ML19263D038

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Attachment: Draft Tn Proprietary Review (09/13/2019, E-Mail from D. Shaw/Tn Americas LLC to N. Garcia-Santos Preliminary Feedback and a Question - Documents - CoC 1004)
ML19263D038
Person / Time
Site: 07201004
Issue date: 09/13/2019
From: Shaw D
TN Americas LLC
To: Garcia-Santos N
Spent Fuel Licensing Branch
Garcia-Santos N
References
Download: ML19263D038 (14)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 PRELIMINARY SAFETY EVALUATION REPORT TRANSNUCLEAR, INC.

STANDARDIZED NUHOMS HORIZONTAL MODULAR STORAGE SYSTEM FOR IRRADIATED NUCLEAR FUEL DOCKET No. 72-1004 NUHOMS SYSTEM AMENDMENT NO. 16 superscript

Table of Contents Page

SUMMARY

...................................................................................................................................... 1

1.0 BACKGROUND

.................................................................................................................. 1 1.1 Previous Studies............................................................................................................... 1 1.2 Application to Implement a Pilot Graded Approach Criteria....................................... 2 2.0 GRADED APPROACH METHODOLOGY........................................................................ 5 2.1 Graded Approach Criteria................................................................................................ 5 2.2 Evaluation format.............................................................................................................. 8 3.0 EVALUATION OF PROPOSED CHANGES..................................................................... 8 3.1 Certificate of Compliance (Evaluation Forms 1 to 12)................................................. 8 3.1.1 Form No. 1. I.D. CoC-1, Condition No. 1, Casks approved under the general license.......................................................................................................................... 8 3.1.2 Form No. 2. I.D. CoC-2, Condition No. 2, Changes to the certificate or technical specifications.............................................................................................................. 9 3.1.3 Form No. 3. I.D. CoC-3a, Model Nos. included in the certificate........................ 10 3.1.4 Form No. 4. I.D. CoC-3b, Cask description.......................................................... 11 3.1.5 Form No. 5. I.D. CoC-3c, Cask drawings............................................................... 12 3.1.6 Form No. 6. I.D. CoC-3d, Casks basic components............................................. 12 3.1.7 Form No. 7. I.D. CoC-4, Notification of fabrication schedules........................... 13 3.1.8 Form No. 8. I.D. CoC-5, Notification of use of active cooling............................. 13 3.1.9 Form No. 9. I.D. CoC-6, Quality assurance program........................................... 14 3.1.10 Form No. 10. I.D. CoC-7, Condition No. 7 (first paragraph), heavy loads requirements and procedures for each lift............................................................ 14 3.1.11 Form No. 11. I.D. CoC-7, Condition No. 7 (second paragraph), evaluation of consequences of accidental drops........................................................................ 15 3.1.12 Form No. 12. I.D. CoC-8, Dry run training exercise.............................................. 15 3.2 Technical Specifications (Evaluation Forms 13 to 16(?)).......................................... 16 3.2.1 Section 1.0, Use and Application (Evaluation Forms 13 to 16)....................... 16 3.2.1.1 Form No. 13. I.D. TS-1.1, Definitions...................................................................... 16 3.2.1.2 Form No. 14. I.D. TS-1.2, Logical connectors........................................................... 16 3.2.1.3 Form No. 15. TS-1.3, Completion times.................................................................... 17 3.2.1.4 Form No. 16. I.D. TS-1.4, Frequency........................................................................ 17 3.2.2 Section 2.0, Functional and Operating Limits (Evaluation Form Nos. 17 to 20)

..................................................................................................................................... 17 99

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 PRELIMINARY SAFETY EVALUATION REPORT STANDARDIZED NUHOMS STORAGE SYSTEM DOCKET NO. 72-1004 AMENDMENT NO. 16

SUMMARY

On October 3, 2012, the Nuclear Energy Institute (NEI) submitted a petition for rulemaking (i.e.,

PRM No. 72-7), Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste (NEI, 2012).

This petition for rulemaking was accepted by the U.S. Nuclear Regulatory Commission (NRC) in 2012. The goal was to revise the regulation to include specific criteria for the format and content to be included in a certificate of compliance (CoC) for a spent fuel storage system. This petition for rulemaking was the genesis for using amendment 16 of the Model No. NUHOMS storage system as a pilot to develop a methodology to streamline the format and content of a CoC for a storage system design.

