ML23258A233

Submission of Replacement Pages for Supplemental Responses to the Nuclear Regulatory Commissions (NRC) Request for Additional Information for the NAC International Magnastor Cask System, Amendment No. 13

ML23258A233
Person / Time
Site:	07201031
Issue date:	09/15/2023
From:	Baldner H NAC International
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
ED20230126
Download: ML23258A233 (1)

Text

ED20230126 Atlanta Corporate Headquarters 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com September 15, 2023 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Attn:

Document Control Desk

Subject:

Submission of Replacement Pages for Supplemental Responses to the Nuclear Regulatory Commission¶s (NRC) Request for Additional Information for the NAC International MAGNASTOR Cask System, Amendment No. 13 Docket No. 72-1031

References:

1. U.S. Nuclear Regulatory Commission (NRC) Certificate of Compliance (CoC)

No. 1031 for the NAC International MAGNASTOR Cask System, Amendment No. 9, December 7, 2020

2. MAGNASTOR Cask System Final Safety Analysis Report (FSAR),

Revision 12, NAC International, September 2021

3. ML060970083, Department of Energy, Idaho Operations Office, Notice of Issuance of Materials License SNM-2508 for TMI-2 Independent Spent Fuel Storage Installation, March 19, 1999

4. ML060970085, Safety Evaluation Report of Three Mile Island Unit 2 Independent Spent Fuel Storage Installation Safety Analysis Report, March 19, 1999

5. ML060970079, License for Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste, SNM-2508, Docket No. 72-20, U.S. DOE, March 19, 1999

6. NRC PDR 8808170310, Post-Defueling Monitored Storage Proposed License Amendment and Safety Analysis Report, GPU Nuclear Three Mile Island Nuclear Station Unit II, DPR 73 Docket No. 50-320, August 16, 1988

7. ML20059D154, Issuance of Amendment No. 48 for Possession Only License No.

DPR-73 for Three Mile Island Nuclear Station Unit 2, December 28, 1993

8. ML20011F536, GPU, Defueling Completion Report, Final Submittal, February 22, 1990

9. ML20090B852, NRC Letter Proposed Possession Only License, Proposed Technical Specifications and Supporting Safety Evaluation for Post Defueling Monitored Storage at Three Mile Island Unit 2, February 20, 1992

10. ED20220089, Submission of Data Disk for the NAC International MAGNASTOR Cask System, Amendment No. 13, July 13, 2022

11. ED20220069, Submission of an Amendment Request for the NAC International MAGNASTOR Cask System, Amendment No. 13, July 13, 2022

12. ED20220157, Supplement to the Submission of an Amendment Request for the NAC International MAGNASTOR Cask System, Amendment No. 13, October 13, 2022

ED20230126 Atlanta Corporate Headquarters 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com U.S. Nuclear Regulatory Commission September 15, 2023 Page 2 of 3

13. ED20220164, Supplement to the Submission of an Amendment Request for the NAC International MAGNASTOR Cask System, Amendment No. 13, November 17, 2022

14. ED20230028, Request to Withdraw Changes Associated with Administrative Controls for Short Duration Operations from NAC International MAGNASTOR Cask System, Amendment No. 13, March 8, 2023

15. U.S. Nuclear Regulatory Commission, Application for Amendment No. 13 to the Model No. MAGNASTOR Storage Cask Request for Additional Information, March 29, 2023

16. ED20230076, Submission of Responses to the Nuclear Regulatory Commission¶s (NRC) Request for Additional Information for the NAC International MAGNASTOR Cask System, Amendment No. 13, ED20230076

17. ED202300118, Submission of Supplemental Responses to the Nuclear Regulatory Commission¶s (NRC) Request for Additional Information for the NAC International MAGNASTOR Cask System, Amendment No. 13, August 17, 2023 NAC International (NAC) hereby submits replacement pages for our supplemental responses to the NRCs Request for Additional Information (RAI) (Reference 17). Inconsistencies were found in the RAI response and the FSAR changed, therefore the following replacement pages are being submitted to resolve these issues; RAI Response 3-3 (page 5 of 18); FSAR pages 2.4-8, 9.7-15, 9.7-16 and 9.7-17. The FSAR changed pages contained herein are common to both the Proprietary and Non-proprietary submittal packages.

