ML19137A304

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Memorandum to J. Cai User Need for Rulemaking for Amendment No. 3 to the Holtec International Storage, Transport and Repository (HI-STAR) 100 Storage System
ML19137A304
Person / Time
Site: 07201008
Issue date: 05/15/2019
From: John Mckirgan
Spent Fuel Licensing Branch
To: Jason Cai
Office of Nuclear Material Safety and Safeguards
White B
Shared Package
ML19137A299 List:
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Download: ML19137A304 (7)
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Text

May 15, 2019 MEMORANDUM TO: June Cai, Chief Materials Rulemaking and Project Management Branch Division of Rulemaking Office of Nuclear Material Safety and Safeguards FROM: John McKirgan, Chief /RA/

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

SUBJECT:

USER NEED FOR RULEMAKING FOR AMENDMENT NO. 3 TO THE HOLTEC INTERNATIONAL STORAGE, TRANSPORT AND REPOSITORY (HI-STAR) 100 STORAGE SYSTEM The following information is being provided to request rulemaking support for the following Division of Spent Fuel Management 10 CFR Part 72 licensing activity:

1. Changes to 10 CFR 72.214 rule text (changes appear in bold):

Certificate Number: 1008 Initial Certificate Effective Date: October 4, 1999 Amendment Number 1 Effective Date: December 26, 2000 Amendment Number 2 Effective Date: May 29, 2001 Amendment Number 3 Effective Date: TBD SAR Submitted by: Holtec International SAR

Title:

Final Safety Analysis Report on the HI-STAR 100 MPC [Multipurpose Canister]

Storage System for Irradiated Nuclear Fuel Docket Number: 72-1008 Certificate Expiration Date: October 4, 2019 Model Number: HI-STAR 100 (MPC-24, MPC-32, MPC-68, MPC-68F)

CONTACT: Bernard White, NMSS/DSFM (301) 415-6577

J.Cai 2. Use the following text for the purpose and scope of the amendment:

By letter dated September 25, 2015 (Agencywide Document Access and Management System (ADAMS) Accession No. ML15280A178), as supplemented by letters dated January 15 and April 29, 2016, December 15, 2017, July 2, 2018, and February 6, 2019 (ADAMS Accession Nos. ML16041A041, ML16133A518, ML17360A162, ML18183A447, and ML19037A152 respectively), Holtec International (Holtec) submitted an amendment request to the U.S. Nuclear Regulatory Commission (NRC) to amend the HI-STAR 100 (MPC-24, MPC-32, MPC-68, MPC-68F) Storage System for Irradiated Nuclear Fuel. Specifically, Holtec proposed the following changes:

a. Inclusion of multipurpose canister (MPC)-32 for storage of pressurized-water reactor (PWR) spent fuel in the Holtec International Storage, Transport and Repository (HI-STAR) 100 storage system,
b. Inclusion of the Metamic neutron absorber for MPC-32, MPC-24 and MPC-68.
c. Revise the confinement boundary criterion to be leaktight in accordance with Interim Staff Guidance (ISG) -18, Revision 1, The Design and Testing of Lid Welds on Austenitic Stainless Steel Canisters as the Confinement Boundary for Spent Fuel Storage (ADAMS Accession No. ML081220694).
d. Credit the soluble boron in criticality analyses for both the MPC-32 and MPC-24.
e. Designate the pocket trunnions as optional in the HI-STAR 100 design.
f. Incorporate standard system features and ancillaries such as the forced helium dehydration (FHD).
g. Allow for horizontal storage of the casks.
h. Update the permissible fuel cladding temperature limits under normal, accident, and short term operating conditions to be consistent with ISG-11, Revision 3, Cladding Considerations for the Transportation and Storage of Spent Fuel (ADAMS Accession No. ML033230244).
i. Designate the cask transporter as single-failure-proof.
j. Include a summary of the quality assurance program from the HI-STORM UMAX SAR (Docket No. 72-1040) as it is applied to safety significant activities for the HI-STAR 100.
k. Provide updated drawings.
l. Revise the MPC design pressure for accident condition to be 200 psig.

