|
---|
Category:Legal-Affidavit
MONTHYEARML24310A0982024-11-0505 November 2024 Tn Americas, LLC, Application for Amendment 19 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 0 ML24256A0442024-09-0505 September 2024 E-63874 Affidavit for Meeting Slides-Signed ML23213A0282023-08-0101 August 2023 NUH-003, Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 21 ML23095A1012023-04-0505 April 2023 Tn Americas LLC, Third 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 6 ML23067A0772023-03-0808 March 2023 Tn Americas LLC, Second Supplemental Response to Request for Additional Information for Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks – Non-Proprietary ML23020A9212023-01-20020 January 2023 Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks Request for Additional Information Non-Proprietary Responses ML22334A2442022-11-30030 November 2022 Tn Americas LLC, Affidavit ML22140A0252022-05-20020 May 2022 Tn America, LLC, Application for Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 0 ML22094A2082022-03-16016 March 2022 Meeting Slides Affidavit - Notarized ML21356A0322021-12-22022 December 2021 Tn Americas LLC, Supplemental Response to Request for Additional Information - Proposed Alternative to the ASME Code, NG-4230 Tack Welds for Renewed Certificate of Compliance No. CoC 1004, Amendment Nos. 13, 14, 15, 16 and 17 ML21253A1052021-09-10010 September 2021 Proposed Alternative to the ASME Code, NG-4230 Tack Welds, Docket 72-1004, CoC 1004, for Recent Amendments ML21215A5592021-08-0303 August 2021 Tn Americas LLC, NUH-003, Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 20 ML21022A3962021-01-22022 January 2021 NUH-003, Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 19 ML20366A1062020-12-29029 December 2020 Tn Americas LLC Updated Licensing Plans ML20255A2062020-09-11011 September 2020 Tn America, LLC - Response to Request for Additional Information - Application for Amendment 17 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 1 (Docket No. 72-1004, CAC No. 001028, EPID: L- ML17363A2772017-12-14014 December 2017 Tn Americas LLC - Response to First Request for Additional Information on Application for Amendment 15 to Standardized Nuhoms for Spent Fuel Storage Casks, Revision 2, Enclosures 1,3,4,& 5 2024-09-05
[Table view] Category:Letter
MONTHYEARML24310A0982024-11-0505 November 2024 Tn Americas, LLC, Application for Amendment 19 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 0 ML24130A1742024-05-10010 May 2024 Tn Americas Llc. - the U.S. Nuclear Regulatory Commission Inspection Report No. 72-1004/2024-201 ML23293A2992023-11-0808 November 2023 Amendment No. 18 to Certificate of Compliance No. 1004 for the Standardized NUHOMS System (Docket No. 72-1004, CAC No. 001028, (Enterprise Project Identifier: L-2022-LLA-0079) ML23284A0642023-10-11011 October 2023 Supplement to Submittal of Biennial Reports of 72.48 Evaluations Performed for the Standardized NUHOMS System, Certificate of Compliance (CoC) 1004, for the Periods 07/26/2016 to 07/25/2018 and 7/28/2020 to 7/27/2022, Docket 72-1004 ML23206A0172023-09-29029 September 2023 Congressional Letters: List of Approved Spent Fuel Storage Casks: Tn Americas LLC Standardized NUHOMS Horizontal Modular Storage System, Certificate of Compliance No. 1004, Renewed Amendment No.18 ML23213A0282023-08-0101 August 2023 NUH-003, Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 21 ML23095A1012023-04-0505 April 2023 Tn Americas LLC, Third 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 6 ML23067A0772023-03-0808 March 2023 Tn Americas LLC, Second Supplemental Response to Request for Additional Information for Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks – Non-Proprietary ML23047A0282023-02-16016 February 2023 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- ML23030A6682023-01-30030 January 2023 Independent Spent Fuel Storage Installation ((Isfsi) - Submittal of Cask Registration for Spent Fuel Storage ML23027A0562023-01-27027 January 2023 Response to Request for Additional Information – Application for Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 3 (Docket No. 72-1004, CAC No. 001028, EPID: L-2022-LLA-0079) ML23020A9212023-01-20020 January 2023 Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks Request for