ML19015A333

Letter to J. Tomlinson Amendment No. 14 to Certificate of Compliance No. 1014 for the HI-STORM 100 Multipurpose Canister Storage System - Request for Additional Information (W/Enclosure 1)

ML19015A333
Person / Time
Site:	Holtec
Issue date:	01/24/2019
From:	Yen-Ju Chen Spent Fuel Licensing Branch
To:	Tomlinson J Holtec
Chen Y
References
CAC 001028, EPID L-2018-LLA-0292
Download: ML19015A333 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 24, 2019 Ms. Joyce Tomlinson Adjunct Licensing Manager Holtec International Holtec Technology Campus One Holtec Boulevard Camden, NJ 08104

SUBJECT:

AMENDMENT NO. 14 TO CERTIFICATE OF COMPLIANCE NO. 1014 FOR THE HI-STORM 100 MULTIPURPOSE CANISTER STORAGE SYSTEM -

REQUEST FOR ADDITIONAL INFORMATION

Dear Ms. Tomlinson:

By letter dated October 31, 2018 [Agencywide Document Access and Management System (ADAMS) Accession No. ML18331A056] and supplemented by a letter dated November 6, 2018 (ADAMS Accession No. ML18324A577), Holtec International submitted an amendment request to the U.S. Nuclear Regulatory Commission for the HI-STORM 100 Multipurpose Canister Storage System Certificate of Compliance (CoC) No. 1014.

Your letter requested an effective date of October 2019 for this amendment to facilitate the decommissioning of the Pilgrim Nuclear Power Station. The NRC staff has decided to accept the application for review and established a schedule for the review. The schedule allows the staff to complete a draft certificate of compliance and safety evaluation report for rulemaking in May 2019, based on having only one request for additional information (RAI) and Holtec satisfactorily responding to the RAI within 30 days of RAI issuance. The staff estimates that completing the safety review of this certificate amendment application will require approximately 750 staff review hours.

The NRC staff reviewed your application and determined the need for additional information as identified in the RAI in the enclosure to this letter. We request that you provide the responses to these RAIs within 30 days from the date of this letter. If you are unable to meet this deadline, please notify us in writing, within two weeks of receipt of this letter, of your new submittal date and the reasons for the delay.

During the review, Holtec communicated with the staff that it plans to remove Editorial Change B, which updates Drawing 7195, from Amendment No. 14. Therefore, the attached RAI does not include staffs questions on the proposed Drawing 7195. The removal of Editorial Change B should be reflected in your response to the attached RAI.

J. Tomlinson Please reference Docket No. 72-1014, CAC No. 001028, and EPID No. L-2018-LLA-0292 in future correspondence related to this licensing action. If you have any questions, please contact me at 301-415-1018.

Sincerely,

/RA/

Yen-Ju Chen, Sr. Project Manager Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-1014 CAC No.: 001028 EPID No.: L-2018-LLA-0292

Enclosures:

1. RAI

2. RAI (Proprietary)

ML19024A034 (package) ML19015A333 (letter)

• concur via email OFFICE: DSFM DSFM DSFM DSFM DSFM DSFM NAME: YChen WWheatley* PKoch* JChang* JSmith* TAhn*

DATE: 1/15/2019 1/17/2019 1/16/2019 1/23/2019 1/17/2019 1/18/2019 OFFICE: DSFM DSFM DSFM DSFM DSFM ASotomayor- DDunn* for NAME: Rivera*

CBajwa* TTate* JMcKirgan MRahimi DATE: 1/15/2019 1/23/2019 1/23/2019 1/18/2019 1/24/2019 Request for Additional Information Docket No. 72-1014 Holtec International HI-STORM 100 Multipurpose Canister Storage System Certificate of Compliance No. 1014 Amendment No. 14 By letter dated October 31, 2018 [Agencywide Document Access and Management System (ADAMS) Accession No. ML18331A056] and supplemented by a letter dated November 6, 2018 (ADAMS Accession No. ML18324A577), Holtec International submitted an amendment request to the U.S. Nuclear Regulatory Commission for the HI-STORM 100 Multipurpose Canister Storage System Certificate of Compliance (CoC) No. 1014. The proposed changes include adding three new load patterns to MPC-68M, reducing the cooling time to 1 year for all fuel types for storage in MPC-68M, using damaged fuel isolator (DFI) for damaged fuel stored in MPC-68M, and modifying the description of the vents in the overpack in the CoC.

The staff identified additional information needed in connection with its review of the application as provided in the request for additional information discussed below. Each question describes information needed by the staff to complete its review of the application and to determine whether the applicant has demonstrated compliance with regulatory requirements in 10 CFR Part 72.

Chapter 3 Structural Evaluation RAI 3-1. Provide an evaluation demonstrating that the DFI will perform its intended function of constraining fissile material during credible accident conditions (e.g., non-mechanistic tip over or seismic event).