Specific changes to the TS are listed below:

a. Revise the TABLE OF CONTENTS page to reflect the addition of Section 2.3, SFSC Criticality Control, deletion of Sections 3.1, Training Program, 3.2, Pre-Operational Testing and Training Exercise, and 3.3, Special Requirements For First Systems In Place, and the changes to the page numbers.
b. Change the following definitions:
  • Revise definition for DAMAGED FUEL ASSEMBLY under TS 1.1 from DAMAGED FUEL ASSEMBLIES are fuel assemblies with known or suspected cladding defects, as determined by a review of records, greater than pinhole leaks or hairline cracks, missing fuel rods that are not replaced with dummy fuel rods, or those that cannot be handled by normal means. Fuel assemblies which cannot be handled by normal means due to fuel cladding damage are considered FUEL DEBRIS to read DAMAGED FUEL ASSEMBLIES are fuel assemblies with known or suspected cladding defects, as determined by a review of records, greater than pinhole leaks or hairline cracks, empty fuel rod locations that are not filled with dummy fuel rods, missing structural components such as grid spacers, whose structural integrity has been

J.Cai 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. Fuel assemblies which cannot be handled by normal means due to fuel cladding damage are considered FUEL DEBRIS.

  • Revise definition for DAMAGED FUEL CONTAINER (DFC) under TS 1.1 from DFCs are specially designed enclosures for DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS which permit gaseous and liquid media to escape while minimizing dispersal of gross particulates. DFCs authorized for use in the HI-STAR 100 design are shown in Figures 2.1.1 and 2.1.2 of the Final Safety Analysis Report (SAR) for the HI-STAR 100 Cask System, to DFCs are specially designed enclosures for DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS which permit gaseous and liquid media to escape while minimizing dispersal of gross particulates.
  • Add a new definition ZR under TS 1.1 as ZR means any zirconium-based fuel cladding or fuel channel material authorized for use in a commercial nuclear power plant reactor.
c. Make the following changes to TS 2.1.2 for incorporation of FHD, as discussed in Change Nos. 3 and 6, above:
  • Revise CONDITION A of limiting condition for operation (LCO) 2.1.1 from MPC cavity vacuum drying pressure limit not met to MPC cavity vacuum drying pressure or demoisturizer exit gas temperature limit not met.
  • Revise TS surveillance requirement] (SR) 2.1.1.1 from Verify MPC cavity vacuum drying pressure is within the limit specified in Table 2-1 for the applicable MPC model to Verify MPC cavity has been dried in accordance with the applicable limits in Table 2-1 for the applicable MPC model.
  • Revise TS SR 2.1.1.3 from Verify that the total helium leak rate through the MPC lid confinement weld and the drain and vent port confinement welds is within the limit specified in Table 2-1 for the applicable MPC model to Verify that the helium leak rate through the MPC vent and drain port cover plates (confinement welds and the base metal) meets the leaktight criteria of [American National Standards Institute] ANSI N14.5-1997. The corresponding FREQUENCY was revised from During LOADING OPERATIONS to Once, prior to TRANSPORT OPERATIONS.
d. Under Table 2-1, MPC Model-Dependent Limits, make the following changes for incorporation of FHD and horizontal storage orientation, as discussed in Change Nos. 6 and 7, above:
  • Revise item 1.a. for MPC Model MPC-24 from MPC Cavity Vacuum Drying Pressure to MPC Cavity Vacuum Drying Pressure OR FHD gas temperature, and add the LIMITS value for FHD gas temperature as 21 °F [fahrenheit] for 30 min.[minutes].
  • Revise item 1.c., MPC Helium Backfill Pressure1, LIMITS from 22.2 psig [pounds per square inch gauge] to 22.2 psig (Vertically-Oriented System) and 40.8 psig +/-2 psi [pounds per square inch] (Horizontally-Oriented System).
  • Delete item 1.e. (MPC Helium Leak Rate for MPC-24).
  • Revise item 2.a. for MPC Model MPC-68 from MPC Cavity Vacuum Drying Pressure to MPC Cavity Vacuum Drying Pressure OR FHD gas temperature, and add the LIMITS value for FHD gas temperature as 21 °F for 30 min.
  • Revise item 2.c, MPC Helium Backfill Pressure1, LIMITS from 28.5 psig to 28.5 psig (Vertically-Oriented System) and 40.8 psig +/-2 psi (Horizontally-Oriented System).
  • Delete item 2.e. (MPC Helium Leak Rate for MPC-68).
  • Revise item 3.a. for MPC Model MPC-68F from MPC Cavity Vacuum Drying Pressure to MPC Cavity Vacuum Drying Pressure OR FHD gas temperature, and the LIMITS

J.Cai value for FHD gas temperature was added as 21 °F for 30 min.