Additional Information Non-Proprietary Responses ML22355A0932023-01-0606 January 2023 Orano Tn Americas - USNRC Inspection Report 72-1004/2022-203 ML23005A1712023-01-0404 January 2023 Independent Spent Fuel Storage Installation (Isfsi), Submittal of Cask Registration for Spent Fuel Storage ML22313A0462022-12-21021 December 2022 Letter-Review of Amd18 CoC No. 1004 Request for Additional Information ML22224A0412022-08-12012 August 2022 Tn Americas, LLC, Submittal of Response to Request for Supplemental Information - Application for Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 1 ML22165A2782022-07-0505 July 2022 Inspection Report 2022 Orano Corporate Inspection ML22140A0252022-05-20020 May 2022 Tn America, LLC, Application for Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 0 NG-22-0047, Registration of Independent Spent Fuel Installation Storage Cask and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool2022-04-11011 April 2022 Registration of Independent Spent Fuel Installation Storage Cask and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool NG-22-0042, Registration of Independent Spent Fuel Installation Storage Casks2022-04-0808 April 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0030, Registration of Independent Spent Fuel Installation Storage Casks2022-03-23023 March 2022 Registration of Independent Spent Fuel Installation Storage Casks ML22063B1652022-03-16016 March 2022 U.S. Nuclear Regulatory Commission Inspection Report No. 721004/2022201 and 07201042/2022201 NG-22-0025, Registration of Independent Spent Fuel Installation Storage Casks2022-03-0808 March 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0021, Registration of Independent Spent Fuel Installation Storage Casks2022-02-24024 February 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0014, Registration of Independent Spent Fuel Installation Storage Casks2022-02-10010 February 2022 Registration of Independent Spent Fuel Installation Storage Casks ML22025A1692022-02-0303 February 2022 Code Alternative Approval Letter for Certain CoC 1004 Amendments NG-22-0009, Registration of Independent Spent Fuel Installation Storage Casks2022-01-20020 January 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0001, Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61BTH Type 2 Dry Shielded Canister2022-01-0606 January 2022 Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61BTH Type 2 Dry Shielded Canister ML21356A0322021-12-22022 December 2021 Tn Americas LLC, Supplemental Response to Request for Additional Information - Proposed Alternative to the ASME Code, NG-4230 Tack Welds for Renewed Certificate of Compliance No. CoC 1004, Amendment Nos. 13, 14, 15, 16 and 17 NG-21-0038, Registration of Independent Spent Fuel Installation Storage Casks2021-12-22022 December 2021 Registration of Independent Spent Fuel Installation Storage Casks NG-21-0035, Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61 Bth Type 2 Dry Shielded Canister2021-12-10010 December 2021 Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61 Bth Type 2 Dry Shielded Canister ML21323A0572021-11-19019 November 2021 Tn Americas, LLC - Response to Request for Additional Information - Proposed Alternative to the ASME Code, NG-4230 Tack Welds for Renewed Certificate of Compliance No. CoC 1004, Amendment Nos. 13, 14, 15, 16 and 17 ML21292A3312021-11-0303 November 2021 CoC 1004 - Proposed ASME Code Alternative RAI 1 - Letter ML21253A1052021-09-10010 September 2021 Proposed Alternative to the ASME Code, NG-4230 Tack Welds, Docket 72-1004, CoC 1004, for Recent Amendments ML21215A5592021-08-0303 August 2021 Tn Americas LLC, NUH-003, Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 20 ML21179B0272021-06-28028 June 2021 Independent Spent Storage Installation, Submittal of Cask Registration for Spent Fuel Storage ML21168A2662021-06-17017 June 2021 Independent Spent Fuel Storage Installation (ISFSI) - Submittal of Cask Registration for Spent Fuel Storage ML21109A3272021-05-0505 May 2021 Issuance of Certificate of Compliance No. 1004, Renewed Amendment No. 17, for the Standardized NUHOMS System ML21067A6302021-03-0808 March 2021 Orano Tn - Replacement Pages for NUH-003, Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 19 ML21022A3962021-01-22022 January 2021 