ML19282C363
| ML19282C363 | |
| Person / Time | |
|---|---|
| Site: | 07201032 |
| Issue date: | 10/02/2019 |
| From: | Holtec |
| To: | Division of Spent Fuel Management |
| Shared Package | |
| ML19282C357 | List: |
| References | |
| 5018071 | |
| Download: ML19282C363 (3) | |
Text
Attachment 1 to Holtec Letter 5018071 LAR 1032-6, REVISION 0
SUMMARY
OF PROPOSED CHANGES Page 1 of 3 Proposed Change #1 Add the allowance for the HI-STORM FW overpack to be deployed in an anchored configuration.
Reason for Proposed Change #1 Allowing the HI-STORM FW overpack to be deployed in an anchored configuration permits the use of the HI-STORM FW system at sites where a free-standing overpack would otherwise overturn or slide excessively during the site-specific seismic event.
Justification for Proposed Change #1 The anchored variant of the HI-STORM FW introduces unique cask design features that prevent cask tipover during seismic events which exceed the free-standing cask design basis. These cask features have been analyzed in Holtec Report HI-2188720 and shown to comply with the applicable stress limits of ASME,Section III, Subsection NF and Appendix F. The ISFSI pad on which the anchored HI-STORM will be deployed, as well as the actual pad embedment will be designed site-specifically to account for the specific seismic spectra.
Proposed Change #2 Permit the use of non-single failure proof lifting equipment during handling of heavy loads within the Part 72 jurisdictional boundary.
Reason for Proposed Change #2 Currently, the HI-STORM FW system mandates that all heavy load handling be performed using equipment designed as single failure proof in accordance with NUREG-0612 and thus, precludes sites without such equipment from utilizing the HI-STORM FW system. Allowing the use of non-single failure proof lifting equipment allows these sites to utilize the HI-STORM FW system.
Justification for Proposed Change #2 As an alternative to using single failure proof lifting equipment, NUREG-0612 allows sites to perform an analysis to demonstrate that the consequences of the postulated drops at the specific site are within acceptable limits. These analyses serve as an alternative demonstration that safe handling of heavy loads is maintained.
to Holtec Letter 5018071 LAR 1032-6, REVISION 0
SUMMARY
OF PROPOSED CHANGES Page 2 of 3 Proposed Change #3 Revise LCO 3.1.2 (SFSC Heat Removal System Operability) to allow an engineering evaluation to be performed in lieu of transferring the MPC into a transfer cask.
Reason for Proposed Change #3 Adding the option for analysis eliminates the burden on the site associated with requiring MPC transfer under LCO 3.1.2, Condition C.
Justification for Proposed Change #3 Performing an engineering evaluation using the models and methods described in the FSAR demonstrates that all components and contents remain below temperature limits that would compromise the design functions of the system.
Proposed Change #4 Revise the Radioactive Effluent Control Program to no longer require annual submittal of a separate radioactive effluent report [10 CFR 72.44(d)(3)] for the HI-STORM FW system.
Reason for Proposed Change #4 Eliminating the separate annual report eliminates an unnecessary burden on the site.
Justification for Proposed Change #4 As stated in 5.1.(a) of the Radioactive Effluent Control Program, the HI-STORM FW system does not create any radioactive materials or have any radioactive waste treatment systems. As such, a separate annual report for the HI-STORM storage system is extraneous.
Proposed Change #5 Revise the MPC-37, -89, and -32ML Allowable Contents to clarify that fuel debris permitted for storage does not need to meet all of the dimensional requirements and characteristics in Tables 2.1-2 & 2.1-3, provided the other requirements in Table 2.1-1 are met.
Reason for Proposed Change #5 Eliminating these overly restrictive requirements allows fuel debris currently present at prospective storage sites to be stored in the HI-STORM FW system.
Justification for Proposed Change #5 The dimensional requirements and characteristics specified in Table 2.1-2 and 2.1-3 do not affect the ability of the HI-STORM FW system to perform its intended functions, or the existing analyses thereof.
to Holtec Letter 5018071 LAR 1032-6, REVISION 0
SUMMARY
OF PROPOSED CHANGES Page 3 of 3 Proposed Change #6 Revise the MPC-37, -89, and -32ML basket Design Features to clarify that the minimum cell ID and minimum cell wall thickness are nominal dimensions.
Reason for Proposed Change #6 The current specifications can be misinterpreted as prohibiting any local deviations from the basket ID and cell wall thickness, which is not consistent with the currently approved testing and acceptance for the basket panels.
Justification for Proposed Change #6 Clarifying that the minimum cell ID and cell wall thickness are nominal dimensions allows for localized deviations from these prescribed dimensions. These localized deviations do not affect the ability of the HI-STORM FW system to perform its intended functions, or the existing analyses thereof.