ML24242A047

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1. User Need Memo for Amendment No. 9, and Revision to Amendment Nos. 6, 7, and 8, of the Renewed Certificate of Compliance No. 1025 for the NAC Multi-Purpose Canister System
ML24242A047
Person / Time
Site: 07201025
Issue date: 10/17/2024
From: Yoira Diaz-Sanabria
Storage and Transportation Licensing Branch
To: James Shepherd
NRC/NMSS/DREFS/MRPB
Shared Package
ML24242A043 List:
References
CAC 001028, EPID L-2023-LLA-0149, EPID L-2023-LLA-0148
Download: ML24242A047 (1)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 MEMORANDUM TO: Jill Shepherd, Chief Materials Rulemaking and Project Management Branch Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards FROM:

Yoira Diaz-Sanabria, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards

SUBJECT:

USER NEED FOR RULEMAKING FOR AMENDMENT NO. 9, AND REVISION TO AMENDMENT NOS. 6, 7, AND 8, OF THE RENEWED CERTIFICATE OF COMPLIANCE NO. 1025 FOR THE NAC MULTI-PURPOSE CANISTER SYSTEM The purpose of this communication is to request support for rulemaking activities in the Division of Fuel Management (DFM) for the following Title 10 of the Code of Federal Regulations (10 CFR) Part 72 certification action:

1.

Changes to the 10 CFR 72.214 rule text (changes appear in bold):

Certificate Number: 1025.

Initial Certificate Effective Date: April 10, 2000, superseded by Renewed Initial Certificate Effective Date: October 17, 2023.

Amendment Number 1 Effective Date: November 13, 2001, superseded by Renewed Amendment Number 1 Effective Date: October 17, 2023.

Amendment Number 2 Effective Date: May 29, 2002, superseded by Renewed Amendment Number 2 Effective Date: October 17, 2023.

Amendment Number 3 Effective Date: October 1, 2003, superseded by Renewed Amendment Number 3 Effective Date: October 17, 2023.

Amendment Number 4 Effective Date: October 27, 2004, superseded by Renewed Amendment Number 4 Effective Date: October 17, 2023.

CONTACT: Kristina L. Banovac, NMSS/DFM 301-415-7116 October 17, 2024 Signed by Diaz-Sanabria, Yoira on 10/17/24

J. Shepherd 2

Amendment Number 5 Effective Date: July 24, 2007, superseded by Renewed Amendment Number 5 Effective Date: October 17, 2023.

Amendment Number 6 Effective Date: October 4, 2010, superseded by Renewed Amendment Number 6 Effective Date: October 17, 2023, superseded by Renewed Amendment Number 6, Revision 1 Effective Date: [insert 75 days from date of FR publication].

Amendment Number 7 Effective Date: March 4, 2019, superseded by Renewed Amendment Number 7 Effective Date: October 17, 2023, superseded by Renewed Amendment Number 7, Revision 1 Effective Date: [insert 75 days from date of FR publication].

Amendment Number 8 Effective Date: March 4, 2019, superseded by Renewed Amendment Number 8 Effective Date: October 17, 2023, superseded by Renewed Amendment Number 8, Revision 1 Effective Date: [insert 75 days from date of FR publication].

Renewed Amendment Number 9 Effective Date: [insert 75 days from date of FR publication]

Safety Analysis Report (SAR) Submitted by: NAC International, Inc.

SAR

Title:

Final Safety Analysis Report for the NAC Multi-Purpose Canister System (NAC-MPC System).

Docket Number: 72-1025.

Certificate Expiration Date: May 31, 2020.

Renewed Certificate Expiration Date: April 10, 2060.

Model Number: NAC-MPC System.

2.

Purpose and scope of the Revisions:

By letter dated September 7, 2023 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML23250A056), as supplemented on February 14, 2024 (ML24040A027), May 14, 2024 (ML24135A322), July 10, 2024 (ML24193A110),

and August 27, 2024 (ML24240A133), 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 renewed Certificate of Compliance (CoC) No.

