ML18046A067
| ML18046A067 | |
| Person / Time | |
|---|---|
| Issue date: | 12/21/2017 |
| From: | Manzione K Holtec |
| To: | May Ma Rules, Announcements, and Directives Branch, Document Control Desk |
| References | |
| 82FR49233 00007, NRC-2016-0238 | |
| Download: ML18046A067 (3) | |
Text
HOLTEC INTERNATIONAL December 21, 2017 May Ma Office of Administration Mail Stop: OWFN-2-A 13 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-000 I Holtec Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909
Subject:
Holtec International Comments on Draft NUREG-2214, Managing Aging Processes in Storage (MAPS)
Reference:
[I] NRC-20 I 6-0238. Draft "Managing Aging Processes in Storage Report,'* dated October 24, 20 I 7
Dear Ms. Ma:
Holtec International appreciates the oppo11unity to comment on the NRCs draft '"Managing Aging Processes in Storage repo11 [I]. Hoitec is currently involved in aging management work related to our system, and we appreciate the staffs guidance document.
Holtec has pa11icipated with the industry comment consolidation and supports the comments submitted by the Nuclear Energy Institute. However, because portions of the report discuss specifics of the Holtec systems and designs, we would like to offer the attached comments for the staffs consideration on the Holtec specific information.
If you have any questions please contact me at 856-797-0900 ext 395 I.
Sincerely, Kimberly Manzione Licensing Manager, Holtec International cc:
(via email)
Mr. John McKirgan, USNRC Mr. Michael Layton. USNRC Mr. Meraj Rahimi, USNRC Document ID 5014832.
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HOLTEC INTERNATIONAL Holtec Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 C
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. d f NUREG2,..,14 omments on o tee spec1 1c items 111 ra t I
Location fo Docll.llmeltllt Page 4-94. lines 28 and 29 Page 4-99. line 20 Page 4-106, Table 4-7, "Basket Supports
Page 4-108. Table 4-7.
"'Vent and drain tubes'*
Page 4-109, Table 4-7,
- Damaged Fuel Container" Page 4-109, Table 4-7, "Threaded disc plug adjustment" Page 4-1 I I, Table 4-8, "Lid inner ring" Page 4-111, Table 4-8,
- 'Lid outer ring
Page 4-112, Table 4-8,
'*Outer Shell
Page 4-1 13, Table 4-8, "Inner shell, lid bottom plate, and lid shell" Page 4-115, Table 4-8, "Lid Stud" Page 4-119, Table 4-8, "Closure lid steel (HI-STORM 1 OOU)"
Page 4-129, Table 4-9, "Inner Shell
Page 4-132, Table 4-9, "Intermediate Shells" Document ID 5014832 Page 2 of3 CommeBllt Suggest also noting that the enclosed helium also provides an inert environment that makes corrosion issues non-credible.
The statement says that the pool lid incorporates two gasket seals.
however. the remainder of the sentence correctly notes that those seals are actu~lly one between the pool lid and bottom flange and a second between the MPC and transfer cask. near the top. Suggest removing the '*pool lid incorporates two gasket seals, statement.
The table does not include the "Basket Shim" component (used only in the MPC-68M). which have a thermal function. However, they are stored in the same inert environment, so no aging management is expected to be needed.
The table identifies these as having a structural function, but these components are not credited with any structural function. These components are only used during initial loading and drying, and are not necessary for long term storage.
The table identifies that the Damaged Fuel Container has a confinement "CO" function. However, the DFCs have screens at the top and bottom and are not credited as a confinement boundary. It may be more appropriate to add a criticality function to the DFCs, as they are credited in that analysis.
These components are not credited as part of the confinement boundary for the MPC.
The lid inner ring is also credited for shielding.
The lid outer ring also has a structural function.
The outer shell is also credited for shielding.
These components are also credited for shielding.
The material for the lid stud appears to be incomplete, see the HI-STORM I 00 FSAR Table 2.2.6.
This component is also credited in the structural analysis for missile protection.
The inner shell also provides a structural function, and a thermal function due to heat conduction.
The intermediate shells also provide a thermal function.
HOL TEC INTERNATIONAL Location fo Document Page 4-132. Table 4-9,
- Removable Shear Ring'*
Page 4-133. Table 4-9.
Pocket trunnion
Page 4-134, Table 4-9, "Lifting trunnion" Page 4-135, Table 4-9, "Enclosure shell panels and enclosure shell return**
Page 4-144. Table 4-10, "Top lid Shielding" Page 4-144, Table 4-10, "Fill port plugs" Document JD 5014832 Page 3 of 3 Holtec Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Comment Telephone (856) 797-0900 Fax (856) 797-0909 The removable shield ring does not have a shielding function; its primary safety function is structural.
The main intended safety function of the pocket trunnions is structural.
The lifting trunnions are also credited in shielding.
These components also provide a thermal and shielding purpose.
This component does not have a thermal function.
This component does not have a shielding function.