ML19093A048

Memorandum to C. Regan Summary of March 19, 2019, Meeting with Holtec International to Discuss Proposed Response to the Second RAI for Certificate of Compliance No. 1032 for HI-STORM Flood/Wind, Amendment No. 4 (W/Enclosure 1)

ML19093A048
Person / Time
Site:	07201032
Issue date:	04/04/2019
From:	Yen-Ju Chen Spent Fuel Licensing Branch
To:	Christopher Regan Division of Spent Fuel Management
Chen Y
Shared Package
ML19093A047	List: ML19093A048
References
CAC 001028, EPID L-2017-LLA-0030
Download: ML19093A048 (4)

Text

April 4, 2019 MEMORANDUM TO: Christopher M. Regan, Deputy Director Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards FROM: Yen-Ju Chen, Sr. Project Manager /RA/

Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards

SUMMARY

OF MARCH 19, 2019, MEETING WITH HOLTEC INTERNATIONAL TO DISCUSS PROPOSED RESPONSE TO THE SECOND ROUND OF REQUEST FOR ADDITIONAL INFORMATION FOR CERTIFICATE OF COMPLIANCE NO. 1032 FOR HI-STORM FLOOD/WIND, AMENDMENT NO. 4 On March 19, 2019, staff from the Division of Spent Fuel Management held a public meeting with representatives from Holtec International (Holtec) at the U.S. Nuclear Regulatory Commission (NRC) Headquarters in Rockville, MD. The purpose of the meeting was to discuss Holtecs proposed approach and response to the second round of request for additional information (RAI) (Agencywide Documents Access and Management System [ADAMS]

Accession No. ML19011A127) for Certificate of Compliance (CoC) No. 1032 for the HI-STORM Flood/Wind (FW) Multipurpose Canister Storage System. No regulatory decisions were made nor requested at this meeting.

The meeting was noticed on March 8, 2019 (ADAMS Accession No. ML19066A384). The attendance list is provided in Enclosure 1. The presentation slides are provided in Enclosure 2.

NRCs second round of RAI focuses on fuel qualification, which is the combinations of burnup, initial enrichment, and cooling time that defines the source terms for the design basis spent nuclear fuel based on which the cask shielding design is made. During the meeting, Holtec discussed its approach to present fuel qualification information where the minimum cooling time is calculated as a third-order polynomial function of burnup. Enrichment is not part of this equation. However, Holtec will perform dose/dose rate analyses for each cask using a bounding enrichment determined by selecting an enrichment that encompasses 99% of the known discharged fuel assemblies based on the data in the DOE spent nuclear fuel database GC-859. Holtec determines this minimum enrichment for each 5 GWd/MTU burnup interval within the range of 0-70 GWd/MTU. Then, a selected number of points on the burnup and cooling time curve are used to calculate dose rates around the cask to determine the bounding dose rates. Holtec plans to use this approach in HI-STORM FW Amendments No. 4 and 5 and HI-STORM 100 Amendment No. 15 (to be submitted).

CONTACT: Yen-Ju Chen, NMSS/DSFM (301) 415-1018

C. Regan NRC staff noted that Holtec needs to demonstrate that the storage cask system as amended can meet the regulatory dose limits as prescribed in 10 CFR 72.104 and 72.106. The RAI asked about burnup, enrichment and cooling time (BECT) combination. NRC staff asked Holtec to provide BECT because it is needed to define the spent fuel contents that meet design basis source terms; the source terms are the bases of the shielding design for the HI-STORM F/W spent fuel storage system. However, the BECT may not necessarily be in the form of multipage tables. Approaches, such as the method proposed by Holtec, have the potential to be the alternatives as long as they can uniquely define the allowable spent fuel contents concerning the cask shielding design.

With respect to whether the demonstration of compliance with the regulations is the responsibility of the vendor or a general licensee, NRC staff pointed out that 10 CFR 72.234 requires that Holtec needs to demonstrate that the cask design is capable of meeting the requirements of 10 CFR 72.236. Compliance with the 72.104 and 72.106 regulation demonstrated by the general licensee using the cask is a separate part of the regulation, i.e.,

72.212. The current review is to certify the design rather than an evaluation of compliance with site specific design.

NRC staff also asked Holtec to provide results for dose/dose rate for more burnup/cooling time points on the curve, especially for higher burnup assemblies. NRC staff also noted that there is not very much data available for very high burnup fuel assemblies (55-70 GWd/MTU), therefore using an enrichment that bounds 99% of fuel assemblies is not statistically justified.

Furthermore, the dose rate is sensitive to changes in initial enrichment the higher the burnup is and industry trends are going towards higher and higher burnup. Therefore, NRC staff asked Holtec, in lieu of a technical specification requirement on minimum enrichment for this burnup range, to provide more justification that the selected enrichment bounds 99% of higher burnup assemblies not present in the database including those that will be discharged in the future.

NRC staff also requested that Holtec provide additional explanation on the process it uses to determine the bounding dose/dose rates for loading patterns where there are multiple loading zones and therefore there are multiple burnup/cooling time correlations being used within the same cask.

Two members of the public provided feedback.

Docket No.: 72-1032 CAC: 001028 EPID: L-2017-LLA-0030

Enclosures:

1. Attendance List

2. Meeting Presentation Slides

C. Regan

SUMMARY

OF MARCH 19, 2019, MEETING WITH HOLTEC INTERNATIONAL TO DISCUSS PROPOSED RESPONSE TO THE SECOND ROUND OF REQUEST FOR ADDITIONAL INFORMATION FOR CERTIFICATE OF COMPLIANCE NO. 1032 FOR HI-STORM FLOOD/WIND, AMENDMENT NO. 4, DOCUMENT DATE: April 4, 2019 DISTRIBUTION:

DSFM r/f NRC attendees ADAMS Package No.: ML19093A047 Memo: ML19093A048 Slides: ML19077A218 OFFICE: DSFM DSFM DSFM DSFM NAME: EGoldfeiz VWilson ZLi TTate DATE: 3/25/19 3/25/19 3/25/19 4/2/19 OFFICE: DSFM DSFM DSFM DSFM NAME: CJacobs WWheatley JMcKirgan for YChen DATE: 4/2/19 4/2/19 4/4/19 OFFICIAL RECORD COPY

ATTENDANCE LIST March 19, 2019 Name Affiliation Tae Ahn NRC/DSFM Ilka Berrios NRC/DSFM Yen-Ju Chen NRC/DSFM Norma Garcia-Santos NRC/DSFM Eliezer Goldfeiz NRC/DSFM Christian Jacobs NRC/DSFM Zhian Li NRC/DSFM Travis Tate NRC/DSFM Veronica Wilson NRC/DSFM Peter Stefanovic Holtec (Participating by phone)

Kimberly Manzione Holtec Donna Gilmore San Onofre Safety Carlyn Greene Spent Fuel UxC Ace Hoffman Michael Keegan Marvin Lewis Rick Migliore TN-Americas, Orano Enclosure 1