The NEI and the staff from NRC (the staff, thereafter) had several public meetings to discuss the criteria to streamline the format and content of a storage CoC. After several interactions, the NEI and the staff decided to test the criteria on an amendment request as a pilot (NEI, 2017b). The amendment application would only evaluate the format and content and contain no technical changes to the license. TN Americas LLC volunteered to submit the application to pilot the criteria.

The staff did not use NUREG-1536, Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility, (NUREG-1536) because the applicant did not request changes to the design of the storage system (i.e., cask system). Instead, the staff followed these main steps:

1) reviewed each proposed change to the CoC1 against the criteria agreed upon the staff and NEI (NEI, 2017b),
2) verified that no technical changes were made in the transition to the new CoC format and contents.

The staff reviewed the evaluation performed by TN Americas (thereafter, the applicant). The application consisted of the evaluation forms, the CoC, technical specifications (TSs), and updated final safety analysis report (UFSAR) page changes. The forms served as a decision-making tool to evaluate changes to the CoC and TSs in a consistent manner. The applicant 1 The CoC includes the TSs.

by

0 used the forms to document the evaluation of the information in the CoC and TSs against the set of criteria agreed upon with NEI. During the evaluation process, the staff exercised engineering judgment, based on the staffs technical and operating experience, and used NRCs guidance2 applicable to the specific changes proposed by the applicant. Figure S.1. of this safety evaluation report includes the main steps and criteria that the staff followed for identifying the information that should be removed or moved from the technical specifications for the Model No. NUHOMS.

Figure S.1. Overview of the criteria used for removing, editing, moving, or adding information to the CoC, TSs, or FSAR (NUHOMS, Amendment 16).

The following sections of this document include background information about the genesis of this project, the graded approach methodology, and the safety evaluation related to this amendment request.

2 The staff used different guidance depending on the change requested. The evaluation of each form includes the references pertinent to the change evaluated by the staff. The references section includes the documents that the staff considered in its evaluation.

  • Propose deleting text considered redundant
  • Verify impact to CoC, TS, and FSAR Delete
  • Edit existing CoC
  • Edit existing TSs Edit
  • Move TSs edited text to FSAR Move
  • Add new text to clarify existing CoC conditions,
  • Add text to clarify existing TSs, and/or
  • Add text to clarify the information in the FSAR.

Add superscript

2 In April 2012, the NRC Risk Management Task Force, headed by NRC Commissioner George Apostolakis, issued NUREG-2150, "A Proposed Risk Management Regulatory Framework,"

encouraging the adoption of a more risk-informed approach to regulating the certification of dry cask storage systems for spent nuclear fuel (NUREG-2150).

1.2 Application to Implement a Pilot Graded Approach Criteria The NRC approved the PRM 72-7 (NEI, 2012) submitted by NEI for consideration for rulemaking on July 18, 2014 (79 FR 41935). On September 30, 2014, the Division of Spent Fuel Storage and Transportation (renamed Division of Spent Fuel Management or DSFM) published a position paper titled, Spent Fuel Storage and Transportation Scoping and Implementation Plan for Risk-Informing Regulatory Activities, (NRC, 2008) which included a high-level description of the activities needed to define a qualitative risk-informed framework for dry cask storage. The position paper outlined the NRCs implementation plan to use a pilot project as the first step on developing a risk-informed framework for certification for dry cask storage systems.

Following the issuance of the position paper, NEI developed a proposal to improve the efficiency of the regulatory framework used for certifying dry storage systems. In April 12, 2016, NEI submitted a proposal in the form of a Regulatory Issue Resolution Protocol3 (RIRP) (i.e.,

RIRP-I-16-01) to NRC (NEI, 2016a). NEI discussed the proposal at a public meeting held on August 8, 2016 (NRC, 2016a). NEI proposed using an amendment to CoC number (No.) 1004 as a pilot case to implement the graded approach methodology and determine how the proposed criteria would improve the format and content of a CoC for a storage system by using a qualitative risk-informed framework. The goal of the pilot project was to determine what information should be included in the CoCs, TS, and FSAR to comply with the regulatory requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 72.

