ML23291A167
| ML23291A167 | |
| Person / Time | |
|---|---|
| Site: | 07201031 |
| Issue date: | 10/18/2023 |
| From: | Baldner H NAC International |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| ED20230154 | |
| Download: ML23291A167 (1) | |
Text
ED20230154 Atlanta Corporate Headquarters 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com October 18, 2023 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Attn:
Document Control Desk
Subject:
Supplement to the Amendment Request No. 14 for the NAC International MAGNASTOR Cask System Docket No. 72-1031
References:
- 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
- 5. ED20230100, Submission of an Amendment Request for the NAC International MAGNASTOR Cask System Amendment No. 14, July 24, 2023 NAC International (NAC) hereby submits a supplement to the request to amend Reference 1. NAC is requesting the changes being proposed via this amendment be included in those TS changes for Amendments 0 thru 12 via the issuance of a Certificate of Compliance (CoC) revisions. This supplement contains the letters from all our current MAGNASTOR users documenting their intent to adopt the revised CoCs shortly after the effective date.
If you have any comments or questions, please contact me on my direct line at 678-328-1252.
Sincerely, Heath Baldner Director, Licensing Engineering
+/- NAC-UMS Cask System Users Letters of Intent to Adopt CoC Revisions
ED20230154 Atlanta Corporate Headquarters 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com MAGNASTOR Cask System Users Letters of Intent to Adopt CoC Revisions MAGNASTOR, Amendment 14 (Docket No 72-1031)
NAC International October 2023
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)
September 12, 2023 NAC International Heath Baldner
~
KEWAUNEESOLUTIO S 2 Sun Court, Suite 220 Peachtree Comers, GA 30092 KS-2023-021
Subject:
Kewaunee Solutions (KS) Voluntary Agreement to Implement an Amendment Revision to CoC 1031 To Resolve a MAGNASTOR Non-Mechanistic Tip-over Evaluation Error
Reference:
Dear Mr. Baldner,
In March 2023, NAC notified Kewaunee Solutions (KS) that Corrective Action Report, CAR 23-01 had been generated to document a parameter used in the analysis of bending stress on a fuel rod during a drop evaluation was incorrectly specified resulting in the non-conservative calculation of stresses (Reference 1). NAC reported the computation of bending stress was non-conservative by a factor of 2. The modeling (30-foot side drop during canister transportation activities) was also used in another analysis NAC performed for tip-over of a cask in storage at an ISFSI pad. This error affects both Part 71 transportation and Part 72 storage activities. To resolve this issue, NAC submitted, for NRC review, Amendment Request No. 14 to Certificate of Compliance No. 1031 for the MAGNASTOR cask system on July 23, 2023.
KS presently has MAGNASTOR casks in storage at Kewaunee under CoC 1031 Amendment 6.
It is KS understanding that NAC intends to request from NRC issuance of Revision 2 to Amendment 6 to resolve the issue.
KS intends to implement the revised certificate of compliance (CoC) for the MAGNASTOR system, CoC No. 1031 Amendment 6, Revision 2, after approval from the NRC has been received.
To allow sufficient time to incorporate these changes in a quality manner, KS request that NAC work with NRC to provide its general licensees a maximum 180-day period after the effective date of the revised amendment during which we can complete incorporation of the revised amendment.
Kewaunee Solutions KS-2023-021 Page 2 of2 Please contact Mr. William Zipp at (920) 304-9729 if you have any questions or require additional information.
Sincerely, Joseph R. Lynch Licensing and Regulatory Affairs Manager EnergySolutions, LLC Kewaunee Power Station, N490 Highway 42, Kewaunee, WI 54216
4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-23-092 September 11, 2023 ATTN: Heath Baldner NAC International Inc Atlanta Corporate Headquarters 2 Sun Court Peachtree Corners, GA 30092
Subject:
Notification of Intent to Implement Revised CoC The purpose of this letter is to notify NAC International (NAC), that Constellation Energy Generation (CEG) intends to implement the revised certificate of compliance (CoC) for the MAGNASTOR system, CoC No. 1031 Amendment 9 Revision 2 at the Three Mile Island Nuclear Station, Unit 1, (TMI-1), after approval from the NRC has been received.
Implementation will be completed in a timely fashion after approval.
If you have any questions concerning this letter, please contact Brian Seawright at (779) 231-6151.
Respectfully, Kevin Lueshen Sr. Manager Licensing Constellation Energy Generation, LLC cc:
Heath Baldner - NAC International, hbaldner@nacintl.com George Carver - NAC International, gcarver@nacintl.com Eric Shewbridge - NAC International, eshewbridge@nacintl.com
101 Shiloh Boulevard, Zion IL 60099 (224) 789-4016 Fax: (224) 789-4008 www.zionsolutionscompany.com September 13, 2023 ZS-2023-019 Heath M. Baldner Director of Licensing NAC International Inc.
2 Sun Court, Suite 220 Peachtree Corners, GA 30092
Subject:
Adoption of MAGNASTOR CoC Amendment for CAR 23-01
References:
- 1. E-Mail Communication, E. Shewbridge (NAC) to MAGNASTOR/UMS Licensees, dated September 1, 2023;
Subject:
MAGNASTOR and UMS CoC Amendment for CAR 23 Adoption Letters.
Dear Mr. Baldner:
As requested in Reference 1, Zion Solutions intends to implement the revised certificate of compliance (CoC) for the MAGNASTOR system, CoC No. 1031, Amendment 14, after approval from the NRC has been received. Currently, the Zion 10 CFR 72.212 Evaluation Report Revision 10 references MAGNASTOR CoC No. 1031 Amendment 6.
Respectfully, Amy C. Hazelhoff Senior Vice President - Regulatory Affairs cc:
E. Shewbridge (NAC)
A. Orawiec (ZS)
J. Wheat (ZS)
W. Szymczak (ZS)
K. Van Hoogen (ZS)
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