ML25350C072

Tn Americas LLC - Supplement to Application for Certificate of Compliance No. 9377 Revision 1 of the TN-32 Transportation Package

ML25350C072
Person / Time
Site:	07109377
Issue date:	12/16/2025
From:	Narayanan P Orano TN Americas, TN Americas LLC
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
EPID L-2025-LLA-0103, E-65117, CAC 001029
Download: ML25350C072 (0)

Text

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.

December 16, 2025 E-65117 U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852

Subject:

TN Americas LLC Supplement to Application for Certificate of Compliance No. 9377 Revision 1 of the TN-32 Transportation Package (Docket No. 71-9377), CAC 001029/EPID L-2025-LLA-0103

Reference:

TN Americas letter dated September 5, 2025, TN Americas LLC Application for Certificate of Compliance No. 9377 Revision 1 of the TN-32 Transportation Package (Docket No. 71-9377)

In accordance with 10 CFR 71.31(b), TN Americas LLC (TN) submitted an application to revise Certificate of Compliance (CoC) No. 9377 for the TN-32 Transportation Package [Reference]. This supplement provides additional proposed minor changes to general assembly drawings, a lid assembly and parts list drawing, and impact limiter drawings, to facilitate fabrication and ease of operation.

A description of the changes to the Safety Analysis Report (SAR), as well as justifications for those changes, are provided in Enclosure 2.

Safety Analysis Report annotated drawing sheets are included as Enclosure 3.

The revised drawings show proposed changes in red boxes. There is no public enclosure of the SAR changed pages as all changes occur on proprietary drawings. Finalized drawings will be provided as part of the consolidated SAR, which will be submitted at the end of this application process.

This submittal includes TN proprietary information that may not be used for any purpose other than to support the NRC staffs review of the application. In accordance with 10 CFR 2.390, an affidavit is provided as Enclosure 1, specifically requesting that this proprietary information be withheld from public disclosure. This submittal also contains appropriately labeled security-related sensitive information, which should be withheld under 10 CFR 2.390.

E-65117 Document Control Desk Page 2 of 2 Should the NRC staff require additional information to support review of this application, please contact Doug Yates at (434) 832-3101 or by email at douglas.yates@orano.group.

Sincerely, Prakash Narayanan Chief Technical Officer cc:

Chris Markley (NRC), Storage and Transportation Licensing Branch, Division of Fuel Management

Enclosures:

1.

Affidavit Pursuant to 10 CFR 2.390

2.

Summary of Changes to CoC 9377 TN-32 SAR Revision 1B

3.

TN-32 Safety Analysis Report, Annotated SAR Drawing Sheets (Proprietary version) to E-65117 Page 1 of 1 TN AMERICAS LLC AFFIDAVIT PURSUANT TO 10 CFR 2.390 State of Maryland:

County of HOWARD:

I, Prakash Narayanan, depose and say that I am the Chief Technical Officer of TN Americas LLC, duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information which 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:

• - TN-32 Safety Analysis Report, Annotated SAR Drawing Sheets (Proprietary version)

This document has 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 document, should be withheld.

1) The information sought to be withheld from public disclosure involves certain design details associated with the SAR drawings for the TN-32B Transportation Cask, 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 analysis of a radioactive material transportation system, 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 America LLCs product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

Further the deponent sayeth not.

Executed on: December 12th, 2025 Prakash Narayanan Chief Technical Officer, TN Americas LLC to E-65117 Page 1 of 2 Summary of Changes to CoC 9377 TN-32 SAR Revision 1B Item 1:

Description of Changes:

1) Change the ID of Items 17 and 18 in the bill of materials (BOM) of safety analysis report (SAR) Drawing 19885-71-2 to 80.699 inches and 82.373 inches, respectively.

2) Change the material specification of SAR Drawing 19885-71-3 Item 12 to HN290SP.

3) Eliminate tack welds between the nuts (Item 33) and tie-rod plates (Item 16 and Item 23) in SAR Drawing 19885-71-9, and update the BOM to remove (Item 33). These nuts will be installed and tightened during final assembly of the TN-32B package rather than pre-installed (tack-welded) as part of the impact limiter (IL) package.

4) Remove the nuts from Section A-A, Sheet 2, and the top/side views on Sheet 3 of SAR Drawing 19885-71-9.

