ML18200A120
| ML18200A120 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 06/19/2018 |
| From: | Spent Fuel Licensing Branch |
| To: | Division of Spent Fuel Management |
| Cuadrado J | |
| Shared Package | |
| ML18200A123 | List: |
| References | |
| Download: ML18200A120 (8) | |
Text
Division of Spent Fuel Management, NMSS U.S. Nuclear Regulatory Commission Public Meeting with Holtec International June 19, 2018 Holtec HI-STORE CIS Review -
Discussion of 5/24/18 RAI responses on Aircraft Hazards
Summary
- March 28, 2018 - NRC issues request for additional information (RAI), Part 1
- RAI 2 Requests additional details on aircraft hazards assessment for HI-STORE CISF site
- May 24, 2018 - Holtec submits responses to RAIs
- NRC staff has identified issues in Holtec's response to the aircraft hazards analysis
- Proximity criteria for flight paths (NUREG-0800)
- Effective area for the facility
- Crash rate for military aircraft
- Units of measurement (statute vs. nautical)
- Descriptions of SAR Figures
Issue 1 - Proximity Criteria from NUREG-0800
- Criterion B from Section 3.5.1.6 of NUREG-0800 not met
- Proximity of military flight path to the facility requires detailed analysis
- Additional information required for detailed analysis
- Annual number of flights, crash rates for specific aircraft types, distance to site, effective area of facility needed to estimate cumulative annual crash probability
Issue 2 - Estimate of effective area of the facility
- Section 3.5.1.6, Subsection 7 of NUREG-0800 provides guidance for estimating effective area of facility
- Must include footprint area of facility, skid area for specific aircraft, and shadow area of facility structures
- Response does not include shadow area or skid area
- Only footprint area for facility is included
Issue 3 - Basis for military aircraft crash rate
- Response does not provide basis provided for assumed military aircraft crash rate
- Section 3.5.1.6, Subsection 2 of NUREG-0800 cites specific references with data on aircraft crash rates
- DOE, Accident Analysis of Aircraft into Hazardous Facilities, DOE-STD-3014-96, October 1996
Issue 4 - Units of measurement for airway distances
- RAI response should use consistent distance measurement units
- SAR Table 2.2.5 cites distances in nautical miles, compares with statute miles from FAA Sectional chart
- Analysis should consider distances to edge of airway
Issue 5 - References to SAR Figure 2.2.7
- Any figures, tables, or charts provided in the application should be adequately described
Conclusions
- NRC staff needs additional information to address RAIs on aircraft hazards and determine compliance with NRC's safety regulations
- Timely completion of NRC review of Holtec's HI-STORE CISF application requires complete and high quality responses to NRC staff's questions