NUH-003, Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 19 ML20366A1062020-12-29029 December 2020 Tn Americas LLC Updated Licensing Plans PLA-7900, Registration for the Use of Dry Fuel Storage Modules F-6, F-7, and F-8 (PLA-7900)2020-10-14014 October 2020 Registration for the Use of Dry Fuel Storage Modules F-6, F-7, and F-8 (PLA-7900) NG-20-0083, Registration of Independent Spent Fuel Installation Storage Casks2020-10-12012 October 2020 Registration of Independent Spent Fuel Installation Storage Casks PLA-7896, Registration for the Use of Dry Fuel Storage Modules G-8, F-4, and F-5 (PLA-7896)2020-09-28028 September 2020 Registration for the Use of Dry Fuel Storage Modules G-8, F-4, and F-5 (PLA-7896) NG-20-0082, Registration of Independent Spent Fuel Installation Storage Casks2020-09-28028 September 2020 Registration of Independent Spent Fuel Installation Storage Casks ML20255A2062020-09-11011 September 2020 Tn America, LLC - Response to Request for Additional Information - Application for Amendment 17 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 1 (Docket No. 72-1004, CAC No. 001028, EPID: L- PLA-7890, Registration for the Use of Dry Fuel Storage Modules G-6 and G-7 (PLA-7890)2020-09-10010 September 2020 Registration for the Use of Dry Fuel Storage Modules G-6 and G-7 (PLA-7890) ML20245E2542020-08-31031 August 2020 Amendment No. 17 to Certificate of Compliance No. 1004 for the Standardized NUHOMS System - Request for Additional Information PLA-7888, Talen Energy - Susquehanna Steam Electric Station, Registration for the Use of Dry Fuel Storage Modules G-4 and G-5, PLA-78882020-08-25025 August 2020 Talen Energy - Susquehanna Steam Electric Station, Registration for the Use of Dry Fuel Storage Modules G-4 and G-5, PLA-7888 ML20226A0652020-08-21021 August 2020 Standardized NUHOMS Hsm, Amendment 16, (Graded Approach) Finalization Letter (Docket No. 72-1004) 2024-05-10
[Table view] Category:Report
MONTHYEARML23100A0022023-04-0505 April 2023 Enclosure 5: Proposed Amendment 18, Revision 6 Changes to the Standardized NUHOMS System Updated Final Safety Analysis Report (Public Version) ML23095A1012023-04-0505 April 2023 Tn Americas LLC, Third 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 6 ML22203A1202022-05-20020 May 2022 Amendment 18 Non-Proprietary UFSAR ML21350A4522021-12-15015 December 2021 Enclosure - Materials RAI Response Clarifications ML21215A5592021-08-0303 August 2021 Tn Americas LLC, NUH-003, Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 20 ML20308A4882020-12-21021 December 2020 Proposed CoC 1004 Amendment No. 17 Appendix a ML20308A4892020-12-21021 December 2020 Proposed CoC 1004 Amendment No. 17 Appendix B Table of Content ML20308A4902020-12-21021 December 2020 Proposed CoC 1004 Amendment No. 17 Appendix B Text ML20308A4912020-12-21021 December 2020 Proposed CoC 1004 Amendment No. 17 Appendix B Tables ML20308A4942020-12-21021 December 2020 Proposed CoC 1004 Amendment No. 17 Appendix C ML17255A0302017-09-12012 September 2017 Independent Spent Fuel Storage Installation, Registration of Use of Casks to Store Spent Fuel NLS2014044, and ISFSI - Thirty-Day Notification Pursuant to 10 CFR 72.212, Conditions of General License Issued Under Section 72.2102014-05-13013 May 2014 and ISFSI - Thirty-Day Notification Pursuant to 10 CFR 72.212, Conditions of General License Issued Under Section 72.210 LIC-06-0056, Request for Exemption from Nuhoms Certificate of Compliance No. 1004, Amendment No. 82006-06-0909 June 2006 Request for Exemption from Nuhoms Certificate of Compliance No. 1004, Amendment No. 8 2023-04-05
[Table view] Category:Technical
MONTHYEARML23100A0022023-04-0505 April 2023 Enclosure 5: Proposed Amendment 18, Revision 6 Changes to the Standardized NUHOMS System Updated Final Safety Analysis Report (Public Version) ML23095A1012023-04-0505 April 2023 Tn Americas LLC, Third 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 6 ML22203A1202022-05-20020 May 2022 Amendment 18 Non-Proprietary UFSAR ML21215A5592021-08-0303 August 2021 Tn Americas LLC, NUH-003, Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 20 2023-04-05