5) Reduce the overall length of the tie-rods by 1-1/2 inches in SAR Drawing 19885-71-8, Sheet

3.

6) Revise IL general assembly SAR Drawing 19885-71-8 to add washers (Item 16) on the tie-rods (Item 8), under the hex nuts (Item 13), and update the quantity for Item 16 in the BOM to account for the newly added washers. Add locksleeves (Item 9) and quick release pins (Item 11) on the bottom end of the tie-rods, matching what is already present at the top end, and update the quantity of these components in the BOM to reflect this. Also, update Note 2 of SAR Drawing 19885-71-8 to specify a torque requirement for hex nuts (Item 13).

These changes are also reflected in the cask general assembly SAR Drawing 19885-71-1.

7) Remove Note 4 on SAR Drawings 19885-71-9 and 19885-71-10.

Justification of Changes:

1) Per SAR Drawing 19885-71-4, the mean O-Ring groove diameters are 81.074 inches and 82.748 inches. With a cross-section of 0.375 inches, the inner most diameters of the inner and outer O-Rings should be 81.074 -.375 = 80.699 inches and 82.748 -.375 = 82.373 inches. There is no impact on design as this change is necessary to make the O-Ring and O-Ring groove mean diameters coincident, thus ensuring the sealing function can be performed.

2) An incorrect material specification is listed in the BOM. The correct material specification of the actual seal is Helicoflex HN290SP. This change will correct the part number so that the seal can be procured in accordance with the licensing documents. There is no impact on design because this proposed activity will ensure the seal performs its sealing function as intended and that the seal can be retained in the groove during installation.

3) TN is in the process of preparing an assembly procedure for the ILs. It was noted that the tie-rod installation would be encumbered by the current design configuration of the IL tie-rod brackets. The nut (Item 33) shown in SAR Drawing 19885-71-9, Sheet 3 is meant to provide tension to the tie-rod, and the fact that it is tack welded to the IL tie-rod bracket would prevent adequate tightness of the tie-rod after assembly. This change allows ease of installation of the tie-rods.

to E-65117 Page 2 of 2

4) This is an editorial change resulting from Change 3 described above. Because the tack welds described in Change 3 are proposed to be removed, the appearance of these nuts in SAR Drawing 19885-71-9 is no longer needed.

5) For proper installation of the tie-rods through the brackets, as illustrated in Drawing 19885-71-8, tie-rods should be inserted with one end fully through the bracket holes. Then, they are aligned, and the opposite end of the tie-rod is inserted into the bracket holes on the opposing side. This installation requires sufficient clearance. After reviewing the IL assembly model, it was recognized that the tie-rods may be too long, which can cause an interference issue during installation. This change does not impact the existing structural evaluation of the IL attachments addressed in UFSAR Section 2.12.9. This change allows ease of installation of the tie-rods.

6) Because the nuts are no longer tack-welded per Change 3, a proper torque requirement needs to be specified on SAR Drawing 19885-71-8, and washers need to be added under the nuts to prevent them from tearing off the coatings on the brackets. For additional security, the quantity of the locksleeves and quick released pins is increased from 13 to 26 to secure the tie-rods from both sides. This change allows ease of installation of the tie-rods.

7) After reviewing the fabrication procedures of the ILs, it was noted that the white paint coating is only required to be applied on the carbon steel surfaces to protect them against corrosion, rather than the entire exposed IL surfaces, which are made of 304 type stainless steel. Therefore, Note-4 of IL SAR Drawings 19885-71-9 and 19885-71-10 is not needed.

Impact:

The following drawings have been revised as described above:

SAR Drawing 19885-71-1, Sheet 1 and Sheet 2; SAR Drawing 19885-71-2, Sheet 1; SAR Drawing 19885-71-3, Sheet 1; SAR Drawing 19885-71-8, Sheet 1, Sheet 2, and Sheet 3; SAR Drawing 19885-71-9, Sheet 1, Sheet 2, and Sheet 3; and SAR Drawing 19885-71-10, Sheet 1 to E-65117 TN-32 Safety Analysis Report, Annotated SAR Drawing Sheets (Proprietary version)

Withheld Pursuant to 10 CFR 2.390