ML18292A523

Letter to K. Manzione Acceptance Review of Request for Amendment No. 13 to Certificate of Compliance No. 1014 for the HI-STORM 100 Multipurpose Canister Storage System - Request for Supplemental Information (W/Enclosure)

ML18292A523
Person / Time
Site:	Holtec
Issue date:	10/19/2018
From:	Siva Lingam Spent Fuel Licensing Branch
To:	Manzione K Holtec
Lingam S
References
EPID L-2018-LLA-0202
Download: ML18292A523 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 19, 2018 Kimberly Manzione Licensing Manager Nuclear Power Division Holtec International One Holtec Drive Marlton, NJ 08053

SUBJECT:

ACCEPTANCE REVIEW OF REQUEST FOR AMENDMENT NO. 13 TO CERTIFICATE OF COMPLIANCE NO. 1014 FOR THE HI-STORM 100 MULTIPURPOSE CANISTER STORAGE SYSTEM - REQUEST FOR SUPPLEMENTAL INFORMATION

Dear Ms. Manzione:

By letter dated July 18, 2018 (Agencywide Document Access and Management System (ADAMS) Accession No. ML18205A179), Holtec International (Holtec) submitted an amendment request to the U.S. Nuclear Regulatory Commission (NRC) to revise Certificate of Compliance (CoC) No. 1014 for the HI-STORM 100 Multipurpose Canister Storage System.

The NRC staff has performed an acceptance review of your application and determined that the amendment application does not provide sufficient technical information to begin a detailed review and that supplemental information is needed. The information needed to continue our review is described in the enclosed request for supplemental information (RSI). We also added an observation. Please note that most of these RSIs were discussed during the public meeting held on September 12, 2018 (ADAMS Accession No. ML18240A302).

In order to schedule our technical review, responses to the enclosed RSIs, should be provided within 30 days from the date of this letter as mutually agreed on October 9, 2018. If the information described is not received by this date, the application may not be accepted for review. If you are unable to meet this deadline, please notify us in writing, at least one week in advance, of your new submittal date and the reasons for the delay.

K. Manzione Please reference Docket No. 72-1014 and EPID No. L-2018-LLA-0202 in future correspondence related to this licensing action. If you have any questions, please contact me at (301) 415-1564.

Sincerely,

/RA/

Siva P. Lingam, Project Manager Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-1014 EPID No.: L-2018-LLA-0202

Enclosure:

RSIs

K. Manzione

SUBJECT:

ACCEPTANCE REVIEW OF REQUEST FOR AMENDMENT NO. 13 TO CERTIFICATE OF COMPLIANCE NO. 1014 FOR THE HI-STORM 100 MULTIPURPOSE CANISTER STORAGE SYSTEM - REQUEST FOR SUPPLEMENTAL INFORMATION, DOCUMENT DATE: October 19, 2018 File location: G:\SFST\HI-STORM 100\Amendment 13\RSIs\HI-STORM 100 Amd 13 RSIs ltr.docx ADAMS No.: ML18292A523 OFFICE: DSFM DSFM DSFM DSFM DSFM WWheatley JIreland YDiaz-Sanabria NAME: SLingam JMcKirgan (via email) (via email) (via email)

DATE: 10/9/18 10/9/18 10/10/18 10/11/18 10/19/18 OFFICIAL RECORD COPY

Request for Supplemental Information Docket No. 72-1014 Certificate of Compliance No. 1014 Amendment No. 13 to the HI-STORM 100 Multipurpose Canister Storage System By letter dated July 18, 2018 (Agencywide Document Access and Management System Accession No. ML18205A179), Holtec International (Holtec, the applicant) submitted an amendment request to the U.S. Nuclear Regulatory Commission (NRC) to revise Certificate of Compliance (CoC) No. 1014 for the HI-STORM 100 Multipurpose Canister (MPC) Storage System.

This request for supplemental information (RSI) identifies information needed by the NRC staff in connection with its acceptance review of the HI-STORM 100 MPC Storage System application to confirm whether the applicant has submitted a complete application in compliance with regulatory requirements.

NUREG-1536, Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility Final Report, was used by the staff in its review of the application. Each of the following questions describes information needed for the staff to begin a detailed review.

Most of these RSIs were discussed during the public meeting held on September 12, 2018 (ADAMS Accession No. ML18240A302).

Chapter 5 - Confinement Evaluation RSI 5-1 Provide a summary of:

a. all design and operational changes described in the licensing basis for the HI-STORM 100 cask system from Amendment No. 2 forward, and

b. the information to be included in the necessary evaluations that each site will perform.

c. Based on the information provided in responses to (a) and (b), demonstrate that there is no safety impact on the overall performance of the HI-STORM 100 storage system by upgrading loaded casks under Amendment Nos. 2 through 7 to the requested amendment.

