ML23047A028

Supplemental Response to Request for Additional Information - Application for Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 4 (Docket No. 72-1004, CAC No. 001028, EPID: L-2022-

ML23047A028
Person / Time
Site:	07201004
Issue date:	02/16/2023
From:	Narayanan P Orano TN Americas, TN Americas LLC
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
E-62087, EPID L-2022-LLA-0079), CAC 001028
Download: ML23047A028 (1)

Text

February 16, 2023 E-62087 U. S. Nuclear Regulatory Commission Columbia Office 7160 Riverwood Drive Attn: Document Control Desk Columbia, MD 21046 One White Flint North Tel: (410) 910-6900 11555 Rockville Pike

@Orano_USA Rockville, MD 20852

Subject:

Supplemental Response to Request for Additional Information -

Application for Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 4 (Docket No. 72-1004, CAC No. 001028, EPID: L-2022-LLA-0079)

Reference:

[1] E-61864, Response to Request for Additional Information -

Application for Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 2 (Docket No. 72-1004, CAC No. 001028, EPID: L-2022-LLA-0079),

dated January 20, 2023 TN Americas LLC (TN) hereby submits a supplement to Reference [1], above, that provides additional clarifying information in support of TNs use of blended Portland cement meeting the requirements of ASTM C595.

The NRC and TN held a clarification call on February 10, 2023 for the purpose of clarifying TNs UFSAR changes associated with the use of blended Portland cement that correlates to an additional scope item not related to the RAIs as identified in Reference [1].

Enclosure 1 provides a description of the Amendment 18, Revision 4 changes.

Enclosure 2 provides the UFSAR changed pages associated with Revision 4 to the application for Amendment 18. The changed pages include a footer annotated as 72-1004 Amendment 18, Revision 4, February 2023, with changes indicated by italicized text and revision bars. The changes are further annotated with gray shading or a gray box enclosing an added section, as well as a footer to distinguish the Amendment 18, Revision 4 changes from previous Amendment 18 changes.

Should you have any questions regarding this submittal, please do not hesitate to contact Mr. Douglas Yates at 434-832-3101 or me at 410-910-6859.

Sincerely, Prakash Narayanan Chief Technical Officer

Document Control Desk E-62087 Page 2 of 2 cc: Chris Allen (NRC), Project Manager, Storage and Transportation Licensing Branch Division of Fuel Management

Enclosures:

1. Description of Amendment 18, Revision 4 Changes

2. Proposed Amendment 18, Revision 4 Changes to the Standardized NUHOMS System Updated Final Safety Analysis Report

Enclosure 1 to E-62087 DESCRIPTION OF AMENDMENT 18, REVISION 4 CHANGES INTRODUCTION Certain UFSAR pages that support Amendment 18 to the Standardized NUHOMS Certificate of Compliance (CoC) No. 1004 have been modified as described below.

Change No. 1:

Based on the recent clarification call between TN Americas LLC (TN) and the NRC concerning the use of a blended Portland-Limestone cement certified to the requirements of ASTM C595, the following UFSAR changed pages are provided in this submittal to improve information clarity.

Changes have been made to UFSAR Page 4.2-7 to delete the sentence, This applies to all HSM models including HSM-H and HSM-HS unless testing is performed. UFSAR page P.4-25 has been revised to clarify language and improve readability in Section P.4.4.8 with respect to elevated temperature testing.

Change No. 2:

UFSAR Page 4.10-1 has been revised to remove the code year from the newly added reference for ASTM C595. This additional change was not mentioned in the clarification call. This minor edit is necessary because, with respect to ASTM testing and material standards, TN typically uses the latest edition as material suppliers certify their materials to the latest edition. Similarly, testing labs would perform testing to the latest edition of the ASTM. Lastly, active ASTMs are revised frequently with input from the industry.