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARML23095A1012023-04-0505 April 2023 Tn Americas LLC, Third 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 6 ML23067A0772023-03-0808 March 2023 Tn Americas LLC, Second Supplemental Response to Request for Additional Information for Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks – Non-Proprietary ML23047A0282023-02-16016 February 2023 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- ML23027A0562023-01-27027 January 2023 Response to Request for Additional Information – Application for Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 3 (Docket No. 72-1004, CAC No. 001028, EPID: L-2022-LLA-0079) ML23020A9212023-01-20020 January 2023 Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks Request for Additional Information Non-Proprietary Responses ML22224A0412022-08-12012 August 2022 Tn Americas, LLC, Submittal of Response to Request for Supplemental Information - Application for Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 1 ML21356A0322021-12-22022 December 2021 Tn Americas LLC, Supplemental Response to Request for Additional Information - Proposed Alternative to the ASME Code, NG-4230 Tack Welds for Renewed Certificate of Compliance No. CoC 1004, Amendment Nos. 13, 14, 15, 16 and 17 ML21350A4522021-12-15015 December 2021 Enclosure - Materials RAI Response Clarifications ML21323A0572021-11-19019 November 2021 Tn Americas, LLC - Response to Request for Additional Information - Proposed Alternative to the ASME Code, NG-4230 Tack Welds for Renewed Certificate of Compliance No. CoC 1004, Amendment Nos. 13, 14, 15, 16 and 17 ML20255A2062020-09-11011 September 2020 Tn America, LLC - Response to Request for Additional Information - Application for Amendment 17 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 1 (Docket No. 72-1004, CAC No. 001028, EPID: L- ML19224A0522019-08-0808 August 2019 (Lgs), Units 1 and 2 - Response to Requested Supplemental Information for a One Time Alternative Request Pertaining to Dry Shield Canisters Equipped with Boral Neutron Absorber Plates ML18088A1802018-03-22022 March 2018 to Application for Amendment 15 to Standardized Nuhoms Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Supplemental Response to First Request for Additional Information ML17363A2772017-12-14014 December 2017 Tn Americas LLC - Response to First Request for Additional Information on Application for Amendment 15 to Standardized Nuhoms for Spent Fuel Storage Casks, Revision 2, Enclosures 1,3,4,& 5 ML17264A7502017-09-21021 September 2017 Response to Request for Additional Information (RAI) License Amendment Request Regarding Removal of Dry Cask Loading Limits Fort Calhoun Station, Unit 1 Docket No.: 50-285 (MF9831) CNRO-2016-00005, Response to Request for Additional Information Pertaining to a Change to the Entergy Quality Assurance Program Manual (QAPM)2016-02-25025 February 2016 Response to Request for Additional Information Pertaining to a Change to the Entergy Quality Assurance Program Manual (QAPM) 2023-04-05
[Table view] |
Text
April 5, 2023 E-62170
Columbia Office U. S. Nuclear Regulatory Commission 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:
Third 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 6 (Docket No. 72-1004, CAC No. 001028, EPID: L-2022-LLA-0079)
Reference:
[1] E-61864, Response to Request for Additional Info rmation -
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 associated with the responses to certain structural RAIs.
The NRC and TN held a clarification call on March 6, 2023 for the purpose of clarifying TNs responses to certain structural Requests for Additional In formation (RAIs). As a result, TN is providing supplemental information associated with RAIs 4.4 and 4.5.
Enclosure 2 provides a proprietary version of the aforementione d RAIs and supplemental responses as a result of the clarification call. Enclosure 3 provides a public version of the supplemental responses to the RAIs.
The proprietary version of the Updated Final Safety Analysis Re port (UFSAR) changed pages associated with Amendment 18 are included as Enclosure 4, with a footer on each changed page annotated as 72-1004 Amendment 18, Revision 6, April 2023, and changes indicated by italicized text and revis ion 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 6 ch anges from previous Amendment 18 changes. The public version of these UFSAR change d pages is provided as Enclosure 5.
