ML25129A058

Proposed Alternatives to NG-4323 and IX QW-191.2.1, 72-1004, Certificate of Compliance No. 1004

ML25129A058
Person / Time
Site:	07201004
Issue date:	05/09/2025
From:	Narayanan P Orano TN Americas
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
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ML25129A057	List: ML25129A058
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E-64360
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Orano TN 7160 Riverwood Drive Suite 200 Columbia, MD 21046 USA Tel: 410-910-6900 Fax: 434-260-8480 Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.

May 9, 2025 E-64360 U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852

Subject:

Proposed Alternatives to NG-4323 and IX QW-191.2.1, Docket 72-1004, Certificate of Compliance No. 1004 In accordance with the provision cited in Condition II.1.d of Certificate of Compliance (CoC) No. 1004, Renewed Amendment 18, TN Americas LLC (TN) requests alternatives to the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel (B&PV) Code Section III, Division 1, for NG-4323 and for IX QW-191.2.1 to CoC Appendix C, Table C-12 for welder qualification.

The alternatives are requested only for Dry Shielded Canister (DSC) S/N BNP-61BTH-2-F-2H-CH52. No other DSCs are included.

Proposed Alternative CoC 1004 renewed Amendment 18 CoC Condition II.1.b, states that DSCs are designed fabricated, tested, and inspected to the maximum practical extent in accordance with ASME B&PV Code Section III, Division 1, Subsections NB, NF, and NG for Class 1 components and supports. The requested code alternatives provide for an alternative that, in lieu of the requirement for NG-4323 and for IX QW-191.2.1, a full ultrasonic testing (UT) evaluation of the joint may be performed to ensure adequacy of the weld as it relates to qualified welding operators.

Justification The UT examination performed on the fuel compartment tubes for the 61BTH Type 2 DSC (S/N BNP-61BTH-2-F-2H-CH52) was done by a company named RRL NDT Consulting, whose procedure specifications required the use of a calibration block, and a GE transducer, which is equivalent to the #4 Image Quality Indicator (IQI) wire size required in Table T-276 (ASME Section V) for the radiographic testing (RT) examination that the UT is in lieu of.

RRL NDT Consulting has since gone out of business, and the associated procedure qualification record (PQR), is no longer available. However, as part of this submittal, a copy of the certification report for the calibration block used in the inspection is provided as Enclosure 3.

E-64360 Document Control Desk Page 2 of 3 The report details the calibration block configuration and reflectors and shows that it is in accordance with ASME Section V, Article 4, Figure T-434.3-1. The certificate shows that the calibration block is made of Type 316 stainless steel. The fuel compartment tubes that were inspected are made of Type 304 stainless steel. Per the ASNT UT level III inspector that performed the actual inspection, the velocity differences in Type 316 vs. Type 304 stainless steel are negligible in short sound paths such as in 10ga material and the discrepancy in material is permissible.

Also, included as Enclosure 4 of this submittal, is the Ultrasonic Inspection Report performed on the 61 fuel compartment tubes in question (S/N BNP-61BTH-2-F-2H-CH52),

which shows that there were no rejectable identifications found. There was one fuel tube that was fabricated which failed to have sufficient penetration depth in the weld; however, this part was scrapped, and no repair procedure was performed. The information about this rejected part can be found in the Non-Conformance Report (NCR) provided as Enclosure 5.

TN Americas LLC proposed code alternatives added to Appendix C, Table C-12 (ASME NG-4323 and ASME Section IX QW-191.2.1) reflect that the scope of their applicability is limited to a single fabricated DSC (S/N BNP-61BTH-2-F-2H-CH52) and is provided in.

TN believes that these proposed alternatives provide an acceptable level of quality and safety. Additionally, the fabrication of this particular DSC had moved beyond these particular welding steps to an extent that compliance with the specified requirements of the ASME Code would result in unusual difficulty without a compensating increase in the level of quality and safety, based on the proposed alternatives.

Enclosures 3, 4, and 5 contain proprietary information, which may not be used for any purpose other than to support NRC staff review of the proposed code alternative. In accordance with 10 CFR 2.390, an affidavit (Enclosure 1) is provided specifically requesting that this proprietary information be withheld from public disclosure. Because Enclosures 3, 4, and 5 are entirely proprietary, no public versions are provided.

NRC approval is respectfully requested when practical to support future use of this particular 61BTH Type 2 basket. If the NRC staff has any questions regarding this submittal, please contact Mr. Doug Yates at (434) 832-3101, or by email at douglas.yates@orano.group.