By letter dated June 29, 2017 (TN, 2017a) and supplemented on August 31, 2017 (TN, 2017b),

October 13, 2017 (TN, 2017c), November 16, 2017 (TN, 2017d), April 26, 2018 (TN, 2017a),

June 7, 2018 (TN, 2017b), September 3, 2019 (TN, 2019a), September 6, 2019 (TN, 2019b),

September 10, 2019 (TN, 2019c), and September 11, 2019 (TN, 2019d), TN Americas LLC (the applicant) submitted an application for CoC No. 1004, Amendment 16, for the Model No.

Standardized NUHOMS (thereafter, NUHOMS). The amendment request contained no design changes to the NUHOMS system, rather, the applicant included proposed changes to the CoC format and content using a graded approach principle as previously agreed by the staff and NEI (NEI, 2017b). Figure 1.1 summarizes path to the submittal of Amendment 16 of the NUHOMS storage system graded approach as a pilot project. Figure 1.2 includes information related to the review of the application of Amendment 16.

3 The RIRP is a process used by NEI to screen issues that may have generic implications (i.e., issues that may impact multiple companies or individuals). (https://www.nrc.gov/docs/ML0919/ML091960576.pdf) the

14 3.1.9 Form No. 9. I.D. CoC-6, Quality assurance program.

(1)

Proposed Change The applicant proposed to delete the text of CoC Condition No. 6 in Amendment 15, requiring conduct of activities to comply with a quality assurance program that satisfies the applicable requirements of 10 CFR Part 72, Subpart G, Quality Assurance.

(2)

Evaluation of Change The staff reviewed the proposed change. The staff verified that CoC Condition No. 6 in Amendment 15 reflected an existing regulatory requirement, which is 10 CFR 72, Subpart G, Quality Assurance, and removal of this pointer would not modify the licensing requirements.

Therefore, the staff finds the deletion acceptable within the new CoC for Amendment 16.

3.1.10 Form No. 10. I.D. CoC-7, Condition No. 7 (first paragraph), heavy loads requirements and procedures for each lift.

(1)

Proposed Change The applicant proposed to move the text of the first paragraph of r CoC Condition No. 7 of Amendment 15 to the new TS, Section 4, Administrative Controls, of Amendment 16. The TS requires DSC and TC lifts to be made in accordance with existing heavy loads requirements and procedures of the licensed facility (i.e., plant-specific) at which the lift is made to show operational compliance with NUREG-0612 (NUREG-0612) and/or existing plant-specific heavy loads requirements.

The applicant identified the TS, Section 4, Administrative Controls, in Amendment 16 as the appropriate CoC section to incorporate the information of CoC Condition No. 7 in Amendment 15 regarding DSC and TC lifts. In addition, the applicant identified potential risk of reducing the margin of safety (selection criterion No. 8), if this condition were to be removed.

(2)

Evaluation of Change The staff confirmed that the change is within the scope of the selection criteria identified by the applicant, because failure to meet the condition could result in increased probability or consequence of an accident, and the requirement is an administrative control to ensure safe operations. There is no change to the text and relocating this condition would not modify the licensing requirements. Therefore, the staff finds the proposed changes acceptable and the information of CoC Condition No. 7 in Amendment 15 is incorporated in new TS 4.3.4, Heavy Loads Requirements, in Amendment

16. (TN, 2019a)

15 3.1.11 Form No. 11. I.D. CoC-7, Condition No. 7 (second paragraph), evaluation of consequences of accidental drops.

(1)

Proposed Change The applicant proposed to move the text of the second paragraph ofCoC Condition No. 7 in Amendment 15, to the new TS, Section 4, Administrative Controls, in Amendment 16. CoC Condition No. 7 in Amendment 15 requires evaluation of an accidental drop of the shielding components of the OS197L TC (if a single failure proof crane is not used). (NRC, 2018)

The applicant identified the new TS, Section 4, Administrative Controls, in Amendment 16 as the appropriate CoC section to incorporate the information of the CoC Condition No. 7 in Amendment 15. In addition, the applicant identified potential risk in reduction in margin of safety (selection criterion No.