Section 2.1.3.1 of the application states that the DFI caps are geometrically constrained to prevent their ejection from the storage cavity during a postulated accident event.

However, no analysis is presented in the application to support this claim. The applicant needs to demonstrate that the DFI will adequately perform this behavior.

The staff needs this information to determine compliance with the requirements of 10 CFR 72.236(l).

RAI 3-2. Provide drawings of the DFI top and bottom caps with dimensions, tolerances, materials of construction and location relative to the basket.

Section 2.1.3.1 of the application states that the DFI caps are prismatic boxes with flat baseplates which fit inside the storage cell space with a small clearance for ease of installation and are geometrically constrained to prevent their ejection from the storage cavity during a postulated accident event. However, it is unclear from this description or the drawings in Figure 2.1.10, what the dimensions, materials, tolerances, etc. are for the DFI caps. These details are needed to assess the ability of the DFI caps to remain in place and constrain fissile material during a credible accident.

The staff needs this information to determine compliance with the requirements of 10 CFR 72.146(a) and 72.150.

Enclosure 1

2 Chapter 4 Thermal Evaluation RAI 4-1. See Enclosure 2.

RAI 4-2. See Enclosure 2.

RAI 4-3. Revise Table 3-1 and its notes in Appendix A, Technical Specifications (TS), for clarification of the heat load limits on the proposed QSHL-2, QSHL-3, and QSHL-4 patterns.

The applicant should revise the last row of Appendix A, TS, Table 3-1 (and its notes), as below, for clarification of the heat load limits on the proposed QSHL-2, QSHL-3, and QSHL-4 patterns:

Keep table entry 42.8 (MPC-68M)Note 7 unchanged (with Note 7 stating: Maximum per assembly allowable heat loads defined in Appendix B Figure 2.4-1.) and add table entry 38.9 (MPC-68M)Note 8 (with Note 8 stating: Maximum per assembly allowable heat loads defined in Appendix B Figures 2.4-2 through 2.4-4.).

The staff needs this information to determine compliance with the requirements of 10 CFR 72.236(f).

Chapter 8 Materials Evaluation RAI 8-1.

(a) Clarify the condition of the fuel assemblies proposed to be stored utilizing the DFI, given the current design bases and the technical specification definition for damaged fuel assembly.

(b) Clarify whether the DFI provides the ability to handle the fuel assemblies to be stored within it by normal means under both normal and off-normal conditions.

(c) Provide operational descriptions and procedures for use, loading, and unloading of the DFI.

(d) Provide the corresponding revised FSAR page changes, including changes to the operating procedures in Chapter 8 of the FSAR.

The applicant proposes to use the DFI in place of the DFC for damaged fuel assemblies with certain physical defects (e.g., missing or partial fuel rods, a breach in the fuel cladding or a structural failure in the grid strap assembly). The applicant also states that the DFI is to be used only with damaged fuel assemblies that can be handled by normal means and whose structural integrity is such that geometric rearrangement of the fuel is not expected.

However, the current technical specifications define a damaged fuel assembly as an assembly whose structural integrity has been impaired such that geometric rearrangement of fuel or gross failure of the cladding is expected based on engineering evaluations, or that cannot be handled by normal means. Therefore, it is not clear what is the condition of the fuel assemblies that the applicant is proposing to be stored utilizing the DFI.

3 The applicant did not provide detailed drawings or operational descriptions and procedures for use of the DFI to explain its design and use. If the applicant intended that the DFI would provide the ability to handle the damaged fuel assembly stored within by normal means, this should be clarified in the RAI response and the FSAR page changes. In addition, the applicant should provide operational descriptions and procedures for use, loading, and unloading of the DFI, including specific changes to the operating procedures in Chapter 8 of the FSAR.

The staff needs this information to determine compliance with the requirements of 10 CFR 72.236(b) and (m).

RAI 8-2. Provide the references used in determining the densities of Metamic-HT and Holtite-A in Table 6.III.3.5.

The applicant presented 2.60 g/cm3 as the density of Metamic-HT in Table 6.III.3.5. The Metamic-HT Qualification Source Book shows ~ 2.7 g/cm3 as the density of Metamic-HT. The applicant presented 7.82 g/cm3 as the density of Holtite-A in Table 6.III.3.5.

However, Holtecs Holtite-A: Development History and Thermal Performance Data shows ~ 1.7 g/cm3 as the density of Holtite-A.

The staff needs this information to determine compliance with the requirements of 10 CFR 72.236(c) and (d).

References Holtec International, Metamic-HT Qualification Sourcebook, Report HI-2084122, Holtec Proprietary.

Holtec International, Holtite-A: Development History and Thermal Performance Data, Report HI-2002396, Non-proprietary.

Observation O-1 In the initial application for Amendment No. 12, the applicant requested to add a new open loop low pressure drying (LPD) method, and subsequently removed the request.

The staff noted that the description of open loop LPD, which is not approved by the NRC, is in the Report HI-2043317, Appendix P. The description of open loop LPD should be removed.