ML18065A362

Acceptance Review of Tn Americas LLC Application for Amendment No. 4 to Certificate of Compliance No. 1029 - Response to Request for Supplemental Information (Docket 72-1029)

ML18065A362
Person / Time
Site:	07201029
Issue date:	02/22/2018
From:	Bondre J TN Americas LLC
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
E-50760, EPID L-2017-LLA-0390
Download: ML18065A362 (17)

Text

() orano Columbia Office 7135 Minstrel Way Columbia, MD 21045 Tel: (410) 910-6900 @Orano_USA U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 February 22, 2018 E-50760 Subject: Acceptance Review of TN Americas LLC Application for Amendment No. 4 to Certificate of Compliance No. 1029 -Response to Request for Supplemental Information (Docket 72-1029) Reference: Letter from Chris Allen (NRC) to Jayant Bondre (TN Americas LLC), "Application For Amendment No. 4 To Certificate Of Compliance No. 1029 -Supplemental Information Needed," dated January 24, 2018, Docket No. 72-1029, EPID No. L-2017-LLA-0390 This submittal provides responses to the Request for Supplemental Information (RSI) forwarded by the letter referenced above. Enclosure 2 herein provides a proprietary version of the response to the RSI items. Enclosure 11 provides a public version of the response to the RSI items. Each RSI response has a section stating the impact of the RSI response on the application, indicating which sections, tables, etc., of the updated final safety analysis report (UFSAR), have been changed. Enclosure 3 provides a list of changed UFSAR pages. Enclosure 4 provides the UFSAR changed pages associated with this Amendment 4 Application, Revision 1. A public version of this enclosure is provided in Enclosure 5. The footers of the changed Amendment 4 UFSAR pages are annotated as 72-1029 Amendment No. 4, February 2018, Revision 1. UFSAR changes are tracked and indicated by revision bars and italicized text. The new changes, associated with the RSI responses and additional changes herein, are further annotated with rectangles enclosing the changed areas and an indication of which RSI or additional change is associated with the changes. Enclosures 6 through 8 provide calculations associated with the RSI responses. A listing of the computer files associated with the RSI responses is provided in Enclosure 9. Enclosure 10 contains computer files associated with this submittal. Certain portions of this submittal include proprietary information, which may not be used for any purpose other than to support the NRC staffs review of the applicatio Document Control Desk February 23, 2018 E-50760 Page 2 of 2 In accordance with 10 CFR 2.390, TN Americas LLC is providing an affidavit (Enclosure 1), specifically requesting that this proprietary information be withheld from public disclosure. With the exception of Enclosures 6, 7, 8 and 10, public versions of portions containing proprietary and/or security-related information are provided. Should NRC staff have any questions or require additional information to support the review of this application, please contact Mr. Dennis Williford by telephone at (704) 805-2223, or by email at Dennnis.Williford@areva.com.

Sincerely,Jayant Bondre Chief Technical Officer cc: Chris Allen (NRC SFM) as follows, all provided in a separate mailing:

• One paper copy of this cover letter

• Six computer disks, each containing this cover letter and Enclosures 1 through 11

Enclosures:

1. Affidavit Pursuant to 10 CFR 2.390 2. RSls and Responses (Proprietary Version) 3. List of Changed UFSAR Pages Involved in CoC 1029 Amendment 4, Revision 1 4. CoC 1029 Amendment 4 Application, Revision 1 UFSAR Changed Pages (Proprietary) 5. Public Version of CoC 1029 Amendment 4 Application, Revision 1 UFSAR Changed Pages 6. Calculation 503821-0500 Revision O (Proprietary) 7. Calculation SCE-01.0502 Revision 2 (Proprietary) 8. Calculation SCE-23.0502 Revision O (Proprietary) 9. Listing of Computer Files Contained in Enclosure 10 10. Certain Computer Files Associated with RSI Responses (Proprietary) 11. RSls and Responses (Public Version)

TN Americas LLC State of Maryland County of Howard ) ss. ) AFFIDAVIT PURSUANT TO 10 CFR 2.390 Enclosure 1 to E-50760 I, Jayant Bondre, depose and say that I am Chief Technology 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 Commission's regulations for withholding this information. The information for which proprietary treatment is sought is contained in Enclosures 2, 4, 6, 7, 8, and 10, as listed below:

• Enclosure 2 -Portions of certain Request for Supplemental Information (RSI) Responses