8), if this condition were to be removed.

(2)

Evaluation of Change The staff confirmed that the change proposed by the applicant is within the scope of the selection criteria identified by the applicant because the following reasons:

(i) failure to meet the condition could result in increased probability or consequence of an accident, and (ii) the requirement is an administrative control on safety of operations.

There is no change to the text of Condition No. 7 of Amendment 15 and relocating this condition would not modify the licensing requirements.

Therefore, the staff finds the change acceptable and the condition is incorporated in the TS Section 4 in Amendment 16, specifically, TS 4.3.4 Heavy Loads Requirements.

3.1.12 Form No. 12. I.D. CoC-8, Dry run training exercise.

(1)

Proposed Change The applicant proposed to move the text verbatim of CoC Condition No. 8 in Amendment 15, (NRC, 2018) regarding dry run, loading, and unloading operations, to the TS, Section 4, Administrative Controls in Amendment 16.

(2)

Evaluation of Change The staff confirmed that the change is within the scope of the selection criteria identified by the applicant, because the requirement is an administrative control related to the safe of operation of the system. There is no change to the information in CoC Condition No. 8 in Amendment 15 and relocating this condition would not modify the licensing requirements.

Therefore, the staff finds the change, the incorporation of the information inCoC Condition No. 8 in Amendment 15 into the new TS, Section 4 in insert space

16 Amendment 16, specifically, TS 4.3.5, Pre-Operational Testing and Training Exercise.

3.2 Technical Specifications (Evaluation Forms 13 to 16(?))

3.2.1 Section 1.0, Use and Application (Evaluation Forms 13 to 16) 3.2.1.1 Form No. 13. I.D. TS-1.1, Definitions.

(a)

Proposed Change The applicant proposed to retain the text of the TS 1.1, Definitions, in Amendment 15 and relocate it to the TS, Appendix B, Section 1, Use and Application, in Amendment 16, and to add revised definitions for the new inspections, tests, and evaluations (ITE) and LCOs. The applicant proposed to retain most of the definitions and added a definition for operable/operability to this list.

The applicant identified the TS, Section 1, Use and Application, as the appropriate CoC section in Amendment 16 to incorporate this specification.

(b)

Evaluation of Change The staff finds this change acceptable because the following reasons:

(i) this relocation to Appendix B in Amendment 16 conforms to the new CoC format and content, and (ii) this relocation would not modify the licensing requirements.

Therefore, the TS is incorporated in Appendix B, TS, Section 1, Use and Application, in Amendment 16, specifically Subsection 1.1, Definitions.

3.2.1.2 Form No. 14. I.D. TS-1.2, Logical connectors.

(a)

Proposed Change The applicant proposed to retain the text of the TS 1.2, Logical Connectors, in the Appendix B, TS, Section 1, Use and Application from Amendment 15 for Amendment 16.

(b)

Evaluation of Change The staff confirmed that TS, Section 1, is the appropriate location for this program because the logical connectors are key definitions for implementing the logic of the TS. There is no change to TS 1.2. Therefore, the staff finds the proposed =change acceptable and the TS is incorporated in TS, Section 1, Use and Application, subsection 1.2 Logical Connectors, in Appendix B.

Nos.

99

17 3.2.1.3 Form No. 15. TS-1.3, Completion times.

(a)

Proposed Change The applicant proposed to retain the text of the TS 1.3, Completion Times, in the TS, Section 1, Use and Application, in Appendix B of Amendment 15 for Amendment 16.

(b)

Evaluation of Change The staff confirmed that TS, Section 1, is the appropriate location for this program because the completion times are key definitions for implementing the logic of the TS. The staff confirmed that no changes were made to TS 1.3. Therefore, the staff finds the proposed change acceptable and the TS is incorporated in TS, Appendix B, Section 1, Use and Application, Subsection 1.3, Completion Times.

3.2.1.4 Form No. 16. I.D. TS-1.4, Frequency.

(a)

Proposed Change The applicant proposed to retain the text of TS 1.4, Frequency, in the TS, Appendix B, Section 1, Use and Application, in Amendment 15 for Amendment 16.