  • Revise item 3.c, MPC Helium Backfill Pressure1, LIMITS from 28.5 psig to 28.5 psig (Vertically-Oriented System) and 40.8 psig +/-2 psi (Horizontally-Oriented System).
  • Delete item 3.e. (MPC Helium Leak Rate for MPC-68F).
  • Add item 4., for MPC Model MPC-32.
  • Revise Footnote 1 from Helium used for backfill of MPC shall have a purity of 99.995% to Helium used for backfill of MPC shall have a purity of 99.995%. The backfill pressure for horizontally-oriented systems is a reference pressure at a reference temperature of 70 °F, and the backfill procedure shall compensate for actual conditions.
e. Incorporate change 9 above, by revising TS LCO 2.1.3 b from The OVERPACK is lifted with lifting devices designed in accordance with ANSI N14.6 and having redundant drop prevention design features. to The OVERPACK is lifted with lifting devices designed to be single failure proof in accordance with NUREG-0612, Control of Heavy Loads at Nuclear Power Plants: Resolution of Generic Technical Activity A-36 and having redundant drop prevention design features.
f. Make the following changes to TS 2.1.4:
  • Revise TS 2.1.4 title from Fuel Cool-Down to MPC Cavity Reflooding.
  • Revise TS LCO 2.1.4 from The MPC exit gas temperature shall be 200 °F to The MPC cavity pressure < 100 psig.
  • Revise APPLICABILITY of TS LCO 2.1.4 from UNLOADING OPERATIONS prior to flooding to UNLOADING OPERATIONS prior to and during re-flooding.
  • Revise NOTE under ACTIONS of TS LCO 2.1.4 from Separate Condition entry is allowed for each SFSC to Separate Condition entry is allowed for each MPC.
  • Revise CONDITION A of TS LCO 2.1.4 from MPC exit temperature not within limit to MPC cavity pressure not within limit.
  • Revise REQUIRED ACTION A.1 of TS LCO 2.1.4 from Establish MPC helium gas exit temperature within limit to Stop re-flooding operations until MPC Cavity pressure is within limit.
  • Revise COMPLETION TIME for A.1 of TS LCO 2.1.4 from Prior to initiating MPC re-flooding operations to Immediately.
  • Revise REQUIRED ACTION A.2 of TS LCO 2.1.4 from Ensure adequate heat transfer from MPC to the environment to Ensure MPC vent port is not closed or blocked.
  • Revise COMPLETION TIME for A.2 of TS LCO 2.1.4 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to Immediately.
  • Revise TS SR 2.1.4.1 SURVEILLANCE from Verify MPC helium gas exit temperature within limit to Ensure via analysis or direct measurement that MPC cavity pressure is within limit.
  • Revise TS SR 2.1.4.1 FREQUENCY from Prior to initiation of MPC re-flooding operations to Prior to initiation of MPC re-flooding operations. AND Once every 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> thereafter when using direct measurement.
g. Make the following changes to TS 2.2.1:
  • Revise SURVEILLANCE of TS SR 2.2.1.1 from Verify average surface dose rates of OVERPACK containing fuel assemblies are within limits. OVERPACK dose rates shall be measured at locations shown in Figure 2.2.1-1 to Verify average surface dose rates of OVERPACK containing fuel assemblies are within limits. OVERPACK dose rates shall be measured at the top and sides of the overpack.

J.Cai

  • Delete Figure 2.2.1-1, OVERPACK Surface Rate Measurement Locations and provide description of the location for the dose rate measurements.
h. Incorporate change 4, above by adding TS 2.3, SFSC CRITICALITY CONTROL, addressing the boron concentration limits.
i. Delete TS 3.1, TS 3.2, and TS 3.3. Technical Specifications 3.2 and 3.3 were moved to the certificate of compliance.

Holtec requested the following changes to Appendix B of Certificate of Compliance (CoC) 1008, Approved Contents and Design Features for the HI-STAR 100 Cask System:

a. Delete the duplicative definitions and add a reference to Appendix A for definitions in Section 1.0.
b. Delete TS 1.1.2, Preferential Fuel Loading, and incorporate preferential loading condition for Thoria rod canisters in Table 1.1-1.
c. Delete a sentence in TS 1.2, Functional and Operating Limits Violations, associated with the reporting requirements contained in Title 10 of the Code of Federal Regulations (10 CFR) Part 72, Section 72.75.
d. Add a reference to Section II of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel (B&PV) Code in Section 1.3.2.

