ML26056A002
| ML26056A002 | |
| Person / Time | |
|---|---|
| Site: | 07201004 |
| Issue date: | 02/25/2026 |
| From: | Narayanan P TN Americas LLC |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| E-65255 | |
| Download: ML26056A002 (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.
February 25, 2026 E-65255 U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852
Subject:
Response to Additional Information for Proposed Alternatives to NG-4323 and IX QW-191.2.1, Docket 72-1004, Certificate of Compliance No. 1004
References:
Letter from Heath Stroud (U.S. NRC) to Prakash Narayanan (TN Americas LLC), Proposed Alternatives to NG4323 and IX QW191.2.1 for Certificate of Compliance No. 1004-Request for Additional Information, (Docket No. 1004, CAC No. 001028, EPID: L-2025-LLE-0016), dated January 14, 2026 TN Americas LLC (TN) hereby submits our response to the Request for Additional Information (RAI) forwarded by the letter referenced above. Enclosure 2 provides the response to the RAI. The ultrasonic testing (UT) procedure, UT inspection report, and calibration block certification report have been revised as applicable and are provided as Enclosures 3, 4, and 5, respectively.
Enclosures 3, 4, and 5 contain 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 commercial confidential information be withheld from public disclosure. Because Enclosures 3, 4, and 5 are entirely proprietary, no public versions are provided.
E-65255 Document Control Desk Page 2 of 2 If the NRC staff has any questions regarding this submittal, please contact Ms. Jess Gee at 240-389-3194 or Jess.Gee@Orano.group.
Sincerely, Prakash Narayanan Chief Technical Officer cc:
John-Chau Nguyen (NRC-DFM)
Enclosures:
- 1. Affidavit Pursuant to 10 CFR 2.390
- 2. RAI and Response
- 3. UT Procedure 05.01 Revision 3 (Proprietary)
- 4. Ultrasonic Inspection Report (Proprietary)
- 5. Calibration Block Certification Report (Proprietary) to E-65255 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:
- - UT Procedure 05.01 Revision 3 (Proprietary)
- - Ultrasonic Inspection Report (Proprietary)
- - Calibration Block Certification 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: February 23rd, 2026 Prakash Narayanan Chief Technical Officer, TN Americas LLC
RAI and Response to E-65255 Page 1 of 1 Materials Evaluation:
RAI-M-1:
Section 2.4 of RJW 05.01 UT ASME Rev. 0, states, This procedure covers the straight beam and angle examination of carbon steel, low/medium/high alloy steel, and stainless steel 1/2 inch and over in thickness.
However, the Procedure Qualification Record from Enclosure 2 to E64890 states that the base metal thickness is 0.130 inch. The staff requests the applicant to provide justification in utilizing an Ultrasonic Inspection procedure on a weld and base metal that did not meet the minimum thickness requirements listed in the referenced procedure.
This information is requested by the staff to demonstrate compliance with Title 10 of the Code of Federal Regulations 72.236(b).
Response to RAI-M-1:
The use of Ultrasonic Testing (UT) Procedure RJW 05.01 UT ASME Revision 0 for inspection of the fuel tube weld was in error. The procedure was not applicable for this inspection because of the 1/2 inch and over requirement stated in Section 2.4. A Corrective Action has been created to address this oversight and revise the UT procedure to allow inspection of a material thickness suitable to support inspection of the 0.12 thick fuel tube.
The procedure has been revised and requalified using a calibration standard made from the fuel compartment tube material. No significant changes were made that could affect the results obtained in the non-destructive examination (NDE) reports prepared in January 9, 2023 for inspection of the tube assembly. For added assurance, TN Americas LLC had an independent Level III UT inspector from a separate company review the procedure and witness the qualification. The revised UT procedure, UT inspection report, and calibration certification report are included as Enclosures 3, 4, and 5, respectively, for your review.
Note that the NUHOMS 61BTH basket compartment welds are primarily inspected visually and the UT inspection is employed herein to provide the required additional assurance.
Impact:
No change as a result of this RAI.
to E-65255 UT Procedure 05.01 Revision 3 (Proprietary)
Withheld Pursuant to 10 CFR 2.390 to E-65255 Ultrasonic Inspection Report (Proprietary)
Withheld Pursuant to 10 CFR 2.390 to E-65255 Calibration Block Certification Report (Proprietary)
Withheld Pursuant to 10 CFR 2.390