Enclosure 6 provides a listing of computer files contained on the Enclosure 7 hard drive being submitted in support of this submittal. Enclosure 7 contains file formats and sizes not allowed by the NRC EIE application process, so they are provided separately on one computer drive.
Document Control Desk E-62170 Page 2 of 2
Certain portions of this submittal include proprietary informat ion, which may not be used for any purpose other than to support the NRC staffs review of the app lication. In accordance with 10 CFR 2.390, TN Americas LLC is providing an affidavit, Enclos ure 1, specifically requesting that this proprietary information be withheld from public discl osure.
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
cc: Chris Allen (NRC), Project Manager, Storage and Transportation Licensing Branch Division of Fuel Management
Enclosures:
- 1. Affidavit Pursuant to 10 CFR 2.390
- 2. RAIs and Responses (Proprietary)
- 3. RAI and Responses (Public)
- 4. Proposed Amendment 18, Revision 6 Changes to the Standardize d NUHOMS System Updated Final Safety Analysis Report (Proprietary Version)
- 5. Proposed Amendment 18, Revision 6 Changes to the Standardize d NUHOMS System Updated Final Safety Analysis Report (Public Version)
- 6. Listing of Computer Files Contained in Enclosure 7
- 7. Certain Computer Files Associated with Certificate of Compli ance 1004 Amendment 18, Revision 6 (Proprietary) (contained on one hard drive)
Enclosure 1 to E-62170
AFFIDAVIT PURSUANT TO 10 CFR 2.390
TN Americas LLC )
State of Maryland) SS.
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 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 meets the provisions of paragraph (a) (4) of Section 2.390 of the Commission's regulations. The information is listed below:
- Enclosure 2 - Portions of Proposed Amendment 18, Revision 6 Responses to RAIs
- Enclosure 7 - Certain computer files associated with Proposed Amendment 18, Revision 6
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 infonnation sought to be withheld from public disclosure involves portions of the RAI responses, portions of the UFSAR, and analysis computer files, all related to the design 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 infonnation consists of descriptions of the design of dry spent fuel storage systems, the application of which provide a competitive economic advantage. The availability of such infonnation 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.
Further the deponent sayeth not.
Prakash Narayanan Chief Technical Officer, TN Americas LLC
Subscribed and sworn before me this 30day of March, 2023. MARYANNE D ATIENZA
Notary Public Anne Arundel County
1 II----------------------------------------------------- Maryland Notary Public My Commission Expires March 02, 2025 My Commission Expires *3 / ^ cX3
Page 1 of 1 Enclosure 2 to E-62170
RAIs and Responses (Proprietary Version)
Withheld Pursuant to 10 CFR 2.390
RAIs and Responses - Public Enclosure 3 to E-62170
Structural:
RAI 4.4:
Provide buckling evaluations of the 24PTH DSC and Type 3 Basket.
Buckling of the 24PTH DSC and the Type 3 basket were not evaluated. NUREG -2215 suggests that buckling of the fuel basket materials should be considered for normal and off-normal loading (section 4.5.5.1.2 of reference 2) and buckling of the canister should be considered for a load drop (section 4.5.6.1.1 of reference 2). Buckling evaluations of the 24PTH DSC and Type 3 Basket are needed for the staff to complete the evaluations. The resulting basket deformation from these evaluations should be appropriately included in the criticality analys is and shielding analysis since the basket affects axial dose rates.
The above information is necessary to comply with 10 CFR 72.236(c) and (d).
Original Response to RAI 4. 4:
For the 24PTH DSC Shell, the b uckling evaluations of the 24PTH DSC for a postulated 60g end drop are provided in UFSAR Section P.3.7.4.2.4. This section remains unchanged in this submittal since the same DSC Shell is used for all basket types of the 24PTH DSC.
For normal and off-normal loading, the stress in the Type 3 basket compartment plates for the 1g axial handling load due to conservative basket and fuel assembly weights is 0.54 ksi. This stress value is low, such that the DW + 1g axial handling load combination does not control, and no further buckling evaluation is required.