Sincerely, Prakash Narayanan Chief Technical Officer cc:

John-Chau Nguyen (NRC-DFM)

E-64360 Document Control Desk Page 3 of 3

Enclosures:

1. Affidavit Pursuant to 10 CFR 2.390

2. Proposed CoC Appendix C ASME Code Alternatives Table C-12

3. Calibration Block Certification Report (Proprietary)

4. RRL NDT Consulting Ultrasonic Inspection Report (Proprietary)

5. TN Americas LLC Fabrication Nonconformance Report (Proprietary) to E-64360 Page 1 of 1 AFFIDAVIT PURSUANT TO 10 CFR 2.390 State of Maryland:

County of HOWARD:

I, Prakash Narayanan, depose and say that I am Chief Technical Officer of TN Americas LLC, duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information that is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.390 of the Commissions regulations for withholding this information.

The information for which proprietary treatment is sought is listed below:

• - Calibration Block Certification Report (Proprietary)

• - RRL NDT Consulting Ultrasonic Inspection Report (Proprietary)

• - TN Americas LLC Fabrication Nonconformance Report (Proprietary)

These documents have been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by TN Americas LLC in designating information as a trade secret, privileged, or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commissions regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced documents, should be withheld.

1) The information sought to be withheld from public disclosure involves supporting files, all related to the design and fabrication of the Standardized NUHOMS dry spent fuel storage system, which are owned and have been held in confidence by TN Americas LLC.

2) The information is of a type customarily held in confidence by TN Americas LLC, and not customarily disclosed to the public. TN Americas LLC has a rational basis for determining the types of information customarily held in confidence by it.

3) Public disclosure of the information is likely to cause substantial harm to the competitive position of TN Americas LLC, because the information consists of descriptions of the design and fabrication of dry spent fuel storage systems, the application of which provide a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with TN Americas LLC, take marketing or other actions to improve their products position or impair the position of TN Americas LLCs product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

I declare that the statements set forth in this affidavit are true and correct to the best of my knowledge, information, and belief. I declare under penalty of perjury that the foregoing is true and correct.

Executed on: May 9th, 2025 Prakash Narayanan Chief Technical Officer, TN Americas LLC to E-64360 Page 1 of 1 Proposed CoC Appendix C ASME Code Alternatives Table C-12 Reference ASME Code Section/Article Code Requirement Alternatives, Justification & Compensatory Measures NG-4323 Only welders and welding operators who are qualified in accordance with NG-4323 and Section IX shall be used.

Permit the qualification of the welding operator per Section IX QW-305.1 for DSC S/N BNP-61BTH-2-F-2H-CH52, where a minimum of 3 ft (1 m) length of the first production weld(s) is made entirely by the welding operator in accordance with qualified WPS and examined by volumetric NDE.

This alternative is to apply to mechanized and automated welding only and shall exclude performance qualifications using the GMAW Short Circuit process. Examination shall be per Section IX QW-191. Note that the scope of this alternative applies to DSC S/N BNP-61BTH-2-F-2H-CH52 only.

Mechanized welding has a level of inherent consistency that justifies a less stringent set of essential variables. (See Section IX QW-350 and QW-360 and FORM QW-484A and FORM QW-484B). Mechanized welding is more about the understanding of the operational process than the physical coordination control required for manual welding. Additionally, as per Section IX QW-142, Radiographic or Ultrasonic examination per QW-191 may be substituted for mechanical testing of QW-141 for groove-weld performance qualification as permitted in QW-304 to prove the ability of welders to make sound welds.

Section IX QW-191.2.1 (a) The ultrasonic examination in QW-142 for welders and in QW-143 for welding operators may be conducted on test welds in material 1/4 inch (6 mm) thick or greater.

(b) Ultrasonic examinations shall be performed using a written procedure in compliance with Section V, Article 1, T-150 and the requirements of Section V, Article 4 for methods and procedures.

UT examination shall be qualified per Section V Article 4 for DSC S/N BNP-61BTH-2-F-2H-CH52 and the minimum material thickness shall be limited to 0.08 in. (2 mm).

Indications shall not exceed the lesser of 1/2 the weld thickness or Section IX QW-191.2.2(a)-(b). Qualified thickness limits are per Section IX Table QW-451. Note that the scope of this alternative applies to DSC S/N BNP-61BTH-2-F-2H-CH52 only.

Improvements in UT technology have proven reliable down to 1/8 in. (2mm) in thickness. In Section IX QW-191.2, the minimum material thickness was reduced from 1/2 in. to 1/4 in. in 2017 due to improvements in UT technology and performance.

Additionally, examination acceptance criteria are per Section IX of the Code which is more stringent than NG.

to E-64360 Calibration Block Certification Report (Proprietary)

Withheld Pursuant to 10 CFR 2.390 to E-64360 RRL NDT Consulting Ultrasonic Inspection Report (Proprietary)

Withheld Pursuant to 10 CFR 2.390 to E-64360 TN Americas LLC Fabrication Nonconformance Report (Proprietary)

Withheld Pursuant to 10 CFR 2.390