In accordance with NAC¶s administrative practices, upon final acceptance of this application, submittals 22A, 22C, 22D, 23B, 23D and this supplement will be reformatted and incorporated into the next revision of the MAGNASTOR FSAR.

If you have any comments or questions, please contact me on my direct line at 678-328-1252.

Sincerely, Heath Baldner Director, Licensing

Enclosures:

+/- Replacement Pages for MAGNASTOR FSAR Amendment 13 RAI Response Supplement, Revision 23D

ED20230126 Replacement Pages for MAGNASTOR FSAR Amendment 13 RAI Response Supplement MAGNASTOR, Amendment 13 (Docket No 72-1031)

NAC International September 2023

MAGNASTOR System FSAR June 2023 Docket No. 72-1031 Revision 23B NAC International 2.4-8 Table 2.4-1 Safety Classification of MAGNASTOR Components (continued)

Component Description Reference Drawings Safety Function Safety Classification Concrete Cask Assembly Structural Weldments and Base Plate Lid Weldment Lifting Lugs Reinforcing Bars Concrete 71160-561 71160-562 71160-590 Structural, Shielding, Operations and Thermal B

Debris Material Container Assembly 71160-L201 Note(1)

NQ Segmented Tube Assembly 71160-L205 Note(1)

NQ FBM Waste Basket Liner 71160-L211 Shielding(2)

B Note 1: These items have non-structural functions and are not credited in the safety analysis.

Note 2: Lifting of the FBM Waste Basket Liner (WBL) is a non-safety related lift performed during loading operations. It is not structurally credited in the safety analysis; however, the WBL lift lugs are conservatively evaluated to the requirements of ANSI N-14.6 and NUREG-0612 for critical lift criteria. The thermal modeling does include the WBL in a conservative manner to report the WBL maximum temperature.

MAGNASTOR System FSAR June 2023 Docket No. 72-1031 Revision 23B NAC International 9.7-15

18. Close the shield doors using the hydraulic system and reinstall the lock pins into the shield door lock tabs.

19. Lift the MTC from the top of the concrete cask and return it to the cask preparation area for next loading sequence or to its designated storage location.

20. Disconnect hydraulic supply system from the transfer adapter hydraulic cylinders.

21. Loosen and remove the six bolts securing the TSC adapter assembly to the FBM TSC closure lid. Using the designated sling sets, remove from the top of the FBM TSC and store properly.

22. Verify all equipment and tools have been removed from the top of the FBM TSC and transfer adapter.

23. Connect the transfer adapter four-legged sling set to the crane hook and lift the transfer adapter off the concrete cask. Place the transfer adapter in its designated storage location and remove the slings from the crane hook.

24. Using the on-site heavy haul vehicle, remove the concrete cask using the designated conveyance from the FBM TSC transfer station location to permit installation of the concrete cask upper segment.

25. Attach the concrete cask upper segment lift rig. Connect the slings to the overhead crane.

26. Perform visual inspection of the top of the concrete cask and verify all equipment and tools have been removed.

Note: Take care to minimize personnel access to the top of the unshielded loaded concrete cask due to radiation streaming from the FBM TSC.

27. Lift the concrete cask upper segment and move it into position over the concrete cask, ensuring proper alignment.

28. Lower the concrete cask upper segment into position and remove the rig set from the concrete cask upper segment

29. Install four of the concrete cask upper segment bolts and tighten to the torque specified in Table 9.1-2.

30. Perform radiation surveys of the top and sides of the concrete cask. Confirm dose rates are within allowable values.

31. Using the vertical cask transporter lift fixture or device, position the two concrete cask lifting lugs on the concrete cask.

32. Install the lift lug bolts (2 per lift lug) and into the threaded holes in the embedment base.

Torque each of the lug bolts to the value specified in Table 9.1-2.

33. Proceed to Section 9.7.4.

MAGNASTOR System FSAR June 2023 Docket No. 72-1031 Revision 23B NAC International 9.7-16 9.7.4 Transporting and Placing the Loaded Concrete Cask The section describes the general procedures for moving a loaded concrete cask to the ISFSI pad using the vertical cask transporter.