The buckling evaluation for the Type 3 basket under accident side drop loading is discussed in UFSAR Section P.3.8.7.3, and results are presented in UFSAR Tables P.3.8-8 and P.3.8-9. The buckling evaluation for the Type 3 basket under end drop loading is provided in UFSAR Section P.3.8.7.4.Both of these evaluations demonstrate that the 24PTH Type 3 basket will not buckle under accident conditions.
Original Impact:
No change as a result of this RAI.
Supplemental Response to RAI 4.4:
Because the bottom grid plates are subjected to a compressive stress of 17.75 ksi during the 75g end drop loading condition, as discussed in UFSAR Section P.3.8.7.4, a buckling evaluation is performed in accordance with NUREG-6322 and added to UFSAR Section P.3.8.7.4.
NUREG-6322 has been added to reference Section P.3.9.
For the buckling evaluation of the bottom grid plates, which are subjected to the greatest compressive stress, two configurations are considered. The first configuration consists of a
[ ] high grid plate representing an [ ] span of a compartment. [
] as
Page 1 of 6 RAIs and Responses - Public Enclosure 3 to E-62170
shown on Sheet 4 of UFSAR Drawings NUH24PTH-L-5012-SAR, NUH24PTH-S-5012-SAR, and NUH24PTH-S-LC -5012-SAR.
Since the plate is connected to adjacent plates through a portion of the unloaded edges, the plate is considered simply supported on that portion of the edge and free on the rest of the edge, in accordance with Section 5.3 of NUREG -6322. To determine the buckling load of such a plate, an eigenvalue buckling analysis is performed by ANSYS using the model shown in new UFSAR Figure P.3.8-9. The buckling stress determined by ANSYS is 102.7 ksi.
Section 6.5 of NUREG-6322 requires the compressive stress to be limited to 2/3 of the value determined by buckling analysis. Therefore, the allowable stress is (102.7)(2/3) = 68.45 ksi, which is substantially greater than the compressive stress of 17.75 ksi.
The second configuration consists of the top cantilever potion of the plate in the first configuration, which is considered as a plate with two free unloaded edges. Per Equation 19 of NUREG-6322, the elastic buckling stress of such a plate is calculated as :
2
=e DK ah22
where D is the plate rigidity, Kis the effective length factor of columns, a is the plate height, and h is the plate thickness. If the most conservative value of K = 2.1 from Figure 6 of NUREG-6322 is used, e = 47.59 ksi. The allowable stress is, therefore, (47.59)(2/3) = 31.73 ksi, which is substantially greater than the compressive stress of 17.75 ksi. As such, no part of the 24PTH Type 3 basket plates will buckle under accident end drop loading.
Supplemental Impact:
UFSAR Sections P.3.8.7.4 and P.3.9 have been revised as described in the response.
UFSAR Figure P.3.8-9 has been added as described in the response.
Page 2 of 6 RAIs and Responses - Public Enclosure 3 to E-62170
RAI 4.5:
Provide justification that the cross-section model approach is appropriate for the 24PTH DSC Type 3 basket.
The interlocking egg-crate design of the Type 3 basket utilizes no welding and relies on attachments at the basket exterior to keep the structure intact. The mechanical interlocking of the plates at the center of the basket likely has clearance gaps for assembly and thermal growth that give the basket add itional flexibility (drawing details were not available to evaluate the gap dimensions). The application has little discussion of the joints and gaps between the basket plate structures and how these are conservatively accounted for in the ANSYS cross -section model. It is not apparent that the short cross -section basket model accounts for the flexibility of the interlocking joints in the series of plates forming the egg-crate design, and the boundary conditions may be artificially stiffening the structure by disallowing any axial motion of the plates under flexure that could occur due to axial clearance gaps. If the cross -section model approach is overly stiff for simulation of an egg-crate design, this could lead to underprediction of the basket compartment relative displacements, which is important for and impacts, among others, the criticality and shielding analyses.
Provide justification that the modeling domain with the cross -section approach appropriately captures the inherent joint flexibility and assembly gaps of the Type 3 basket design to predict maximum compartment displacement. In addition, provide justification for not using the LS -
DYNA approach as done with the Type 1 and Type 2 basket design.