(b)

Evaluation of Change The staff verified that there is no change made to the text. On this basis, the staff finds the proposed change acceptable and the TS is incorporated in TS, Appendix B, Section 1, Use and Application, Subsection 1.4, Frequency.

3.2.2 Section 2.0, Functional and Operating Limits (Evaluation Form Nos. 17 to 20) 3.2.2.1 Form No. 17. I.D. TS-2.1, Fuel to be stored in the Standardized NUHOMS system.

(a)

Proposed Change The applicant proposed to retain the text of former TS 2.1, Fuel to be Stored in the Standardized NUHOMS System, in the TS, Section 2, Functional and Operating Limits, in Appendix B.

The applicant recognized that the fuel to be stored is the single most important control of any dry storage cask system design and proposed to retain this specification in the Appendix B, TS, Section 2, Functional and Operating Limits. In addition, the applicant identified potential risk for all risk insight criteria (selection criteria Nos. 8, 9, 10), if this condition were to be removed.

superscript

27 Appendix C, ASME Code Alternatives, and subsection II.1.d to the new CoC. subsection II.1.d, has the following statement:

ASME Code alternatives for DSC pressure boundary or confinement boundary components, DSC basket assembly components, and TC components, can be found in CoC Appendix C.

The staff confirmed that no other changes were made to the text of the TS and it is incorporated in the new CoC,Section II, Design Features, subsection II.1.b. Therefore, the staff finds the proposed change acceptable.

3.2.4.7 Form No. 33. I.D. TS-4.2.3, Codes and standards/Transfer canister (TC) (first two paragraphs and table).

(a)

Proposed Change The applicant proposed to move the first two paragraphs and table of former TS-4.2.3, "Codes and Standards / Transfer Cask (TC), which lists codes and standards applicable to the TCs, to CoC,Section II, "Design Features. In addition, the applicant evaluated the potential increase in risk (in probability or consequences) of a previously evaluated accident (selection criterion No.

8), and reduced margin of safety (selection criterion No. 10), if this specification was removed.

(b)

Evaluation of Change The staff confirmed that the change is within the scope of the selection criteria identified by the applicant, because failure to specify applicability would result in increased probability or consequence of an accident, and lack of this information would lead to reduced margin of safety for operations.

Furthermore, because it defines codes and standards which are fundamental for the safety of the design. The staff confirmed that the only change to the text was the deletion of the statement that code alternatives are discussed in former TS 4.2.4. The staff finds this change acceptable because of the addition of Appendix C, ASME Code Alternatives, and subsection II.1.d in the new CoC. subsection II.1.d has the following statement:

ASME Code alternatives for DSC pressure boundary or confinement boundary components, DSC basket assembly components, and TC components, can be found in CoC Appendix C.

The staff confirmed that no other changes were made to the text of the TS and it is incorporated in the new CoC,Section II, Design Features, subsection II.1.c. Therefore, the staff finds the proposed change acceptable.

no dash

28 3.2.4.8 Form No. 34. I.D. TS-4.2.3, Codes and standards/Transfer canister (TC) (last two paragraphs).

(a)

Proposed Change The applicant proposed to move the last two paragraphs of TS-4.2.3, Codes and Standards / Transfer Cask (TC), which lists codes and standards applicable to the OS197L TC shielding, to CoC,Section II, "Design Features.

In addition, the applicant evaluated the potential increase in risk (in probability or consequences) of a previously evaluated accident (selection criterion No.

8), and reduced margin of safety (selection criterion No. 10), if this specification was removed.

(b)

Evaluation of Change The staff confirmed that the change is within the scope of the selection criteria identified by the applicant, because failure to specify applicability would result in increased probability or consequence of an accident, and lack of this information would lead to reduced margin of safety for operations.

Furthermore, because it defines codes and standards, which are fundamental for the safety of the design. The staff confirmed that no changes were made to the text of the TS and it is incorporated in the new CoC,Section II, Design Features, subsection II.1.c. Therefore, the staff finds the proposed change acceptable.