Vertical Cask Transporter

1. Using the cask transporter, lift the loaded concrete cask and move it to the ISFSI pad following the approved onsite transport route.

Note: Ensure vertical cask transporter lifts the concrete cask evenly using the two lifting lugs.

Note: Do not exceed the maximum lift height for a loaded concrete cask of 24 inches, per Section 4.3.1.h. of the Technical Specifications.

2. Move the concrete cask into position over its intended ISFSI pad storage location. Ensure the surface under the concrete cask is free of foreign objects and debris.

3. Using the vertical transporter, slowly lower the concrete cask into position.

4. Loosen and remove the two lift lug bolts from each lifting lug, raise the lift lugs from the top of the concrete cask and move the cask transporter from the area.

5. Install the remaining four concrete cask upper segment bolts into the threaded holes. Torque each bolt to the value specified in Table 9.1-2.

6. For the casks with extensions containing anchor cavities, install the weather seal and cover plates. Install the bolts and washers and torque to the value specified in Table 9.1-2.

7. Install inlet screens to prevent access by debris and small animals.

Note: Screens may be installed on the concrete cask prior to FBM TSC loading to minimize operations personnel exposure.

8. Scribe and/or stamp the concrete cask nameplate, if not already done, with the required information at a minimum.

9. Perform a radiological survey of the concrete cask within the ISFSI array to confirm dose rates comply with ISFSI administrative boundary and site boundary dose limits.

9.7.5 Removing the Loaded FBM TSC from a Concrete Cask Using a Standard MTC This procedure assumes the loaded concrete cask is returned to the reactor loading facility for unloading. However, transfer of the FBM TSC to another concrete cask can be performed at the ISFSI without the need to return to the loading facility, provided a cask transfer facility that meets the requirements specified in the Technical Specifications is available.

As the steps to move a loaded concrete cask are essentially the reverse of the procedures in Section 9.7.3 and Section 9.7.4, the procedural steps are only summarized here.

MAGNASTOR System FSAR June 2023 Docket No. 72-1031 Revision 23B NAC International 9.7-17

1. Remove concrete cask inlet screens.

Note: The minimum ambient air temperature (either in the facility or external air temperature, as applicable for the handling sequence) must be > 0ºF for the use of the concrete cask, per Section 4.3.1.g. of the Technical Specifications.

Remove four of the concrete cask upper segment bolts, and install the lift lugs. Torque the lift lug bolts for each lift lug to the value specified in Table 9.1-2. Attach the concrete cask to the vertical cask transporter.

2. Move the loaded concrete cask to the facility.

3. Remove the concrete cask upper segment.

4. Install the TSC adapter assembly using the six bolts inserted into the canister closure lid threaded holes. Torque the bolts to the prescribed value,

5. Install transfer adapter on top of the concrete cask.

6. Place MTC onto the transfer adapter and engage the shield door connectors.

7. Note: The minimum ambient air temperature (either in the facility or external air temperature, as applicable for the handling sequence) must be > 0ºF for the use of the carbon steel MTC, per Section 4.3.1.f. of the Technical Specifications (not applicable to stainless steel MTCs).

8. Open the shield doors, retrieve the lifting slings, and install the slings on the lifting system.

9. Slowly withdraw the FBM TSC from the concrete cask. The chamfer on the underside of the transfer adapter assists in the alignment into the MTC.

10. Bring the FBM TSC up to just below the retaining blocks (MTC1/MTC2) or the retaining ring (MTC2). Close the MTC shield doors and install the shield door lock pins.

11. Lift MTC off the concrete cask and move to the designated workstation.

12. After the MTC with the loaded FBM TSC is in, or adjacent to, the facility, the operational sequence to load the FBM TSC into another concrete cask is performed in accordance with the procedures in Section 9.7.3.

9.7.6 Wet Unloading a FBM TSC Using a Standard MTC This section provides the basic operational sequence to prepare, open, and unload a FBM TSC in a designated loading area. Due to the rugged design and fabrication of the FBM TSC, users are not expected to perform this operational sequence. However, in accordance with the Technical Specifications, each user shall have the procedures and required equipment available, and perform a dry run of the unloading process.

The procedure that follows assumes that the FBM TSC is in a MTC in the appropriate workstation.