The above information is necessary to comply with 10 CFR 72.236(c) and (d).
References:
- 1. Orano TN, Application for Amendment 18 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks, Revision 0 (Docket No. 72-1004), May 20, 2022.
- 2. NUREG-2215, Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities -
Final Report, April 2020.
- 3. NUREG/CR-3966, Methods for Impact Analysis of Shipping Containers, November 1987.
Original Response to RAI 4. 5:
The mechanical interlocking of the plates at the center of the basket has clearance gaps for assembly and thermal growth, which are considered in the 6-inch cross-section basket model using [ ] elements as described in UFSAR Section P.3.8.6.1. [
] The key basket
dimensions are provided in D rawings NUH24PTH-S-5012-SAR, NUH24PTH-L-5012-SAR, and NUH24PTH-S-LC -5012-SAR in UFSAR Section P.1.5, for the 24PTH-S, -L, and -S-LC DSC, respectively. The drawings show the following basket plate thicknesses.
Page 3 of 6 RAIs and Responses - Public Enclosure 3 to E-62170
Page 4 of 6 RAIs and Responses - Public Enclosure 3 to E-62170
The 24PTH Type 1 and Type 2 basket designs are welded structures for which LS -DYNA was used for structural analysis. However, the 24PTH DSC Type 3 basket egg-crate design is based on the NUHOMS EOS System baskets, so the analysis methodologies including the use of ANSYS for structural analysis for the 24PTH DSC Type 3 basket followed the approach for the NUHOMS EOS basket analysis described in CoC 1042 UFSAR, Section 3.9.2 [1].
Reference:
- 1. NUHOMS EOS System Updated Final Safety Analysis Report, Docket Number 72-1042, Revision 4.
Original Impact:
No change as a result of this RAI.
Supplemental Response to RAI 4.5:
The clearance gaps discussed in the Original Response were modeled in the handling load analysis, but not in the accident side drop load analysis. Additional sensitivity analysis is performed to appropriately consider the effect of the [ ] gap at the intersecting plate slots in the side drop analysis. The Type 3 basket ANSYS model described in UFSAR Section P.3.8.6.1 is modified in such a way that the gaps at the slots of the intersecting plates are
[ ], and the bounding load case from UFSAR Section P.3.8.7.3 of a 210°, 75g side drop without bolts and tie rods is reevaluated. Side loads, material properties, thermal gaps, dummy DSC displacement and all other criteria are unchanged. UFSAR Figure P.3.8-8 has been added and Table P.3.8-7, Table P.3.8-9, and Table P.3.8-11 have been updated to add the results of this sensitivity analysis.
The maximum strain increased from 0.00673 to 0.01048. Nevertheless, the maximum strain is still significantly less than the allowable strain of 0.03. [
]
Page 5 of 6 RAIs and Responses - Public Enclosure 3 to E-62170
The buckling analysis described in UFSAR Section P.3.8.7.3 is performed for the updated model considering a [ ] gap at the intersecting plate slots. There was still convergence at the maximum applied load of 94g, so the 24PTH Type 3 basket will not buckle under accident side drop loading. The 75g end drop evaluation discussed in UFSAR Section P.3.8.7.4 and the response to RAI 4.4 is not affected by the [ ] gap condition.
Maximum relative perpendicular displacement from one fuel compartment plate to another is determined from the ANSYS results for the accident side drop as described in UFSAR Section P.3.8.7.5. These updated results presented in UFSAR Table P.3.8-11 indicate that the maximum relative displacements between adjacent fuel compartments demonstrated a small increase when the [ ] gap is considered as compared with the case of no gap.
The structural analyses considering the revised finite element model of the 24PTH Type 3 basket with an appropriate [ ] gap at the intersecting plate slots demonstrate that the Type 3 basket is structurally adequate under accident loading conditions. Relevant computer files for the updated analysis are included in Enclosure 7.
Supplemental Impact:
UFSAR Sections P.3.8.6.1, P.3.8.7.3, and P.3.8.7.5have been revised as described in the response.
UFSAR Tables P.3.8-7, P.3.8-9, and P.3.8-11 have been revised as described in the response.
UFSAR Figure P.3.8-8 has been added as described in the response.
Page 6 of 6