Page 1 of 1

Enclosure 2 to E-62087 Proposed Amendment 18, Revision 4 Changes to the Standardized NUHOMS System Updated Final Safety Analysis Report

During DSC insertion/withdrawal operations, the transfer cask is docked with the HSM docking flange and mechanically secured to embedments provided in the front wall of the HSM. The cask restraints used for this purpose are shown in Figure 4.2-13. The embedments are equally spaced on either side of the HSM access opening. The HSM embedments are designed in accordance with the requirements of ACI 349 Code (4.14).

The transfer cask restraint system is designed for loads which occur during normal DSC transfer operations and during an off-normal jammed DSC event.

The HSM gap between modules is covered with stainless steel wire bird screen to prevent pests or foreign material from entering the HSM. Periodic surveillance constitutes the only required maintenance activity for the NUHOMS ISFSI.

It is expected that during the installation and loading of an HSM array there will be empty modules. Vacant HSMs can occur due to: partial filling of a complete construction phase of HSMs, or a partial filling of a phase of HSMs which will be expanded at a future date. The following issues have been evaluated for both cases:

Normal Operation Issues, Construction Issues, and Accident Condition Issues. During installation of an additional HSM(s), or for other reasons, shield wall(s) may be removed for a period of time. However, compensatory measures shall be considered for radiation shielding and for missile protection, if necessary.

The design flexibility of the HSMs permits a licensee to choose the most economical arrangement of HSMs which best meets plant specific conditions and requirements. This SAR presents a detailed analysis for a single stand-alone module as this is the governing design case for the postulated environmental loads such as earthquake, flooding, and tornado loads. Thermal loads also provide significant loadings for the HSM structural design for the free-standing prefabricated HSM.

A typical reinforcing steel layout for the HSM floor, walls, and roof is shown in Figure 8.1-19. The reinforcement sizing and placement specified is used for HSM array configurations ranging in size from a single stand alone module to a 2x10 array of HSMs or larger. Licensing details, such as concrete joint and reinforcing bar lap splice requirements, are shown on the Appendix E drawings.

The HSM design documented in this SAR is constructed of 5,000 psi (minimum) compressive strength, normal weight (145 pounds per cubic foot minimum density) concrete with Type II Portland cement meeting the requirements of ASTM C150 (4.6) or blended Portland cement meeting the requirements of ASTM C595 [4.8]. Type III cement may be used as long as it meets the chemical and physical requirements for Type II cement specified in ASTM C150. The concrete aggregate meets the specifications of ASTM C33 (4.6). The concrete is reinforced by ASTM A615 or A706 Grade 60 (4.7) deformed bars placed vertically and horizontally at each face of the walls, roof and floor.

February 2023 Revision 4 72-1004 Amendment No. 18 Page 4.2-7 All indicated changes on this page are for Enclosure1 Item 1

4.10 References 4.1 U.S. Government, Licensing Requirements for the Storage of Spent Fuel in an Independent Spent Fuel Storage Installation (ISFSI), Title 10 Code of Federal Regulations, Part 72, Office of the Federal Register, Washington, D.C.

4.2 Deleted.

4.3 Deleted.

4.4 Deleted.

4.5 American Society of Mechanical Engineers, ASME Boiler and Pressure Vessel Code,Section III, Division 1, 1983 Edition, with Winter 1985 Addenda.

4.6 American Society for Testing and Materials, Annual Book of ASTM Standards, Section 4, Volume 04.02, 1990.

4.7 American Society for Testing and Materials, Annual Book of ASTM Standards, Section 1, Volume 01.04, 1990.

4.8 ASTM International, C595/C595M, Standard Specification for Blended Hydraulic Cements.

4.9 American National Standard for Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds (4500 kg) or More for Nuclear Materials, ANSI N14.6-1993, American National Standards Institute, Inc., New York, New York.

4.10 American Concrete Institute, Building Code Requirement for Reinforced Concrete, ACI-318, 1983.

4.11 American Institute of Steel Construction, (AISC), Specification for Structural Steel Buildings, Ninth Edition 1989, Chicago, Illinois.