3.2.4.9 Form No 35. I.D. TS-4.2.4, American Society of Mechanical Engineers (ASME) code alternatives.

(a)

Proposed Change The applicant proposed to move the tables of ASME Code alternatives contained in TS-4.2.4, ASME Code Alternatives, (NRC, 2018) to a new CoC Appendix C, ASME Code Alternatives (TN, 2019a). In addition, the applicant proposed to retain the statement specifying requirements for proposals and approvals of alternatives to ASME Codes, in CoC,Section II, "Design Features.

The new Appendix retains all the code alternative information previously contained in the former TS 4.2.4. There is no change to the requirements.

Therefore, the staff finds the change acceptable and the ASME code alternatives are incorporated into a new Appendix C to the CoC.

The only information not contained in the new Appendix C is the statement specifying requirements for proposals and approvals of alternatives to ASME codes. This information has been retained, verbatim, in CoC,Section II, "Design Features, subsection II.1.d, ASME Code Alternatives.

(b)

Evaluation of Change This new section explains that ASME code alternatives are in Appendix C and outlines the process for obtaining approvals for proposed code no dash

49 and number of fuel rods per assembly are significant. Therefore, removing control of these parameters in the USFAR imposes no significant risk to criticality safety, radiation protection, heat dispersion and containment. On this basis, the staff finds that this proposed changed to be acceptable.

3.2.6.2 Form No. 82. I.D. Tables, PWR fuel characteristics for NUHOMS DSCs.

(a)

Proposed Change The applicant proposed to remove the following tables from the TS.

(i)

TS Table 1-1f, PWR Fuel Assembly Design Characteristics for the NUHOMS-32PT DSC, (ii)

TS Table 1-1m, PWR Fuel Assembly Design Characteristics for the NUHOMS-24PTH DSC, (iii)

TS Table 1-1bb, PWR Fuel Assembly Design Characteristics for the NUHOMS-32PTH1 DSC, and (iv)

TS Table 1-1nn, PWR Fuel Assembly Design Characteristics for the 37PTH DSC.

The information in these tables have been moved from the TSs to the UFSAR. The corresponding UFSAR tables are Table M.2-2 (32PT), Table P.2-3 (24PTH), Table U.2-3 (32PTH1), and Table Z.2-3 (37PTH).

(b)

Evaluation of Change The staff reviewed the information in these tables and finds that the data are the name, length, fuel type [uranium dioxide (UO2)], fuel weight, and number of rods per fuel assembly. Since only the length, fissile material type, and number of fuel rods per assembly are significant. Therefore, removing control of these parameters in the USFAR imposes no significant risk to criticality safety, radiation protection, heat dispersion and containment. On this basis, the staff finds that this proposed changed to be acceptable.

3.2.6.3 Form No. 83. I.D Tables, Enrichment and B-10 requirements.

(a)

Proposed Change The applicant proposed to retain following tables which contain details of characteristic parameters for fuel, in the TS.

(i)

TS Table 1-1g, Table 1-1g1, Table 1-1g2 and Table 1-1g3, Maximum Planar Average, Enrichment, Number of PRAs and Minimum Soluble Boron Loading for the NUHOMS-32PT DSC, superscript

52 (ii)

TS Table 1-1ee, Thermal and Radiological Characteristics for Control Components Stored in the NUHOMS-32PT and NUHOMS-32PTH1 DSCs, and (iii)

TS Table 1-1qq, Characteristics of Control Components for the 37PTH DSC.

Since the control component decay heat is low in comparison with the fuel, the applicant proposed the following:

(i) delete this value from each table, and (ii) move this information to the following tables of the UFSAR: Table P.2-2 (24PTH), Table N.2-2a (24PHB), Table M.2-2a (32PT), Table U.2-2 (32PTH1), and Table Z.2-2 (37PTH).

Also, the applicant proposed to remove the decay heat limit on the control components.

(b)

Evaluation of Change The staff reviewed the applicants rational that the source limit of the control components meets the requirement of criterion No. A2 (shielding function) and therefore shall be retained and finds it to be acceptable. There is not safety impact by retaining the gamma source in the TS.