The applicant stated, in the reason for the proposed change request No. 1, that the ability for sites to upgrade to the latest amendment provides an operational benefit to sites (particularly shut-down sites). However, the applicant did not identify, or provide evidence, that design or operational changes that are part of the licensing basis (e.g. CoC and Technical Specifications (TS)) would not have any effects on the safety and the overall performance of the HI-STORM 100 storage systems in place under Amendment No. 2 and forward.

The applicant stated, in the justification for the proposed change request No. 1, that the site would perform, necessary evaluations, however, the scope of those evaluations was not described.

Enclosure

This information is needed to determine compliance with Title 10 of the Code of Federal Regulations (10 CFR), Section 72.244, Application for amendment of a certificate of compliance.

RSI 5-2 Provide a discussion of the staffs evaluations of:

a. the previously analyzed detectible leak rate, and the loss of helium in a canister, which could result from a leak of this magnitude,

b. the effects on a canisters ability to reject heat under such a condition, and

c. the results of monitoring of radiation levels at each independent spent fuel storage installation (ISFSI) that demonstrates that there is no significant radioactive release from the canisters.

d. In addition, considering the above, provide similar information on the current state of the HI-STORM 100 storage systems loaded under Amendment Nos. 2 through 7. Alternatively, demonstrate how the staffs previous evaluations of HI-STORM 100 storage systems loaded under Amendment Nos. 2 through 7 remain applicable and, if appropriate, are bounding for the current state of the loaded canisters.

For the information provided, a demonstration of how it forms part of the licensing basis for this amendment should be provided.

The applicant stated, in the justification for proposed change request No. 1, that, for the canisters loaded under Amendment Nos. 2 through 7, the previously analyzed detectible leak rate, the loss of helium from the canister resulting from a leak of this magnitude, and the effects on the canisters ability to reject heat under such a condition, were documented in letters to the NRC. The applicant also stated, in the justification for proposed change request No. 1, that monitoring of the radiation levels at ISFSIs demonstrates that there is no significant radioactive release from the currently deployed canisters that were loaded under Amendment Nos. 2 through 7.

The staff assumes that this information was related to Enforcement Action EA-09-190, Exercise of enforcement discretion - Holtec International, dated August 5, 2009 (ADAMS Accession No. ML092180140). The applicant did not provide the letters from the sites, or the staffs evaluations of the letters, nor did the applicant summarize how the staffs evaluations form part of the licensing basis for this amendment. It is not clear from the amendment request if the staffs evaluations could form part of the licensing basis for canisters loaded under Amendment Nos. 2 through 7 that did not include a requirement to helium leak test the base metal used for the MPC lids.

The staffs review of our evaluations made related to EA-09-190 include numerous documents.

(These include, but may not be limited to, documents with the following ADAMS Accession Nos.: ML100140070, ML101060436, ML101600314, ML102450015, ML111880156, ML111880244, and ML110270139). In the first document, the NRC stated, Your technical justification for continued use of the loaded cask systems evaluated the thermal and radiological performance of the casks and concluded that the casks would continue to meet all of their required functions. The justification relied upon an assumed leakage rate from the casks, and utilized a dose assessment methodology that credited gravitational settling to reduce calculated release estimates. The NRC does not have any data to confirm the acceptability of your assumed cask leakage rates, and has not previously reviewed or endorsed the methodology used in your response for calculating the site dose rates attributed to postulated leakage from the casks. The NRC concluded that while your response provides supplemental information to support the continued safe operation of the casks, additional site specific information is needed to ensure that the loaded casks will continue to meet all regulatory requirements.

In the last six documents, based on specific site data as requested during a teleconference on December 1, 2009 (ADAMS Accession No. ML093510008), the staff determined, [] the continued use of the loaded MPCs at the sites is acceptable, and the NRC does not plan any further action with respect to the continued use of these MPCs.

The applicant also did not provide any additional similar site-specific information on the current state of the loaded canisters from Amendment Nos. 2 through 7 to demonstrate that the staffs evaluations following EA-09-190 remain applicable, are bounding for the current state of the loaded canisters, and form part of the licensing basis for this amendment to demonstrate that the deployed canisters provide adequate heat removal capacity in addition to showing that the confinement features must be provided sufficient to meet 10 CFR 72.104, Criteria for radioactive materials in effluents and direct radiation from an ISFSI or MRS [monitored retrievable storage], with no increase in radiological effluents.

This information is needed to determine compliance with 10 CFR 72.236, Specific requirements for spent fuel storage cask approval and fabrication, items (d) and (f).

RSI 5-3 Clarify the following information regarding the Amendment Nos. impacted by proposed change request No. 1:

a. State whether any MPCs were loaded under the original CoC, Rev. 0 (ADAMS Accession No. ML003711932) and Amendment No. 1 (ADAMS Accession No. ML022000214).

b. If necessary, provide changes to the CoC, TS, and safety analysis report (SAR) to better align with the proposed change request No. 1 that indicates the proposed change is for Amendment Nos. 2 through 7 only.