• Enclosure 4 -Portions of certain updated final safety analysis report (UFSAR) chapters and drawings

• Enclosure 6, 7, and 8 -Calculations associated with the RSI Responses

• Enclosure IO -Certain computer files associated with CoC I 029 Amendment 4 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 Commission's 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 in the RSI responses, portions of the UFSAR, calculations, and computer files, all related to the design of the Standardized Advanced NUHOMS 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 analysis 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 product's position or impair the position of TN Americas LLC's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus. Further the deponent sayeth not. Jayant Bondre Chief Technology Officer, TN Americas LLC Subscribed and sworn before me this 22nd day of February, 2018. Notary Public My Commission Expires_!}_; __J;}_; Page I of I LESLIE LEFORS Notary Public-Maryland Frederick County My Commission Expires September 29, 2021

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• Enclosure 3 to E-50760 List of Changed UFSAR Pages Involved in CoC 1029 Amendment 4, Revision 1

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• Enclosure 3 to E-50760 List of Changed UFSAR Pages Involved in CoC 1029 Amendment 4 Application, Revision 1 Page Number, Description, or Series UFSARPages 5.1-3 A.4.11-8 A.5.1-5 Page 1 of 1

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• L -Enclosure 5 to E-50760 Public Version of CoC 1029 Amendment 4 Application, Revision 1 UFSAR Changed Pages

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• Advanced NUHOMS System Final Safety Analysis Report Rev. 0, 2/03 Surface Rear(1> Front§J Roof Side<1> Table 5.1-2 Summary AHSM Dose Rates Dose Rate Maximum Dose Minimum Dose Component Rate, mrem/hr Rate, mrem/hr Gamma 0.11 1.06E-04 Neutron 0.01 3.04E-06 Gamma 45.27 1.59E-02 Neutron 0.54 6.99E-04 Gamma 3.57 3.57E-04 Neutron 0.05 2.37E-05 Gamma 1.35 5.13E-06 Neutron 0.03 4.61E-08 (1) Rear and side does rates are on the outer surfaces of the shield walls. Average Surface Dose Rate(2>, mrem/hr 4.06E-03 3.70E-04 1.89 0.04 0.03 8.56E-04 0.26 0.01 (2) These dose rates are bounding for 1 meter occupational exposures during transfer operations. (3) The maximum dose rates on the front surface are based on the results calculated in front of the entrance of the bottom air inlet. Around the door centerline (between 152 cm to 394 cm above the ground) has maximum dose rate 4.04 mremlhr (gamma dose rate 3.97 mremlhr and neutron dose rate 0.07 mremlhr) . February 2018 Revision 1 72-1029 Amendment No. 4 All indicated changes are in response to RSI 5-1 5.1-3 I

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• Advanced NUHOM~ System Updated Final Safety Analysis Report February 2018 Revision 1 Proprietary Information on This Page Withheld Pursuant to 10 CFR 2.390 72-1029 Amendment No. 4 All indicated changes are in response to OBS 4-1 Rev. TED, TBDITBD I A.4.11-8 I

