ML25197A615
| ML25197A615 | |
| Person / Time | |
|---|---|
| Site: | 07201004 |
| Issue date: | 08/05/2025 |
| From: | Stroud H Storage and Transportation Licensing Branch |
| To: | Narayanan P TN Americas LLC |
| Shared Package | |
| ML25197A614 | List: |
| References | |
| CAC 001028, EPID L-2024-LLA-0142 | |
| Download: ML25197A615 (1) | |
Text
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OFFICIAL USE ONLY PROPRIETARY INFORMATION OFFICIAL USE ONLY PROPRIETARY INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Prakash Narayanan Chief Technical Officer TN Americas, LLC 7135 Minstrel Way, Suite 300 Columbia, MD 21045
SUBJECT:
APPLICATION FOR AMENDMENT NO. 19 TO CERTIFICATE OF COMPLIANCE NO. 1004 FOR THE STANDARDIZED NUHOMS SYSTEM -
REQUEST FOR ADDITIONAL INFORMATION
Dear Prakash Narayanan:
By \
letter dated November 5, 2024 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML24310A095), as supplemented on February 20, 2025 (ML25051A272, non-public), and March 4, 2025 (ML25063A118, non-public), TN Americas, LLC (TN) submitted an application for Certificate of Compliance No. 1004, Amendment No. 19, to the Standardized NUHOMS System, pursuant to the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 72.
In connection with our review, we need the information identified in the enclosure to this letter.
To assist us in scheduling our review of your response, we request that you provide this information within 30 days from the date of this letter. Inform us at your earliest convenience if you are not able to provide the information by that time frame.
Please reference Docket No. 72-1004, Cost Activity Code System No. 001028 and Enterprise Project Identifier L-2024-LLA-0142 in future correspondence related to this request. The NRC staff is available to clarify these questions, and, if necessary, meet to discuss your proposed responses.
In accordance with 10 CFR Part 2, Agency Rules of Practice and Procedure, 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 call 1-800-397-4209 or 301-415-4737, between 8 a.m. and 4 p.m.
eastern time (ET), Monday through Friday, except Federal holidays. transmitted herewith contains proprietary information. When separated from the sensitive conditions in Enclosure 2, this letter and Enclosure 1 are decontrolled.
August 5, 2025
OFFICIAL USE ONLY PROPRIETARY INFORMATION P. Narayanan 2
OFFICIAL USE ONLY PROPRIETARY INFORMATION If you have any questions regarding this communication, please contact me at 301-287-3664, or via email to heath.stroud@nrc.gov.
Sincerely, Heath Stroud, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-1004 CAC No.: 001028 EPID: L-2024-LLA-0142
Enclosures:
1.
Request for Additional Information (Public) 2.
Request for Additional Information (Proprietary Information)
Signed by Stroud, Heath on 08/05/25
ML25197A614(pkg, non-public),
ML25197A615(ltr & encl 1), ML25197A616(encl 2, non-public)
OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME HStroud JIreland BPatel JHuang DATE 7/16/2025 7/17/2025 7/22/2025 7/30/2025 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME TGovan LRegner WWheatley YDiaz-Sanabria DATE 7/30/2025 7/30/2025 7/30/2025 8/5/2025 OFFICE NMSS/DFM NAME HStroud DATE 8/5/2025
OFFICIAL USE ONLY PROPRIETARY INFORMATION OFFICIAL USE ONLY PROPRIETARY INFORMATION Request for Additional Information Amendment No. 19 to Certificate of Compliance No. 1004 for Standardized NUHOMS System (Docket No. 72-1004, CAC No. 001028, EPID: L-2024-LLA-0142)
Structural Evaluation RAI-St-1 Clarify/explain if the Type 3 DSC and basket can be installed in the HSM-HS and if they can be located in a high seismic level area.
Regarding installation of the 61BTH Type 3 dry storage canister (DSC) and basket inside the HSM-HS, explain and/or clarify the following:
a) How the Type 3 DSC and basket are evaluated for installation within the HSM-HS for the high seismic criteria.
b) Provide a definition and pertinent information of HSM-HS in the proposed certificate of compliance (CoC).
According to the updated final safety analysis report (UFSAR) Section U.1.2.1.2, NUHOMS HSM-HS storage module is an upgraded version of the NUHOMS HSM-H to allow the NUHOMS storage systems use in locations where higher seismic levels exist. The proposed UFSAR Section T.1 in part, describes that the 61BTH Type 1, 2 and 3 DSC (including Type 1, 2 and 3 basket, respectively) can be stored in the HSM-H and HSM-HS storage modules.
The UFSAR Sections T.3.7.2.1 and T.3.7.2.2 indicate that the 61BTH Type 1 and Type 2 DSC and baskets are evaluated for the bounding High Seismic Criteria design loads. The proposed UFSAR Section T.3.8.6.4 indicates that the loading conditions for the 61BTH Type 3 basket bound the seismic loads based on the Standard Seismic Criteria described in Section T.3.7.2.2.
From the UFSAR sections described above, it appears that the 61BTH Type 1 and Type 2 DSC and baskets are evaluated for installation within the HSM-HS storage module for high seismic criteria. However, it is not clear to the NRC staff whether the 61BTH Type 3 DSC and basket were evaluated for installation within the HSM-HS for the high seismic criteria.
Further, the proposed CoC Section I identifies the HSM models authorized for use including the HSM-H, HSM-H high seismic option and HSM-HS. However, the rest of the proposed CoC and appendices do not define and provide relevant information in CoC section II.2.a, Appendix A section 3.1 and Appendix B section 1.1 about HSM-HS.
This information is needed to determine compliance with Title 10 CFR Section 72.236(b) and (c).
OFFICIAL USE ONLY PROPRIETARY INFORMATION Thermal Evaluation RAI-Th-1 Proprietary information. See Enclosure 2.
RAI-Th-2 Proprietary information. See Enclosure 2.
Materials Evaluation RAI-M-1 Describe the neutron absorbing materials for the NUHOMS-61BTH Type 3 design.
UFSAR page T.1-1 states that the NUHOMS-61BTH Type 3 DSC is only designed with the metal matrix composite (MMC) neutron absorber plate material for a single B-10 loading option.
Page T.4-12a states [t]he 61BTH Type 3 DSC design allows for the use of various neutron absorber materials such as MMC neutron absorber material. Drawing No. NUH61BTH-5002-SAR, NUHOMS 61BTH DSC Type 3 Basket Assembly, only lists the MMC.
This information is needed to determine compliance with 10 CFR 72.236(b).
RAI-M-2 Proprietary information. See Enclosure 2.
2 OFFICIAL USE ONLY - PROPRIETARY INFORMATION