e. Incorporate horizontal storage in change 7 above, by adding inequality equation as item 4, and renumber the rest of the items in Table 1-4.
f. Incorporate METAMIC neutron absorber in change 2 above by adding the METAMIC minimum 10B loading in the Boral neutron absorbers in Subsection 1.5.1.1 for MPC-24, and in Subsection 1.5.1.2 for MPC-68F.
g. Incorporate changes 1 and 2 for MPC-32 and METAMIC neutron absorber, above, by adding new Subsection 1.5.1.3 for MPC-32 providing information for minimum fuel cell pitch and minimum 10B loading in the Boral and Metamic neutron absorbers.
h. Make the following changes to Table 1.1-1
  • Revise Table 1.1-1, Fuel Assembly Limits, item II. A. 1. d. i. to include fuel assembly array/class 7x7A decay heat for Zr clad for MPC Model MPC-68 allowable contents.
  • Revise Table 1.1-1, item II. A. 1. e. i. to include fuel assembly array/class 7x7A post-irradiation cooling time and an average burnup per assembly for Zr clad for MPC Model MPC-68 allowable contents.
  • Revise Table 1.1-1, item II. A. 2. to include fuel assembly array/class 6x6B for [Boiling Water Reactor] BWR DAMAGED FUEL ASSEMBLIES as authorized contents in the MPC-68 contents.
  • Add Table 1.1-1, item IV. A. for MPC-32 allowable contents.
i. Revise Table 1.1-2, PWR Fuel Assembly Characteristics..
j. Revise Table 1.1-4 to include the MPC-32.
k. Incorporate change 1 for MPC-32, above, by revising Table 1.1-5, Fuel Assembly Cooling and Average Burnup, to include the MPC-32.
l. Revise Table 1.3-1, List of ASME Code Exceptions for the HI-STAR 100 Cask System, to include additional components.

J.Cai 3. The proposed CoC and TS, and preliminary safety evaluation report (SER) have been placed in ADAMS (see references below) and are available for your use in the rulemaking package. The Division of Spent Fuel Management will designate these documents as Official Agency Records after the Executive Director for Operations has approved the package (ADAMS Package Accession No. ML19137A299).

The Office of the General Counsel has reviewed this memorandum with its referenced documents and has no legal objection to its contents.

Docket No. 72-1008

Enclosures:

1. Proposed CoC No. 1008, Amendment No. 3
2. Proposed TS Appendix A
3. Proposed TS Appendix B
4. Preliminary SER

ML19137A304 CoC ADAMS Accession No. ML19137A303 TS Appendix A Accession No. ML19137A300 TS Appendix B Accession No. ML19137A301 SER Accession No. ML19137A302 File Locations:

G:\SFST\HI-STAR 100\Amendment 3\Preliminary Memo to DRM,CoC, TS and SER\Transmittal Memo (HI-Star 100).docx G:\SFST\HI-STAR 100\Amendment 3\Preliminary Memo to DRM,CoC, TS and SER\Preliminary CoC 1008 A3.docx G:\SFST\HI-STAR 100\Amendment 3\Preliminary Memo to DRM,CoC, TS and SER\CoC 1008 Amd 3 TS Appendix A.docx G:\SFST\HI-STAR 100\Amendment 3\Preliminary Memo to DRM,CoC, TS and SER\ CoC 1008 Amd 3 TS Appendix B.docx G:\SFST\HI-STAR 100\Amendment 3\Preliminary Memo to DRM,CoC, TS and SER\Holtec HI-STAR 100 100 A3 Preliminary SER - OGC NLO.docx OFFICE NMSS/DSFM NMSS/DSFM NMSS/DSFM NMSS/DSFM BWhite WWheatley JSmith TTate for NAME (via email) (via email) SGhrayeb (via email)

DATE 10/4/18 10/12/18 10/19/18 2/22/19 OFFICE NMSS/DSFM NMSS/DSFM NMSS/DSFM NMSS/DSFM JIreland YKim CKenny TAhn NAME (via email) (via email) (via email) (via email)

DATE 10/15/18 10/19/18 10/12/18 10/19/18 OFFICE NMSS/DSFM NMSS/DSFM NMSS/DSFM NMSS/DSFM JTapp TTravis DTang for MRahimi NAME (via email) (via email) YDiaz-Sanabria (via email)

(via email)

DATE 10/17/18 2/22/19 2/27/19 2/22/19 OFFICE NMSS/DSFM OGC NMSS/DSFM PSilva NMertz JMcKirgan NAME (via email) (via email)

DATE 10/24/18 5/7/19 5/15/19

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