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• Updated Advanced NUHOMS System Final Safety Analysis Report Table A.5.1-2 Summary of AHSM Dose Rates Dose Rate Dose Rate (mrem/hr) Rev. 2, 08/06 Surface Component Maximum Average Gamma 143.881 +/- 15.5%(*) Rear End of the Neutron 0.207 +/- 4.3% N/A TSBA(bJ Total 144.088 +/- 15.5% Gamma 1.115 +/- 4.2% 0.085 +/- 3.3% Back of the Rear Neutron 0.008 +/- 1.4% l.05E-3 +/- 1.6% Shield WalfbJ Total 1.123 +/- 4.1% 0.086 +/- 3.3% Gamma 44.318 +/- 5.3% 2.154 +/- 2.9% Front(cJ Neutron 0.838 +/- 1.1% 0.138 +/- 7.7% Total 45.156 +/- 5.2% 2.292 +/- 2.8% Gamma 149.298 +/- 4.5% 0.011 +/- 2.7% RoofidJ Neutron 0.279 +/- 1.6% 0.001 +/- 7.5% Total 149.577 + 4.5% 0.012 + 2.6% Gamma 6.657 +/- 6.8% 0.474 +/- 5.6% AHSMTop<*J Neutron 0.016 +/- 1.8% l.56E-3 +/- 1.5% Total 6.673 +/- 6.8% 0.476 +/- 5.6% Gamma 1.790 +/- 3.3% 0.309 +/- 2.0% Side Neutron 0.074 +/- 3.6% l.06E-3 +/- 1.4% Total 1.865 +/- 3.1% 0.319 +/- 1.9% (a) Statistical one standard deviation uncertainty in the Monte Carlo calculation . (b) The maximum gamma dose rates on the rear concrete surface (of"top" model) but below the roof elevation are less than 0.2 mrem/hr and the maximum gamma dose rates on this surface above the roof level are about 1.12 mrem/hr; i.e., the dose rate above the roof drops off very rapidly with distance in x from the vent (note the dose rate near the edge of the vent is 144.1 mrern/hr). (c) These maximum dose rates on the front oft~.c...Li=ll.Jlw.....wi.>.i..1.1...1.U.JL...IJ.llii....Ll""'-lolU,.L.::,...l..Q,.U...U..LQJ,J...U..~LIJJL........, front of the entrance of the bottom air inlet. The maximum dose rate around the door is 4.453 mrem/hr (gamma dose rate 3.909 mrem/hr and neutron dose rate 0.544 mrem!h,) from the "top" MCNP model as shown in Figure A.5.4-3. (d) The dose rates are calculated on top of the AHSM roof. The maximum dose rates on the roof are based on the dose rates just at the roof vent opening. Knowing dose rates just above the roof vent opening is important, since this area must be accessed to clean the vent screens, if debris accumulates on the screens. For dose rates in front of the Top Shield Block Assembly (TSBA), the "Roof' maximum dose rate is below 1.0 mrem/hr. The average dose rates are calculated over the roof segment in front of the TSBA (before its -x side). (e) The dose rates are calculated on the plane enveloping the AHSM from the top. The average dose rate is calculated over the entire plane enveloping the AHSM from the top. This dose rate is used for the site dose rate analysis. The location of the maximum dose rate is near the rear end of the TSBA (its +x side, the side facing rear of the AHSM). Note: Gamma results include the dose rates from gammas produced from neutrons in the neutron calculation. These partial gamma dose rates and the neutron dose rates have been multiplied by [1/( J-k)=l/(1-0.45)=1.82] to conservatively include neutron multiplication from induced fissions in the source region containing damaged fuel rods. Note: The averaged dose rates are calculated over the planes enveloping the AHSM geometry, while peak dose rates are for localized areas. The average dose rates are needed for the site dose rate analysis. February 2018 Revision 1 72-1029 Amendment No. 4 All indicated changes are in response to RSI 5-1 A.5.1-5

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• Enclosure 11 to E-50760 RSls and Responses (Public Version)

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• RSls and Responses Enclosure 11 to E-50760 RSI 4-1 Provide the following maximum temperatures, or provide justification showing that it is unnecessary to report the following maximum temperatures: dry shielded canister (DSC) spacer disc, DSC guidesleeve or failed fuel can, DSC oversleeve, DSC support rod/spacer sleeve, DSC Boral sheet, and peak cladding temperatures. The maximum temperatures for the following components were previously provided for the off-normal analysis in Table A.4.1-2 and for the accident analysis in Table A.4.1-3 respectively of the updated final safety analysis report (UFSAR): dry shielded canister (DSC) spacer disc, DSC guidesleeve or failed fuel can, DSC oversleeve, DSC support rod/spacer sleeve, DSC Bora I sheet, and peak cladding temperature. However, Tables A.4.11.2-4 and A.4.11.2-5 of the application do not identify the maximum temperatures under off-normal and accident conditions respectively for these components. In addition, the applicant has not provided information demonstrating that these maximum temperatures are either irrelevant (e.g., the components are not used in the 24PT 4 DSC), or the previously provided temperatures bound the temperatures associated with the current amendment. If the thermal models are updated in order to provide these maximum temperatures, the updated thermal models should also be provided. This information is needed to determine compliance with 10 CFR 72.236(f). RESPONSE TO RSI 4-1 : The maximum temperatures for the various components within the 24PT4 DSC are reported in UFSAR Table A.4.1-2 and Table A.4.1-3 for off-normal and accident conditions, respectively. For off-normal conditions, the thermal model of the 24PT 4 DSC utilized to evaluate these temperatures does not include the advanced horizontal storage module (AHSM), as described in Section A.4.4.4. Instead, the DSC shell temperatures obtained from the AHSM model are applied as boundary conditions on the 24PT 4 DSC thermal model to obtain the DSC component temperatures, as mentioned in Section A.4.4.4.1. For accident conditions, the maximum temperatures listed in Table A.4.1-3 for the 24PT 4 DSC are based on a comparison of the differences in the maximum DSC shell temperatures between the various models, as described in Section A.4.6.2.2. Table A.4.11.2-4 and Table A.4.11.2-5 show that the maximum temperatures for the DSC shell during off-normal conditions and blocked vent accident conditions are bounded by the design basis analysis. The DSC shell temperatures are lower than the design basis analysis by 74 °F and by 177 °F for off-normal and blocked vent accident conditions, respectively. Therefore, it is concluded that the DSC component temperatures presented in Table A.4.1-2 and Table A.4.1-3 are bounding and still applicable for the 24PT 4 DSC. Application Impact: No changes as a result of this RSI. Page 1 of 6

