ML19092A173
| ML19092A173 | |
| Person / Time | |
|---|---|
| Site: | Holtec |
| Issue date: | 03/20/2019 |
| From: | Holtec |
| To: | Division of Spent Fuel Management |
| Shared Package | |
| ML19092A192 | List: |
| References | |
| 5014867 | |
| Download: ML19092A173 (9) | |
Text
ResponsestoHISTORM100Amendment13RequestsforAdditionalInformation 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.
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.
Holtec Response:
Provided below for convenience is a summary table of the changes between the amendments. However, the change requested in this amendment is not intended to provide a blanket ability for sites to upgrade from earlier amendments to Amendment 13, which is why the change is limited to only the helium leak test condition and no statements are made in the CoC or FSAR to attempt to encompass all changes since Amendment 2. Sites are expected to follow the regulatory path for upgrading of amendments that is outlined in 72.212(b)(4),(5), and (6). A statement has been added to Chapter 9 to ensure that users understand that they are still bound by the rules in 10CFR72.212 for necessary evaluations.
ATTACHMENT 2 TO HOLTEC LETTER 5014867 1 of 9
ResponsestoHISTORM100Amendment13RequestsforAdditionalInformation Amendment Number Description of Changes 2
Add use of Metamic as an alternate neutron absorber material
Allow storage of damaged fuel in MPC-32 and MPC-32F
Include appropriate values for soluble boron for MPC-32 and MPC-32F
Clarify that heat conduction elements are no longer used
Revise CoC to reflect changes in MPC cavity drying
Revise the TS to remove the helium leakage test requirement
Relocate the helium backfilling requirements to new table in the TS
Revise requirements for ensuring MPC cavity bulk helium temperature
Add new TS Program for radiation protection
Add other components to non-fuel hardware
Increase initial enrichment for PWR damaged fuel/fuel debris to 5.0 wt%
Revise burn-up as a function of cooling time and fuel array/class
Modify completion times for blocked duct LCO
Add new limits for burnup as a function of decay heat, enrichment, cooling time, fuel class
Revise maximum allowable uranium masses
Revise maximum allowable burn-up for non-fuel hardware
Update ASME Code alternatives
Revise App B in accordance with ISG-11 Rev 3
Increase off-normal design pressure and temperature limit for overpack lid
Move FSAR appendices 3.B through 3.AS to calculation package
Remove three-ducts blocked condition
Revise discussion of QA program
Editorial corrections in CoC
Modify CoC condition 11
Modify drying acceptance criterion for FHD
Include maximum boron carbide content in Metamic
Add language incorporating FSAR Section 9.1.5.3 by reference
Clarify the equation for free-standing casks
Modification of design temperatures of MPC shell, overpack concrete, and Holtite
Modify Code applicability for MPC basket and basket angle supports
Add FHD failure and SCS power failure as off-normal events and SCS failure as accident event
Add new requirement to address degraded cask/pad interface friction 3
Minor editorial changes to CoC
Modify the TS to eliminate the requirement to perform helium leak rate testing on vent and drain port cover plates if the associated welds are performed with at least a two weld pass and liquid penetrant examinations of the root and final weld passes
Modify the TS to eliminate cooling of the MPC cavity prior to reflood during unloading. The requirement is now on MPC cavity pressure.
