ML25003A178
| ML25003A178 | |
| Person / Time | |
|---|---|
| Site: | 07201015 |
| Issue date: | 03/10/2025 |
| From: | Boyce T Storage and Transportation Licensing Branch |
| To: | Andrew Carrera NRC/NMSS/DREFS |
| Shared Package | |
| ML25003A177 | List: |
| References | |
| 001028, EPID L-2023-LLA-0154 | |
| Download: ML25003A178 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 MEMORANDUM TO: Andrew Carrera, Acting Chief Materials Rulemaking and Project Management Branch Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards FROM:
Thomas H. Boyce, Acting Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
USER NEED FOR RULEMAKING FOR AMENDMENT NOS. 5 THROUGH 9, REVISON 1, AND AMENDMENT NO. 10 OF THE RENEWED CERTIFICATE OF COMPLIANCE NO. 1015 FOR THE NAC-UMS UNIVERSAL STORAGE SYSTEM The purpose of this communication is to request support for rulemaking activities in the Division of Fuel Management (DFM) for the following Title 10 of the Code of Federal Regulations (10 CFR) Part 72 certification action:
1.
Changes to the 10 CFR 72.214 rule text (changes appear in bold):
Certificate Number: 1015.
Initial Certificate Effective Date: November 20, 2000, superseded by Renewed Initial Certificate Effective Date: July 15, 2024.
Amendment Number 1 Effective Date: February 20, 2001, superseded by Renewed Amendment Number 1 Effective Date: July 15, 2024.
Amendment Number 2 Effective Date: December 31, 2001, superseded by Renewed Amendment Number 2 Effective Date: July 15, 2024.
Amendment Number 3 Effective Date: March 31, 2004, superseded by Renewed Amendment Number 3 Effective Date: July 15, 2024.
CONTACT: Norma Garcia-Santos, NMSS/DFM 301-415-6999 March 10, 2025 Signed by Boyce, Thomas on 03/10/25
A. Carrera 2
Amendment Number 4 Effective Date: October 11, 2005, superseded by Renewed Amendment Number 4 Effective Date: July 15, 2024.
Amendment Number 5 Effective Date: January 12, 2009, superseded by Renewed Amendment Number 5 Effective Date: July 15, 2024, superseded by Renewed Amendment Number 5, Revision 1 Effective Date: [insert 75 days from date of Federal Register (FR) publication].
Amendment Number 6 Effective Date: January 7, 2019, superseded by Renewed Amendment Number 6 Effective Date: July 15, 2024, superseded by Renewed Amendment Number 6, Revision 1 Effective Date: [insert 75 days from date of FR publication].
Amendment Number 7 Effective Date: July 29, 2019, superseded by Renewed Amendment Number 7 Effective Date: July 15, 2024, superseded by Renewed Amendment Number 7, Revision 1 Effective Date: [insert 75 days from date of FR publication].
Amendment Number 8 Effective Date: October 19, 2021, as corrected (ADAMS Accession No. ML21312A499); superseded by Renewed Amendment Number 8 Effective Date: July 15, 2024; superseded by Renewed Amendment Number 8, Revision 1 Effective Date: [insert 75 days from date of FR publication].
Amendment Number 9 Effective Date: August 29, 2022, superseded by Renewed Amendment Number 9 Effective Date: July 15, 2024, superseded by Renewed Amendment Number 9, Revision 1 Effective Date: [insert 75 days from date of FR publication].
Renewed Amendment Number 10 Effective Date: [insert 75 days from date of FR publication]
Safety Analysis Report (SAR) Submitted by: NAC International, Inc.
Title:
Final Safety Analysis Report for the NAC-UMS Universal Storage System.
Docket Number: 72-1015.
Renewed Certificate Expiration Date: November 20, 2060.
Model Number: NAC-UMS.
2.