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• RSls and Responses Enclosure 11 to E-50760 RSI 4-2 Provide analyses, safety analysis report text or other information which shows how credit for the installed temperature monitoring system specified in TS 5.2.5(b) and (c) can be used for the 24PT1 DSC. The analysis in Section A.4.11.2 of the application is for the 24PT 4 DSC, and it is unclear how this analysis applies to the 24PT1 DSC. Also, while the applicant provided analytical results for the 24PT1-DSC in Table 4.4-12, "Technical Specifications 5.2.5.b Temperature Monitoring Limits for the 24PT1-DSC," the applicant did not provide the analysis to support the information presented in Table 4.4.-12. In addition, the brief paragraph on monitoring advanced horizontal storage module (AHSM) temperatures provided in UFSAR Section 4.4.2.5, "Monitoring of AHSM Temperature" does not discuss the 24PT1 DSC. The safety analysis report text that discusses the analysis supporting the use of the installed temperature monitoring system for the 24PT1 DSC, or if necessary any supporting analyses, should be provided to clearly identify how credit for the installed temperature monitoring system specified in TS 5.2.5(b) can be used for the 24PT1 DSC. This information is needed to determine compliance with 10 CFR 72.236(f). RESPONSE TO RSI 4-2: Temperature monitoring for the 24PT1 DSC was previously approved in TS 5.2.5 of Amendment O of Certificate of Compliance No. 1029, and no changes are requested regarding this option in this license amendment request. No additional information on temperature monitoring for the 24PT1 DSC has been provided since this was approved by the U.S. Nuclear Regulatory Commission (NRC). In addition, it should also be noted that the thermal evaluation presented for the 24PT4 DSC in Updated Final Safety Analysis Report (UFSAR) Section A.4.11.2 is not credited for the 24PT1 DSC. As identified in the RSI question, UFSAR Section 4.4.2.5, along with Table 4.4-12, provide a discussion of the temperature monitoring for the 24PT1 DSC. The information presented in Section 4.4.2.5 and Table 4.4-12 is based on the thermal evaluation of the AHSM presented in Section 4.4.2 for off-normal conditions and Section 4.6.2 for accident blocked vent conditions. The only change requested in this amendment is to remove the requirement for the visual inspection when temperature monitoring is also being performed, and vice-versa. This change provides consistency between the 24PT1 DSC and 24PT4 DSC in TS 5.2.5 (c). It is also consistent with other NUHOMS systems wherein the users need to perform either the visual inspection or the temperature monitoring, but not both. Application Impact: No changes as a result of this RSI. Page 2 of 6

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• RSls and Responses Enclosure 11 to E-50760 RSI 5-1 Provide calculations, computer input files or other information which justify adding the proposed dose rates to the technical specifications. The applicant proposed dose rate limits of 50 mrem/hr on the AHSM front inlet bird screen and 10 mrem/hr on the AHSM door outside surface. However, the applicant did not provide information justifying that these dose rates limits are adequate. The applicant should provide all calculations and computer input files which substantiate implementing the proposed dose rate limits. This information is necessary for the staff to evaluate compliance with 10 CFR 72.236(d) . Page 3 of 6 RSls and Responses Enclosure 11 to E-50760