The proposed change request No. 1 does not indicate if canisters loaded under the original CoC and Amendment No. 1 should be affected by this proposed change. The applicants proposed CoC change under condition 3 states, Casks previously loaded to Amendment 7 and all prior amendments are exempt from this requirement and must meet the requirements of the amendment to which they were loaded.

However, the justification for proposed change request No. 1 indicates the proposed change is for Amendment Nos. 2 through 7.

Similar language that describes casks previously loaded to Amendment No. 7 and all prior amendments appears on pages 2-2, 2-5, 2-174, 9-10, and 9-18 of the SAR, in addition to page 3.1.1-1 of Appendix A of the TS. These pages should be modified to better reflect the proposed change request No. 1.

This information is needed to determine compliance with 10 CFR 72.244.

RSI 5-4 Clarify that the confinement boundary weldment was not leak tested at fabrication on the HI-STORM 100 for Amendment Nos. 2 through 7.

The reason for proposed change request No. 1 states the licensing basis for canisters loaded under CoC Amendment Nos. 2 through 7 did not include a requirement to helium leak test the base metal used for the MPC lids; however, EA-09-190 states that there was a change to the final safety analysis report (FSAR) for CoC No. 1014 that eliminated a helium leak rate test of the MPC confinement boundary weldment at fabrication. The proposed change request should clearly describe what was not leakage rate tested for each MPC loaded under Amendment Nos. 2 through 7.

This information is needed to determine compliance with 10 CFR 72.244.

RSI 5-5 Revise the proposed change language for the CoC under Condition 3 to better reflect proposed change request No. 1.

The proposed change language under CoC Condition 3 states, Casks previously loaded to Amendment 7 and all prior amendments are exempt from this requirement and must meet the requirements of the amendment to which they were loaded.

The staff suggests the following language to better reflect proposed change request No. 1.

Casks loaded prior to July 1, 2009, to Amendment Nos. 2 through 7 are grandfathered and therefore not required to comply with the above helium leak test requirements.

Casks fabricated and loaded after July 1, 2009, must comply with the above helium leak test requirement.

There may be a need to continue to revise the proposed language above based on the results of the staffs evaluation of the proposed change No. 1.

The date of July 1, 2009, came from the Reply to EA-09-190 (ADAMS Accession No. ML0924703631), which states, Leakage testing has been reinstated at the manufacturing facility for all MPCs currently being fabricated or in storage. Leakage tested on newly fabricated MPCs was reinstated on July 1, 2009.

Proposed change request No. 1 does not change the fact that all casks are required to comply with CoC Condition 3, which states, Written cask acceptance tests and maintenance program shall be prepared consistent with the technical basis described in Chapter 9 of the FSAR.

The staff suggests that the sentence above form a separate paragraph from the paragraph on leakage rate testing under CoC Condition 3.

This information is needed to determine compliance with 10 CFR 72.244.

RSI 5-6 Revise Page 3.1.1-1 of TS Appendix A to remove outdated language related to HI-STORM 100 Amendment No. 12 proposed change request No. 5.

Page 3.1.1-1 of TS Appendix A includes outdated language from HI-STORM 100 Amendment No. 12 proposed change request No. 5 that was removed prior to the submittal of this amendment request.

This information is needed to determine compliance with 10 CFR 72.244.

Observation 5-1 Clarify the number of canisters that were not leakage rate tested.

It should be clear how many canisters are impacted by this amendment request.

Enforcement Action EA-09-190 states, This issue is considered to be of greater than minor significance since approximately 120 MPCs were loaded without being adequately tested to demonstrate their leaktightness.

The reply to EA-09-190 (ADAMS Accession No. ML092470363) states,

[] 107 MPCs were manufactured and loaded without fabrication leakage testing being performed.

Evaluations of non-helium leak rate testing of Holtec MPCs by the staff, (described in documents with ADAMS Accession Nos. ML101060436, ML102450015, ML111880156, ML111880244, and ML110270139), found that, in total, 82 canisters were loaded without helium leak rate testing of welded confinement boundaries on MPCs after fabrication; however, the continued use of these loaded MPCs (at the sites specifically addressed in the letters) was acceptable to the staff.

Despite the staffs findings, the, Response to NRC's Request for Disposition of Non-Helium Leak Tested Holtec Multi-Purpose Canisters (MPCs) as Discussed in EA-09-190, Exercise of Enforcement Discretion - Holtec International, (ADAMS Accession No. ML100350810) and the, Evaluation of non-helium leak rate test of Holtec Multi-Purpose Canisters (MPCs) (ADAMS Accession No. ML101600314), do not describe the number of canisters that were loaded with the change in leak test requirements.

It is also not clear if the same number of canisters, or more, did not have the MPC lid base material leakage rate tested.

This information is needed to determine compliance with 10 CFR 72.236(d), (f), and (j).