Purpose and scope of the Revisions:
By application dated October 10, 2023 (Agencywide Documents Access and Management System [ADAMS] Accession Nos. ML23283A249 and ML23291A095), as supplemented on February 13, 2024 (ML24044A221), June 26, 2024 (ML24179A058),
December 19, 2024 (ML25021A284), and January 14, 2025 (ML25014A450), NAC International (NAC or the applicant) submitted a request for Amendment No. 10, and Revision to Amendment Nos. 5 through 9, of the renewed Certificate of Compliance (CoC) No. 1015 for the NAC-UMS Universal Storage System (NAC-UMS). The
A. Carrera 3
application includes proposed changes to correct design basis deficiencies identified in the NAC letter dated March 10, 2023 (ML23069A215).
The proposed changes for Amendment No. 10 and the Revisions to Amendment Nos. 5 through 9 include the following:
a.
Revise a parameter used in the computation of bending stress in the finite element model used to structurally evaluate a fuel rod under the non-mechanistic tip-over accident condition.
b.
Update the pressurized-water reactor (PWR) end drop evaluation using the methodology already approved for the boiling-water reactor (BWR) end drop evaluation.
c.
Change the address in the CoC to reflect the new address of the applicants headquarters offices.
3.
Proposed Backfitting Discussion for the Direct Final Rule for the Revisions to renewed CoC No. 1015, Amendment Nos. 5 through 9.
This direct final rule revises Amendment Nos. 5 through 9 of the renewed CoC No. 1015 for the NAC-UMS system, as currently listed in 10 CFR 72.214, List of approved spent fuel storage casks. Revision 1 to Amendment Nos. 5 through 9 to renewed CoC No.
1015 would:
a.
Revise a parameter used in the computation of bending stress in the finite element model used to structurally evaluate a fuel rod under the non-mechanistic tip-over accident condition.
b.
Update the PWR end drop evaluation using the methodology already approved for the BWR end drop evaluation.
c.
Change the address in the CoC to reflect the new address of the applicants headquarters offices.
For the following reasons, the NRC has determined that the regulations in 10 CFR 72.62, Backfitting, do not apply to this direct final rule.
NAC has manufactured casks under existing CoC No. 1015, Amendment Nos. 5 through 9, that are being revised by this final rule. As the vendor, NAC is not within the scope of the backfitting provisions in 10 CFR 72.62.
Under 10 CFR 72.62, general licensees are entities that are within the scope of the backfitting regulations. However, according to NAC (ML25021A284), no general licensees are currently using NAC-UMS systems under CoC No. 1015, Amendment Nos. 5 and 8, which are, in part, the subject of these revisions. Therefore, because CoC No. 1015, Amendment Nos. 5 and 8 are not in use by any licensee, the changes in the revisions for CoC No. 1015, Amendment Nos. 5 and 8, which are approved in this direct final rule, do not fall within the definition of backfitting under 10 CFR 72.62.
A. Carrera 4
Maine Yankee Atomic Power Company at its Maine Yankee independent spent fuel storage installation (ISFSI) is the only general licensee using Amendment No. 6 that could be affected by the issuance of Revision 1 to Amendment No. 6. In its letter to NAC (ML23283A249), Maine Yankee Atomic Power Company stated that it intends to adopt the revision to Amendment No. 6, following the NRC approval and issuance. Therefore, because the licensee voluntarily intends to implement the revision, the issuance of Revision 1 to Amendment No. 6 does not fall within the definition of backfitting under 10 CFR 72.62. In its subsequent letter to the NRC (ML24094A060), Maine Yankee Atomic Power Company stated that it plans to adopt Amendment No. 9 to CoC No. 1015 as part of its work to adopt the renewed CoC No. 1015. In its email to the NRC (ML25031A348) Maine Yankee Atomic Power Company stated that it also intends to adopt the revision to Amendment No. 9, following NRC approval and issuance.
Therefore, because the licensee voluntarily intends to implement the revision, the issuance of Revision 1 to Amendment No. 9 does not fall within the definition of backfitting under 10 CFR 72.62.
