions specified.

The basemat and approach slab are reinforced concrete foundations which perform a structural design function in support of the HSM-H and transfer cask (TC), respectively. Although these components are credited to perform a structural design function, they are classified as NITS since there is no credible mechanism that could result in gross structural failure of these components, and as such they are non-licensed components that may be designed and constructed to commercial standards. The LR determined that the change does not affect the safety functions of the HSM-H and that the structural design function of the basemat and approach slab to provide structural support to the HSM-H and transfer trailer loaded with the TC, respectively, continues to be satisfied by use of appropriate ACI design and construction codes which are acceptable per NUREG-1536. All eight 72.48 evaluation criteria were met.

Changes were incorporated into UFSAR Revision 19.