4.12 American National Standards Institute, American National Standard for Radioactive Materials - Leakage Tests on Packages for Shipment, ANSI N14.5, 1977.

February 2023 Revision 4 72-1004 Amendment No. 18 Page 4.10-1 All indicated changes on this page are for Enclosure1 Item 2

P.4.4.7 HSM-H Thermal Model Results P.4.4.7.1 Normal and Off-normal Operating Condition Results Temperature distributions for the normal and off-normal cases are shown in Figure P.4-6 through Figure P.4-13. The maximum component temperatures for the normal and off-normal cases are listed in Table P.4-2, Table P.4-3, and Table P.4-4. Temperature distributions for the single HSM-H which provides maximum temperature gradients in concrete walls, are shown in Figure P.4-16. Note that Figure P.4-16 shows the analysis temperature distribution before any adjustments made based on the results for bounding Case 1 documented in Table P.4-2. As seen from Table P.4-2 and Table P.4-3, the HSM-H concrete and DSC shell temperatures without the fins on the side heat shield for 31.2 kW are bounded by the case with the fins for 40.8 kW decay heat load. Therefore, fins are not required on the side heat shields in the HSM-H, if the total heat load is 31.2 kW or less. This is summarized in Table P.4-43.

P.4.4.7.2 Accident Condition Results Temperature distributions for the blocked vent accident case with 40.8 kW decay heat load at 38.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after blockage of the vents are shown in Figure P.4-14. The maximum component temperatures for the blocked vent accident case are listed in Table P.4-5.

Figure P.4-15 shows the time-temperature history of HSM-H components for this transient.

The maximum component temperatures for these cases are listed in Table P.4-6. Figure P.4-17 provides maximum temperature gradients in concrete walls during accident conditions. Table P.4-5 and Table P.4-6 incorporate the adjustments made to the analytical results as described in P.4.4.8 based on the thermal tests of the HSM-H [4.48]. Note that Figure P.4-14, Figure P.4-15 and Figure P.4-17 show the analysis temperature distributions, before any adjustments made based on the results for bounding Case 1 documented in Table P.4-2.

P.4.4.8 Evaluation of HSM-H Performance The thermal performance of the HSM-H is evaluated under normal, off-normal, and accident conditions of operation as described above and is shown to satisfy all the temperature limits and criteria. The DSC shell temperatures calculated here, are used in the DSC basket and fuel cladding models as a boundary condition in Section P.4.6. The results show that all the basket and fuel cladding material temperature limits are satisfied. The results of the HSM-H temperatures are used in Section P.3 toshow that thermal stresses in the HSM-H are also within these allowables.

The results of the 117 °F ambient blocked vent condition show that the maximum concrete temperature at the end of 38.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (with finned side heat shields, louvered top heat shield, and with slots on plate on top of support rail) and 30.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> (with flat stainless steel heat shields and without slots on plate on top of support rail) in the blocked vent accident are 431 °F and 415 °F, respectively. These are above the 350

°F limit given in NUREG 1536 [4.42] for accident conditions. To account for the effect of these higher concrete temperatures on the concrete compressive strengths, the structural analysis of HSM-H concrete components in Section P.3 is based on 10% reduction in concrete material properties. Elevated temperature testing of the concrete mix (cement type, additives, water-cement ratio, aggregates, proportions) is performed to ensure that the required strength is maintained. Portland cements meeting the requirements of ASTM C 150 or ASTM C595 (blended Portland cement) are acceptable for use. The use of any Portland cement concretes will require testing to be performed since the concrete accident temperature exceeds 350 °F. Testing will be performed to demonstrate that the level of strength reduction is less than the 10% reduction that was employed in the calculations, and to ensure that there is no deterioration of the concrete due to higher temperatures.

February 2023 Revision 4 72-1004 Amendment No. 18 Page P.4-25 All indicated changes on this page are for Enclosure1 Item 1