1025 for the NAC Multi-Purpose Canister (NAC-MPC) System. The application proposes to revise the description of the vertical concrete cask (VCC) in the CoC and technical specifications to make a distinction between the VCC body and the VCC lid, in terms of applicability of the American Concrete Institute (ACI) Specifications ACI 349 and ACI 318.

The proposed changes for Amendment No. 9 and the Revisions to Amendment Nos. 6, 7, and 8 include the following:

1) Revise the NAC-MPC system description in the CoC to distinguish between the VCC body and VCC lid and clearly indicate that only the VCC body is a reinforced concrete structure.

J. Shepherd 3

2) Revise the CoC appendix A (Appendix A, Technical Specifications) definitions, by revising the definition of VCC, and adding a new definition for VCC lid.
3) Revise the CoC appendix B (Appendix B, Approved Contents and Design Features), Section 3.3, Codes and Standards to indicate that the ACI 349 and ACI 318 govern the design and construction only of the VCC body. New text is added to provide the fabrication requirements for the concrete in the VCC lid to include:

the minimum concrete density, the allowable methods for measuring the density of the concrete in the VCC lid, and requirements for the concrete mix, placement, and curing methods used in the construction of the concrete in the VCC lid.

4) Correct conflicting information in the final safety analysis report (FSAR) design bases regarding the minimum concrete density in the VCC lid, to indicate a minimum concrete density of 140 pounds per cubic foot (pcf); revise the shielding analysis and calculation to reflect the 140 pcf concrete density.

3.

Proposed Backfitting Discussion for the Direct Final Rule for the Revisions to renewed CoC No. 1025, Amendment Nos. 6, 7, and 8 General licensees using the specific CoC amendments that are being revised are required to meet the conditions of the revised CoC. The NRC added a condition to the revised CoC that requires the general licensees to implement the revised CoC within six months and perform written evaluations in accordance with 10 CFR 72.212(b)(5), which establish that the cask will conform to the terms, conditions, and specifications of the revised CoC. The six-month timeframe in the condition is considered a standard timeframe for implementation, consistent with the information in Regulatory Issue Summary 2017-05, Administration of 10 CFR Part 72 Certificate of Compliance Corrections and Revisions. Additionally, the implementation timeframe was recognized by the applicant and the general licensees using these amendments (ML23250A056 and ML24193A110).

For the following reasons, the NRC has determined that the regulations in 10 CFR 72.62, Backfitting, do not apply to this direct final rule. This direct final rule revises Amendment Nos. 6, 7, and 8 for renewed CoC No. 1025 for the NAC-MPC System, as currently listed in 10 CFR 72.214, List of approved spent fuel storage casks. Revision 1 to Amendment Nos. 6, 7, and 8 to renewed CoC No. 1025 revises the NAC-MPC system description to distinguish between the VCC body and VCC lid, revise the definition of VCC and add a new definition for VCC lid, and add new fabrication requirements for the concrete in the VCC lid.

NAC has manufactured casks under existing CoC No. 1025, Amendment Nos. 6, 7, or 8, that are being revised by this final rule. As the vendor, NAC is not within the scope of the backfitting provisions in 10 CFR 72.62.

Under 10 CFR 72.62, general licensees are entities that are within the scope of the backfitting regulations. However, according to NAC (ML24193A110), no general licensees are currently storing NAC-MPC systems under CoC No. 1025, Amendment No. 6, which is, in part, the subject of these revisions. Therefore, because CoC No.

J. Shepherd 4

1025, Amendment No. 6 is not in use by a licensee, the changes in the revision to CoC No. 1025, Amendment No. 6, which are approved in this direct final rule do not fall within the definition of backfitting under 10 CFR 72.62.

Dairyland Power Cooperative at its La Crosse Boiling Water Reactor independent spent fuel storage installation (ISFSI) is the only general licensee using Amendment No. 7 that could be affected by the issuance of Revision 1 to Amendment No. 7. In its letters to NAC (ML23250A056 and ML24193A110), Dairyland Power Cooperative stated that it intends to implement the revision to Amendment No. 7, as soon as practical after it is issued, and noted that all previously fabricated systems on site will be recertified to the adopted amendment revision. Because the licensee voluntarily intends to implement the revision, the issuance of Revision 1 to Amendment No. 7 does not fall within the definition of backfitting under 10 CFR 72.62.

