ML25078A249

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1 User Need for Rulemaking for the NUHOMS Eos Dry Spent Fuel Storage System, Certificate of Compliance No. 1042, Amendment No. 4
ML25078A249
Person / Time
Site: 07201042
Issue date: 04/24/2025
From: Yoira Diaz-Sanabria
Storage and Transportation Licensing Branch
To: Andrew Carrera
NRC/NMSS/DREFS/MRPB
Shared Package
ML25078A248 List:
References
CAC 001028, EPID L-2022-LLA-0017
Download: ML25078A249 (1)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 MEMORANDUM TO:

Andrew Carrera, Acting 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 THE NUHOMS EOS DRY SPENT FUEL STORAGE SYSTEM CERTIFICATE OF COMPLIANCE NO. 1042, AMENDMENT NO. 4 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 licensing action:

1.

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

Certificate Number: 1042.

Initial Certificate Effective Date: June 7, 2017.

Amendment Number 1 Effective Date: June 17, 2020.

Amendment Number 2 Effective Date: October 26, 2021.

Amendment Number 3 Effective Date: July 17, 2023.

Amendment Number 4 Effective Date: [insert 75 days from date of Federal Register publication].

SAR Submitted by: TN Americas LLC.

SAR

Title:

Final Safety Analysis Report for the NUHOMS EOS Dry Spent Fuel Storage System.

Docket Number: 72-1042.

Certificate Expiration Date: June 7, 2037.

Model Number: EOS-37PTH, EOS-89BTH, 61BTH Type 2.

2.

By letter dated September 29, 2022 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML22272A575), as supplemented in letters dated CONTACT: Yen-Ju Chen, NMSS/DFM 301-415-1018 April 24, 2025 Signed by Diaz-Sanabria, Yoira on 04/24/25

A. Carrera 2

March 30, 2023 (ML23089A175), June 28, 2023 (ML23179A120), April 22, 2024 (ML24113A307), November 6, 2024 (ML24311A209), and February 12, 2025 (ML25043A122), TN Americas LLC (TN) requested that the U.S. Nuclear Regulatory Commission amend the Certificate of Compliance (CoC) No. 1042 to include the following changes:

Change No. 1:

For the EOS-37PTH, similar to the EOS-89BTH concept submitted under Amendment No. 3 (Change No. 7), incorporate a method to determine new loading patterns based on the maximum allowable heat load per dry shielded canister (DSC), identified as the maximum allowable heat load configuration (MHLC). The MHLC is applicable to the EOS-37PTH transferred in the EOS-TC125 and stored in the EOS-horizontal storage module (HSM). Two new heat load zone configurations (HLZCs) are applicable to this MHLC.

Change No. 2:

Introduce a steel plate composite option for the EOS-HSM. The steel plate composite option allows for the HSM components to be constructed from concrete-filled integrated steel wall forms. The walls are tied together with tie bars and studs are welded to the inside of the walls to provide concrete reinforcement. When used without distinction, EOS-HSM-SC refers to both the segmented and one-piece base. The EOS-HSM-SC is used only with the flat plate support structure.

Change No. 3:

Introduce the use of MAVRIC software for a confirmatory run of the HSM-MX dose rates.

Change No. 4:

Technical Specification (TS) changes for consistency among DSC types and terminology clarification.

Change No. 5:

Various updated final safety analysis report (UFSAR) editorial corrections for consistency and clarification.

Change No. 6:

Add measured exposures from past loading campaigns to highlight that measured exposures are significantly less than calculated exposures.

Additional Scope Change No. 1:

Add an additional scope item to allow use of a blended Portland cement that would be certified to the requirements of American Society for Testing and Materials (ASTM)

C595. The reason for this change is that the cement supplier will no longer provide cement in accordance with ASTM C150 since the supplier is transitioning to a cement with a smaller carbon footprint that includes 10 percent limestone. This change supports continued EOS-HSM and EOS HSM-MX fabrication activities. In support of this additional scope, revise UFSAR sections 8.2.1.3, EOS HSM Horizontal Storage Module; 8.7, References; A.8.2.1.3, HSM-MX Horizontal Storage Module; and A.8.7, References.

Also add an editorial clarification to UFSAR chapters 8 and A.8 regarding the use of a blended Portland cement that would be certified to the requirements of ASTM C595.

A. Carrera Additional Scope Change No. 6:

Add an additional scope item related to the use of the MX-Loading Crane (LC) for the 61BTH Type 2 DSCs. The reason for this change is that, under Amendment No. 3, TN added detail to demonstrate the single failure proof capability of the MX-LC. That information was provided to demonstrate compliance with CoC No. 1042, Amendment No. 3, Condition 5 for lifts of the DSC and transfer cask (TC) above heights not analyzed for an accidental drop, and to comply with CoC No. 1042, Amendment No. 3, TS 5.2.1 for TC/DSC lifting height limits. However, TN omitted addressing use of the MX-LC for the 61BTH DSCs. This change supports the continued use of the HSM-MX in conjunction with the MX-LC for 61BTH DSCs. In support of this additional scope, revise UFSAR sections B.9.1.6, DSC Transfer to the HSM-MX; B.9.2.1, DSC Retrieval from the HSM-MX; B.9.3, References; B.12.3.1, OS197 Transfer Cask (TC) Drop; and B.12.4, References.

Additional Scope Change No. 8:

Add an additional scope item to clarify the scenarios under which the maximum heat loads can be reduced for EOS-37PTH. The reason for this change is to clarify the different site-specific conditions that could result in a reduction in the maximum heat load for existing HLZCs and to also note that one could develop new HLZCs based on the MHLC methodology described in UFSAR section 2.4.3.1. Add this clarifying language to the fourth paragraph on UFSAR page 2-10 and to page 2-2 of the TS.

The proposed CoC, 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 (ML25078A248).

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

Docket No. 72-1042 CAC No. 001028 EPID: L-2022-LLA-0017 ADAMS

References:

1.

Proposed CoC No.1042 - EOS Amendment No. 4 (ML25078A250) 2.

Proposed Technical Specifications - EOS Amendment No. 4 (ML25078A251) 3.

PSER - EOS Amendment No. 4 (ML25078A252)

ML25078A248(Package); ML25078A249(Memo);

ML25078A250(CoC), ML25078A251(TS for CoC), ML25078A252(SER)

OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME YChen ABarto CBajwa ASotomayor-Rivera DATE 3/20/2025 3/20/2025 3/20/2025 3/20/2025 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME DDunn JTapp WWheatley JSmith DATE 3/20/2025 3/21/2025 3/26/2025 3/26/2025 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME DJohnson TGovan LRegner GGeorge DATE 3/26/2025 3/28/2025 3/28/2025 3/30/2025 OFFICE OGC NLO NMSS/DFM NMSS/DFM NAME CCarson YChen YDiaz-Sanabria DATE 4/22/2025 4/23/2025 4/24/2025