Modify the TS to allow linear interpolation between minimum soluble boron concentrations of 4.1 wt% and 5.0 wt% enrichment in the MPC-32/32F ATTACHMENT 2 TO HOLTEC LETTER 5014867 2 of 9
ResponsestoHISTORM100Amendment13RequestsforAdditionalInformation Amendment Number Description of Changes
Modify the definition of fuel debris to permit containers/structures that provide support to loose fuel assembly parts and non-fuel hardware to be stored as fuel debris in DFCs
Modify the definition of non-fuel hardware to include neutron source assemblies
Modify the TS to permit storage of PWR fuel assemblies with annular fuel pellets in the top and bottom 12 in of active fuel length
Modify the definition of damaged fuel 4
Indian Point Unit 1 options added to CoC:
o Shortening of the HI-STORM 100S Ver B, MPC-32,-32F, and HI-TRAC 100D o
TS Definition of Transport Operations o
Soluble boron requirements for 14x14E IP1 fuel o
Helium gas backfill requirements for 14x14E IP1 fuel o
Addition of another DFC design o
Addition of separate burnup cooling time, and decay heat limits for 14x14E IP1 fuel o
Addition of antimony-beryllium secondary sources as approved contents o
Loading of all IP1 fuel assemblies in DFCs o
Preclusion of loading of IP1 fuel debris in MPC-32 or -32F o
The reduction of maximum enrichment for 14x14E IP1 fuel from 5.0 to 4.5 wt%
o Changes to licensing drawings to differentiate the IP1 MPC-32 and -32F
Replace all UST&D references with HMD 5
Deletion of the requirement to perform thermal validation tests
An increase in the design basis maximum decay heat loads and addition of regionalized loading scheme
Increase in the maximum BWR fuel assembly weight from 700 to 730 lb
Increase in the maximum fuel assembly weight of up to 1,720 pounds for assemblies not requiring spacers, otherwise 1,680 pounds.
Changes to PWR 16x16 fuel assembly
Change in storage location for fuel with APSRs in the MPC-32 and in the MPC-24, -24E, and -32 for fuel with CRAs, RCCAs, and CEAs
Elimination of restriction that fuel debris can only be loaded into the MPC-24EF,-32F, -68F, and -68FF
Requirement that MPC confinement boundary components and MPC components exposed to spent fuel pool water or ambient environment be made of stainless steel, or for MPC internals, neutron absorber or aluminum
Addition of a threshold heat load below which SCS is not required
Editorial changes
Modification of the definition of non-fuel hardware 6
Modify TS for editorial changes
Modify TS to allow ITTRs in MPC-24 and -32 7
Addition of HI-STORM 100U System, with separate CoC appendices
Upgrade all thermal simulations to utilize a 3D model
Incorporate mandatory radiation protection perimeter around loaded VVMs ATTACHMENT 2 TO HOLTEC LETTER 5014867 3 of 9
ResponsestoHISTORM100Amendment13RequestsforAdditionalInformation Amendment Number Description of Changes
Incorporate previously approve provisions of CoC 1014, Amendment 6 that add instrument tube tie rods to the approved contents of MPC-24 and MPC-32 models
Reinstating decay heat limits for damaged fuel and fuel debris from Amd 3 that had been inadvertently deleted from Amds 5 and 6 8, 8R1
Addition of new MPC-68M with two new BWR fuel array classes
Addition of new PWR fuel array class
Revised Condition 3 to perform helium leak test on base material Rev 1 Changes
Change to burnup/cooling time limits for TPDs
Changes to Metamic-HT testing requirements
Changes to Metamic-HT MGVs
Update fuel definitions to allow BWR fuel affected by certain corrosion mechanisms within specific guidelines to be classified as undamaged fuel 9, 9R1
Broadening the subgrade requirements for the HI-STORM 100U part of the HI-STORM 100 Cask System
Update the HI-TRAC thermal methodology from 2-D to 3-D Rev 1 Changes
Change to burnup/cooling time limits for TPDs
Changes to Metamic-HT testing requirements
Changes to Metamic-HT MGVs
Update fuel definitions to allow BWR fuel affected by certain corrosion mechanisms within specific guidelines to be classified as undamaged fuel 10
Addition of new 16x16B and C fuel classes
Addition of ASME Code Alternative for SA-516/516A Grade 70 material
Revision to Condition 9 11
Increase per storage weight limit for BWR MPCs
Revise surveillance requirements for overpack blocked vents with low heat load MPCs
Revise enrichment limits for BWR MPCs with a combination of standard fuel and fuel that meets certain criteria for being considered undamaged
Increase enrichment limit for 10x10G assembly
Add soluble boron limits for17x17A fuel
Permit loading of NFH in combination with other control components
Add thoria rods/canister for the MPC-68M, with a modified composition for all MPC-68 models
Clarifications and editorial changes 12
Addition of new loading patterns for the MPC-68M (QSHL)
Add an exception to the ASME code to allow use of certain duplex stainless steels
Addition of cyclic vacuum drying
Update coefficients for burnup calculation equation for fuel assembly with cooling time of 2 through 40 years.