The staff finds that removing the decay heat of the control components from the TS has minimal impact because the decay heat contribution from the Co-60 in a fuel assembly at 60 GWd/MTU and 5 years of cooling time contributes only about 3% to the total decay heat [ORNL, 2001]. Similarly, the contribution to decay heat from control component is low in comparison with the spent fuel. As such, the risk of exceeding decay heat limit is low with removal of the limit on decay heat from the control component contents. On this basis, the staff finds the proposed changes to be acceptable. This approach is also consistent with deleting the fuel qualification tables from the technical specifications. In addition, because this information has been moved to the UFSAR in the following tables: Table P.2-2 (24PTH), Table N.2-2a (24PHB), Table M.2-2a (32PT), Table U.2-2 (32PTH1), and Table Z.2-2 (37PTH). To avoid duplication, parameters listed in the UFSAR tables that remain in the TS are cross referenced to the Technical Specifications. The applicant must perform a 72.48 evaluation if the decay heat for the control components is to be changed.

3.2.6.6 Form No. 89. I.D. TS-Table 1-1u, BWR fuel assembly design characteristics for the 61BTH DSC (a)

Proposed Change The applicant proposed to delete Table 1-1u from the TSs. This information is provided in the FSAR Table T.2-2.

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59 (NUREG/CR-6700)

U.S. Nuclear Regulatory Commission, Nuclide Importance to Criticality Safety, Decay Heating, and Source Terms Related to Transport and Interim Storage of High-Burnup LWR Fuel, NUREG/CR-6700, January 2001, ADAMS Accession No. ML010330186.

(NUREG/CR-6716)

U.S. Nuclear Regulatory Commission, Recommendations on Fuel Parameters for Standard Technical Specifications for Spent Fuel Storage Casks, NUREG/CR-6716, March 2001, ADAMS Accession No. ML010820352.

(NUREG/CR-6802)

U.S. Nuclear Regulatory Commission, Recommendations for Shielding Evaluations for Transport and Storage Packages, NUREG/CR-6802, May 2003, ADAMS Accession No. ML031330514 (TN, 2017a)

Bondre, Jayant, TN Americas LLC (TN), letter to U. S. Nuclear Regulatory Commission (NRC), Attn.: Document Control Desk, June 29, 2017, ADAMS Package Accession No. ML17191A227.

(TN, 2017b)

Bondre, Jayant, TN Americas LLC (TN), letter to U. S. Nuclear Regulatory Commission (NRC), Attn.: Document Control Desk, August 31, 2017, ADAMS Package Accession No. ML17249A001.

(TN, 2017c)

Bondre, Jayant, TN Americas LLC (TN), letter to U. S. Nuclear Regulatory Commission (NRC), Attn.: Document Control Desk, October 13, 2017, ADAMS Package Accession No. ML17304A278.

(TN, 2017d)

Bondre, Jayant, TN Americas LLC (TN), letter to U. S. Nuclear Regulatory Commission (NRC), Attn.: Document Control Desk, November 16, 2017, ADAMS Package Accession No. ML17325A408.

(TN, 2018a)

Bondre, Jayant, TN Americas LLC (TN), letter to U. S. Nuclear Regulatory Commission (NRC), Attn.: Document Control Desk, April 26, 2018, ADAMS Package Accession No. ML18124A195.

(TN, 2018b)

Bondre, Jayant, TN Americas LLC (TN), letter to U. S. Nuclear Regulatory Commission (NRC), Attn.: Document Control Desk, June 7, 2018, ADAMS Package Accession No. ML18162A061.

(TN, 2019a)

Bondre, Jayant, TN Americas LLC (TN), letter to U. S. Nuclear Regulatory Commission (NRC), Attn.: Document Control Desk, September 3, 2019, ADAMS Package Accession No. MLXXXXXXXX.

(TN, 2019b)

Shaw, Donis, TN Americas LLC (TN), email to García Santos, Norma, U.

S. Nuclear Regulatory Commission (NRC), September 6, 2019, ADAMS Package Accession No. ML19252A394.

(TN, 2019c)

Shaw, Donis, TN Americas LLC (TN), email to García Santos, Norma, U.

S. Nuclear Regulatory Commission (NRC), September 10, 2019, ADAMS Package Accession No. ML19253C390.

Narayanan, Prakash Don't see in ADAMs yet