• RESPONSE TO RSI 5-1: *

• The proposed dose rate limits on the advanced horizontal storage module (AHSM) front inlet bird screen and on the AHSM door outside surface are based on shielding analysis results presented in Updated Final Safety Analysis Report (UFSAR) Table 5.1-2 for the 24PT1 dry shielded canister (DSC), and UFSAR Table A.5.1-2 for the 24PT4 DSC. The shielding analysis results for the AHSM door outside surface have been added to UFSAR Table 5.1-2 for the 24PT1 DSC, and UFSAR Table A.5.1-2 for the 24PT4 DSC. The dose rate results shown in UFSAR Tables 5.1-2 and A.5.1-2 indicate that the proposed limits are adequate. The proposed dose rate limit of 50 mrem/hr on the AHSM front inlet bird screen is based on [ ] for the 24PT1 DSC ,and [ ] for the 24PT 4 DSC. For the 24PT1 DSC, the dose rate reported in Table 5.1-2 of the UFSAR is obtained from [ ]. For the 24PT4 DSC, the dose rate reported in Table A.5.1-2 of the UFSAR is obtained from [ ]. The proposed dose rate limit of 10 mrem/hr on the AHSM door outside surface is based on [ ] for the 24PT1 DSC and [ ] for the 24PT4 DSC. For the 24PT1 DSC, the dose rate added to Table 5.1-2 of the UFSAR is obtained from [ ]. For the 24PT4 DSC, the dose rate added to Table A.5.1-2 of the UFSAR is obtained from [ ]. [ ] was prepared to summarize the above information to support the proposed dose rate limits of 50 mrem/hr on the AHSM front inlet bird screen, and 10 mrem/hr on the AHSM door outside surface. [ ] are provided in Enclosures 6 through 8 of this submittal. Computer input files associated with these calculations are provided in Enclosure 10, with a summary listing of these files provided in Enclosure 9. Application Impact: UFSAR Table 5.1-2 and Table A.5.1-2 have been revised as described in the response . Page 4 of 6 RSls and Responses Enclosure 11 to E-50760

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• Provide analyses, safety analysis report text or other information which demonstrates that the boundary conditions described in the application and the boundary conditions applied to the thermal model ensure bounding results for either a single or double module AHSM. Table A.4.11.2-1, "AHSM lnsolation," of the application states insolation is applied only to the AHSM roof and front wall. However, the application does not show how this modeling assumption is conservative for a single module AHSM where insolation should be applied to the AHSM back wall. In addition, Section A.4.11.2.3.3, "CFO Modeling," part D., "Specific Operating, Initial and Boundary Conditions -External Boundary Condition," of the application states radiation and free convection is applied to all exterior surfaces of the AHSM. However, the application does not show how these modeling assumptions are conservative for a double module AHSM where the back wall boundary conditions from the first AHSM should be applied to the second AHSM back wall. The applicant needs to provide either analyses, safety analysis report text, or both which demonstrates that the boundary conditions chosen provide bounding temperatures. If the thermal models are updated, the updated thermal models should also be provided. This information is needed to determine compliance with 10 CFR 72.236(1). RESPONSE TO OBS 4-1: Updated Final Safety Analysis Report (UFSAR) Section A.4.11.2.3.3 (D) has been revised to clarify the boundary conditions that were applied on the external walls of the advanced horizontal storage module (AHSM). Adiabatic boundary conditions were applied to the back of the AHSM thermal model. Figure OBS 4-1-1 below also shows the exterior boundary conditions that were applied to the AHSM walls. Applying adiabatic boundary conditions is conservative when there are back-to-back arrays of the AHSM since there is no heat transfer considered through the rear wall. In the case of the single-module array, a three-foot thick concrete rear shield wall is installed at the back of the AHSM, as mentioned in Sections 1.2.1.2 and 3.1.1.2 of the UFSAR. This effectively eliminates the insolation at the back wall. Application Impact: UFSAR Section A.4.11.2.3.3 (D) has been revised as described in the response . Page 5 of 6

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• RSls and Responses Enclosure 11 to E-50760 Note: Green -Adiabatic Boundary Conditions; Blue -Convection, Radiation and insolation Boundary Conditions; Cyan -Inlet Vent; Yellow -Outlet Vent. Figure OBS 4-1-1 Exterior Boundary Conditions Applied to the AHSM Walls Page 6 of 6 0 orono TN Americas LLC (formerly AREY A TN Americas, an operating division of AREVA Inc.) Acceptance Review of TN Americas LLC Application for Amendment No. 4 to Certificate of Compliance No. 1029 -Response to Request for Supplemental Information (Docket 72-1029) February 2018