ATTACHMENT 2 TO HOLTEC LETTER 5014867 4 of 9
ResponsestoHISTORM100Amendment13RequestsforAdditionalInformation 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 ATTACHMENT 2 TO HOLTEC LETTER 5014867 5 of 9
ResponsestoHISTORM100Amendment13RequestsforAdditionalInformation 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).
Holtec Response:
The NRC staff is correct in relating the discussion to EA-09-190, and identifies a number of the related ML numbers in the RSI. These letters are based on site-specific data and were communications between the NRC and individual sites. Therefore, these are not generic letters that can be evaluated in the HI-STORM 100 generic license. However, Holtec understands that these are important documents which add to the previous and current condition of the canisters loaded to earlier amendments. To ensure that this information is properly documented and evaluated, instructions have been added to the generic FSAR to ensure that sites evaluate their site-specific documentation if they choose to upgrade to this amendment.
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 ATTACHMENT 2 TO HOLTEC LETTER 5014867 6 of 9
ResponsestoHISTORM100Amendment13RequestsforAdditionalInformation 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.
Holtec Response:
The FSAR, Technical Specifications, and CoC condition have been updated to clarify that the request is for Amendment Numbers 2 through 7. Casks loaded to older amendments would need additional licensing actions prior to being upgraded.
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.
Holtec Response:
The summary of proposed changes, Reason for Proposed Change #1, has been updated to clearly indicate that there were two changes to the helium leak tests of the canisters over time that will be encompassed by this change. One change was for the testing of the base metal of the MPC lids and one is related to the 72.48 that eliminated the fabrication helium leak rate test for a period between 2006 and 2009.
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, ATTACHMENT 2 TO HOLTEC LETTER 5014867 7 of 9
ResponsestoHISTORM100Amendment13RequestsforAdditionalInformation 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.
Holtec Response:
Holtec understands the NRCs request, and confirms that the fabrication leakage rate test was re-instated after June 30, 2009. However, the staffs suggested wording above only addresses the fabrication leakage test, and does not address the lid base metal test, which was not a requirement in Amendment 7 and prior (which was issued in December 2009). Holtec has used the staffs suggested language and modified the condition to include both aspects of the change.
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.
Holtec Response:
Agreed, language has been aligned with the expected final language from Amendment No. 12.
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.
ATTACHMENT 2 TO HOLTEC LETTER 5014867 8 of 9
ResponsestoHISTORM100Amendment13RequestsforAdditionalInformation 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).
Holtec Response:
This change is to the generic license and therefore, if approved, would not be limited to any site or any specific number of canisters. However, for the staffs information, the Holtec Root Cause Report associated with EA-09-190 identifies 107 canisters that were loaded without the fabrication leakage rate test, as described in Holtecs letter (ML092470363). Other canisters that were fabricated but not loaded at the time were tested prior to loading. The MPC lid base metal leakage test was not a requirement until Amendment 8 of the HI-STORM 100 CoC, and therefore canisters manufactured prior to that amendment did not have the lid base metal test. There were approximately 650 canisters manufactured prior to the lid base metal requirement being implemented.
Note that the changes requested in this amendment will only be applied to sites that choose to upgrade to this amendment, and therefore they may not apply to all canisters identified above.
ATTACHMENT 2 TO HOLTEC LETTER 5014867 9 of 9