ML24095A112

Request for Additional Information for NAC International Request for Amendment No. 9, and Revision to Amendment Nos. 6, 7, and 8, of the Certificate of Compliance No. 1025 for the NAC Multi-Purpose Canister System

ML24095A112
Person / Time
Site:	07201025
Issue date:	04/17/2024
From:	Kristina Banovac Storage and Transportation Licensing Branch
To:	Baldner H NAC International
References
CAC 001028, EPID L-2023-LLA-0149, EPID L-2023-LLA-0148
Download: ML24095A112 (1)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Heath Baldner - Director, Licensing Engineering NAC International 2 Sun Court, Suite 220 Peachtree Corners, GA 30092

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR REVIEW OF THE NAC INTERNATIONAL REQUEST FOR AMENDMENT NO. 9, AND REVISION TO AMENDMENT NOS. 6, 7, AND 8, OF THE CERTIFICATE OF COMPLIANCE NO. 1025 FOR THE NAC MULTI-PURPOSE CANISTER SYSTEM - COST ACTIVITY CODE/ENTERPRISE PROJECT IDENTIFICATION NUMBERS 001028/L-2023-LLA-0149 AND L-2023-LLA-0148

Dear Heath Baldner:

By letter dated September 7, 2023 (Agencywide Documents Access and Management System

[ADAMS] Accession No. ML23250A056), as supplemented on February 14, 2024 (ML24040A027), NAC International (NAC) submitted an application to the U.S. Nuclear Regulatory Commission (NRC) for Amendment No. 9, and Revision to Amendment Nos. 6, 7, and 8, of the Certificate of Compliance (CoC) No. 1025 for the NAC Multi-Purpose Canister System. The application proposes to revise the description of the vertical concrete cask in the CoC and technical specifications to make a distinction between the vertical concrete cask (body) and the vertical concrete cask lid, in terms of applicability of the American Concrete Institute (ACI) Specifications ACI-349 and ACI-318.

In connection with our review, we need the information identified in the enclosed request for additional information (RAI). To assist us in scheduling the NRC staff review of your response, we request that you provide this information 30 calendar days from the date of this letter. Inform us at your earliest convenience, but no later than 2 weeks before the response date, if you are not able to provide the information by that date. If you are unable to provide a response by the stated date, our review may be delayed.

Please reference Docket No. 72-1025 and Cost Activity Code/Enterprise Project Identification Nos. 001028/L-2023-LLA-0149 and 001028/L-2023-LLA-0148 in future correspondence related to this review. The NRC staff is available to clarify these questions, and, if necessary, to meet and discuss your proposed responses.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. The PDR is open by appointment.

To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.gov or April 17, 2024

H. Baldner 2

call 1-800-397-4209 or 301-415-4737, between 8:00 a.m. and 4:00 p.m. eastern time (ET),

Monday through Friday, except Federal holidays.

If you have any questions regarding this communication, please contact me at (301) 415-7116, or via email to Kristina.Banovac@nrc.gov.

Sincerely, Kristina L. Banovac, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-1025 EPID Nos.: L-2023-LLA-0149 L-2023-LLA-0148

Enclosure:

Request for Additional Information Signed by Banovac, Kristina on 04/17/24

ML24095A112 OFFICE NMSS/DFM/STLB NMSS/DFM/MSB NMSS/DFM/STLB NAME KBanovac CSydnor WWheatley DATE 4/4/2024 4/4/2024 4/9/2024 OFFICE NMSS/DFM/MSB NMSS/DFM/STLB NMSS/DFM/STLB NAME TBoyce BWhite for YDiaz-Sanabria KBanovac DATE 4/11/2024 4/17/2024 4/17/2024

Enclosure Request for Additional Information NAC International Docket No. 72-1025 Certificate of Compliance No. 1025 Amendment No. 9, and Revision to Amendment Nos. 6, 7, And 8 Model No. NAC Multi-Purpose Canister System This request identifies additional information that is needed by the U.S. Nuclear Regulatory Commission (NRC) staff in connection with its review of the NAC International (NAC) application for Amendment No. 9, and Revision to Amendment Nos. 6, 7, and 8, of the Certificate of Compliance (CoC) No. 1025 for the NAC Multi-Purpose Canister System (NAC-MPC). The NRC staff used NUREG-2215, Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities, and NUREG-2214, Managing Aging Processes In Storage (MAPS) Report, in its review of the application.

Each question describes information needed by the NRC staff to complete its review of the application and to determine whether the applicant has demonstrated compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 72.

General Information RAI G-1 Provide the proposed changes to the CoC and its Appendices (Appendix A, Technical Specifications and Appendix B, Approved Contents and Design Features) for the requested Revision to Amendment Nos. 6, 7, and 8 of CoC No. 1025.

In Enclosure 1, NAC provides the proposed changes to the CoC and its Appendices for the requested Amendment No. 9. NAC also requests in its application that the changes proposed in Amendment No. 9 be included in the Revisions to Amendment Nos. 6, 7, and 8. Therefore, provide the proposed changes to the CoC and its Appendices for the requested amendment revisions, or otherwise state if the Enclosure 1 proposed changes are identical for the requested Revisions to Amendment Nos. 6, 7, and 8.

This information is needed to demonstrate compliance with 10 CFR 72.244.

Materials Evaluation RAI M-1 Specify the initial diameter (prior to shrinkage) of the concrete component of the vertical concrete cask lid for the NAC-MPC system.

This information is needed to verify that NACs calculation of the expected radial gap around the edge of the concrete cask lid due to concrete shrinkage for the NAC MAGNASTOR system is also reasonably representative of the vertical concrete cask lid for the NAC-MPC system. The concrete shrinkage for the MAGNASTOR system was provided in a March 18, 2022, supplement (ML22077A769). The staff is requesting this information so that it can verify that

2 there will be no unacceptable radiation streaming through the expected radial gap around the edge of the vertical concrete cask lid due to concrete shrinkage for the NAC-MPC system.

This above information is requested to ensure that the NAC-MPC vertical concrete cask lid meets the requirements of 10 CFR 72.236.

RAI M-2 Explain whether the concrete in the vertical concrete cask lid is completely encased in carbon steel or is otherwise protected from exposure to the outdoor air and precipitation environment. If the concrete in the vertical concrete cask lid is exposed to the outdoor air and precipitation environment, identify the maintenance criteria or aging management program criteria that are credited toward ensuring that there is no loss of material or deterioration in the material condition of the exposed concrete that could cause a significant increase in radiation dose rates during the approved storage term for CoC No. 1025.

This information is needed to verify either that the concrete in the vertical concrete cask lid is adequately protected from exposure to the outdoor air and precipitation environment, or, if not protected from exposure, that there are suitable maintenance or aging management program criteria in place to ensure that aging degradation of exposed concrete will not lead to material loss or deterioration that could cause a significant increase in radiation dose rates during the approved storage period.

For concrete that is exposed to outdoor air and precipitation, there is potential for intrusion of rainwater and dissolved compounds into the concrete. Based on consideration of the concrete aging mechanisms in NUREG-2214, the staff noted that potential aging mechanisms related to rainwater intrusion for exposed concrete include freeze and thaw, reaction with aggregates, chemical attack, leaching of calcium hydroxide, and salt scaling. Since there is no structural strength requirement for the concrete in the cask lid, the staff noted that the above aging mechanisms are only a concern if they result in significant loss of material or formation voids, cracks, and/or other concrete deterioration that could cause an increase in radiation dose rates.

This above information is requested to ensure that the NAC-MPC vertical concrete cask lid meets the requirements of 10 CFR 72.236.