Connecticut Yankee Atomic Power Company at its Haddam Neck Plant ISFSI and Yankee Atomic Electric Company at its Yankee Nuclear Power Station ISFSI are the two general licensees using Amendment No. 8 that could be affected by the issuance of Revision 1 to Amendment No. 8. In its letter to NAC (ML23250A056), Connecticut Yankee Atomic Power Company stated that it intends to adopt Revision 1 to Amendment No. 8 following NRC approval and issuance. Yankee Atomic Electric Company also stated in its letter (ML23250A056) that it intends to adopt Revision 1 to Amendment No. 8 following NRC approval and issuance. The licensees noted that the proposed changes do not directly impact the Haddam Neck Plant ISFSI and Yankee Nuclear Power Station ISFSI, because the sites utilize solid carbon steel lids for the VCCs they store. Because both licensees voluntarily intend to implement the revision, issuance of Revision 1 to Amendment No. 8 does not fall within the definition of backfitting under 10 CFR 72.62.

4.

The proposed CoCs, technical specifications, and preliminary safety evaluation report have been placed in ADAMS (see references below) and are available for your use in the rulemaking package. DFM will designate these documents as Official Agency Records after the Executive Director for Operations has approved the package (ML24242A043).

The Office of the General Counsel has reviewed this memorandum with its referenced documents and has no legal objection to its contents.

Docket No.: 72-1025 CAC No.: 001208 EPID Nos: L-2023-LLA-0149 L-2023-LLA-0148 ADAMS

References:

1.

User Need Memo for Amendment No. 9, and Revision to Amendment Nos. 6, 7, and 8, of the Renewed Certificate of Compliance No. 1025 for the NAC Multi-Purpose Canister System (ML24242A047) 2.

Proposed Renewed CoC No. 1025, Amendment No. 6, Revision 1 (ML24242A048) 3.

Proposed Renewed CoC No. 1025, Amendment No. 6, Revision 1, Appendices A and B (ML24242A049)

J. Shepherd 5

4.

Proposed Renewed CoC No. 1025, Amendment No. 7, Revision 1 (ML24242A050) 5.

Proposed Renewed CoC No. 1025, Amendment No. 7, Revision 1, Appendices A and B (ML24242A051) 6.

Proposed Renewed CoC No. 1025, Amendment No. 8, Revision 1 (ML24242A052) 7.

Proposed Renewed CoC No. 1025, Amendment No. 8, Revision 1, Appendices A and B (ML24242A053) 8.

Proposed Renewed CoC No. 1025, Amendment No. 9 (ML24242A054) 9.

Proposed Renewed CoC No. 1025, Amendment No. 9, Appendices A and B (ML24242A055) 10.

Preliminary Safety Evaluation Report for NAC Multi-Purpose Canister System, Renewed CoC No. 1025, Amendment No. 9, and Revision to Amendment Nos. 6, 7, and 8 (ML24242A056)

ML24242A043 (Pkg), ML24242A047 (Memo)

ML24242A048 - ML24242A056 (Encls)

OFFICE NMSS/DFM/STLB NMSS/DFM/MSB NMSS/DFM/MSB NMSS/DFM/MSB NAME KBanovac CSydnor BPatel GZhao DATE 9/4/2024 9/5/2024 8/29/2024 8/29/2024 OFFICE NMSS/DFM/NARAB NMSS/DFM/IOB NMSS/DFM/MSB NMSS/DFM/NARAB(A)

NAME ASotomayor-Rivera ADjapari DDunn for TBoyce TGovan DATE 8/29/2024 9/5/2024 9/6/2024 9/9/2024 OFFICE NMSS/DFM/IOB NMSS/DFM/STLB OGC NMSS/DFM/STLB NAME HRodriguez WWheatley EDuncan YDiaz-Sanabria DATE 9/5/2024 9/12/2024 9/25/2024 10/17/2024

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