Duke Energy at the Catawba and McGuire ISFSIs is the only general licensee using Amendment No. 7 that could be affected by the issuance of Revision 1 to Amendment No. 7. In its letter to NAC (ML23283A249), Duke Energy stated that instead of adopting the revision to the amendment, Catawba and McGuire will be adopting the latest amendment for the NAC-UMS system, CoC No. 1015, Amendment 10 after approval from the NRC has been received. Therefore, because the licensee voluntarily intends to adopt the latest Amendment No. 10, the issuance of Revision 1 to Amendment No. 7 does not fall within the definition of backfitting under 10 CFR 72.62.
Arizona Public Service Company at the Palo Verde ISFSI is the only general licensee currently using Amendment No. 9 that could be affected by the issuance of Revision 1 to Amendment No. 9. In its communications to NAC (ML23283A249 and ML25014A450),
Arizona Public Service Company stated that it intends to adopt Amendment No. 9, Revision 1, once approved. Therefore, because the licensee voluntarily intends to adopt the revision, the issuance of Revision 1 to Amendment No. 9 does not fall within the definition of backfitting under 10 CFR 72.62.
4.
The proposed CoCs, technical specifications, and preliminary safety evaluation report have been placed in ADAMS (see references below) and are available for your use in the rulemaking package. DFM will designate these documents as Official Agency Records after the Executive Director for Operations has approved the package (ML25003A177).
The Office of the General Counsel has reviewed this memorandum with its referenced documents and has no legal objection to its contents.
Docket No.: 72-1015 CAC No.: 001208 EPID No: L-2023-LLA-0154 ADAMS
References:
1.
Renewed Certificate of Compliance No. 1015, Amendments 5 to 9, Revision 1, and Amendment 10 for the Model No. NAC-UMS Storage System (ML25003A177)
A. Carrera 5
2.
User Need Memo for Amendment Nos. 5 through 9, Revision 1, and Amendment No. 10 of the Renewed Certificate of Compliance No. 1015 for the NAC-UMS Universal Storage System (ML25003A178) 3.
Proposed Renewed CoC No. 1015, Amendment No. 5, Revision 1 (ML25003A180) 4.
Proposed Renewed CoC No. 1015, Amendment No. 5, Revision 1, Appendix A (ML25003A181) 5.
Proposed Renewed CoC No. 1015, Amendment No. 5, Revision 1, Appendix B (ML25003A182) 6.
Proposed Renewed CoC No. 1015, Amendment No. 6, Revision 1 (ML25003A183) 7.
Proposed Renewed CoC No. 1015, Amendment No. 6, Revision 1, Appendix A (ML25003A184) 8.
Proposed Renewed CoC No. 1015, Amendment No. 6, Revision 1, Appendix B (ML25003A185) 9.
Proposed Renewed CoC No. 1015, Amendment No. 7, Revision 1 (ML25003A186) 10.
Proposed Renewed CoC No. 1015, Amendment No. 7, Revision 1, Appendix A (ML25003A187) 11.
Proposed Renewed CoC No. 1015, Amendment No. 7, Revision 1, Appendix B (ML25003A188) 12.
Proposed Renewed CoC No. 1015, Amendment No. 8, Revision 1 (ML25003A189) 13.
Proposed Renewed CoC No. 1015, Amendment No. 8, Revision 1, Appendix A (ML25003A190) 14.
Proposed Renewed CoC No. 1015, Amendment No. 8, Revision 1, Appendix B (ML25003A191) 15.
Proposed Renewed CoC No. 1015, Amendment No. 9, Revision 1 (ML25003A192) 16.
Proposed Renewed CoC No. 1015, Amendment No. 9, Revision 1, Appendix A (ML25003A193) 17.
Proposed Renewed CoC No. 1015, Amendment No. 9, Revision 1, Appendix B (ML25003A194) 18.
Proposed Renewed CoC No. 1015, Amendment No. 10 (ML25003A195) 19.
Proposed Renewed CoC No. 1015, Amendment No. 10, Appendix A (ML25003A196) 20.
Proposed Renewed CoC No. 1015, Amendment No. 10, Appendix B (ML25003A197) 21.
Preliminary Safety Evaluation Report, Model No. NAC-UMS Universal Storage System, Renewed CoC No. 1015, Amendment Nos. 5 through 9, Revision 1, and Amendment No.
10 (ML25029A237)