ML20031D056
| ML20031D056 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 01/29/2020 |
| From: | Boshoven J Consolidated Interim Storage Facility |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| CAC 001028, E-56011, EPID L-2017-NEW-0002 | |
| Download: ML20031D056 (17) | |
Text
IN1ERIM STORA_GE PARTNERS Director, Division of Spent Fuel Management Office of Nucl13ar Material Safety and Safeguards U. S. Nuclea_r Regulatory Commission Attn: Document Controi Desk One White Flint North 11555 Rockville Pike Rockville, MD.20852 January 29; 2020 E-56011 S~bject:
Submission of ISP Updated Draft Responses for RAls NP-8-1, NP-8-2 and Associated SAR Markups from First Request For Additional Information, Part 2, Docket 72-1050 CAC/EPID 001028/L-2017-NEW-0002
Reference:
- 1.
Letter from John-Chau Nguyen (NRC) to Jeffery D. Isakson, "Interim Storage Partners LLC's License Application To Construct And Operate The Waste Control Specialists Consolidated Interim Storage Facility, AndrC3Ws County, TC3xas, Docket No. 72-1050 -
First Request For Additional Information, Part 2,1' dated March 6, 2019 Interim Storage Partners LLC hereby submits its updated draft responses to RAls NP-8.,.
1 and NP-8-2 from Reference [1] in preparation for possible meetings to be scheduled with NRC staff for di$cussion. Enclosure 1 contains the updated draft responses to the RAls and associated Safety Analysis Report (SAR) marked up pages, Should you have any questions regarding this submission, please contact me by telephone at (410) 910-6955, or by email at jack.boshoven@orano.group.
Sincer¢1y,
~t:;*-2*~) ~-~
Jack Boshoven Chief Engineer CISF, Licensing and Engineering Interim Storage Partners LLC P.o. Box 1129
- AQdrews, Tex.as 79714
- int:*erimstoragepartners. cqm
Document Control Desk cc:
John-Chau Nguyen, Senior Project Manager, U.S. NRC Jeff Isakson, ISP LLC Elicia Sanchez, ISP LLC Renee Murdock, ISP LLC
Enclosures:
E-56011 Page 2 of 2
- 1.
Updated draft RAI NP-8-1 and NP-8-2 responses with associated SAR change pages
RAls and Responses - Public SAR Chapter 8, "Thermal Evaluation" RAI NP-8-1: to E-56011 Provide bounding site specific ambient temperatures which account for seasonal variations.
Seasonal variations must be accounted for as ambient temperatures may persist for periods of time sufficient for the cask systems to reach steady state conditions, which may differ from the use of an annual average, as analyzed in the respective FSARs.
The applicant has not clearly defined an ambient temperature which considers seasonal variations. According to the monthly averaged values provided, able 1-2 of the license application seems to provide a value that bounds seasonal variations. The applicant needs to clearly state how a bounding site-specific ambient temperature which considers seasonal variations is obtained.
This information is needed to determine compliance with 10 CFR 72.122 and 72.128.
Response to RAI NP-8-1 :
The NAG and NUHOMS storage systems cover a more than 20-year licensing history. Over that time, the NRG has approved each amendment and system. This results in not only differences in the data and values in certificates of compliance (CoCs) and materials licenses themselves, but also in differences in approaches concerning the basis and data used to license the individual storage systems.
NAG and NUHOMS storage systems have different approaches to defining the specific ambient temperature for normal, off-normal and accident conditions the. Table NP-8-1-1 summarizes how site normal, off-normal and accident temperatures are calculated, and then compares the limits defined in eacl) CoC of Material License Technical Specifications. As shown in the table, the NUHOMS storage systems included in the WCS CISF License Application, as a rule, use high an low measured temperatures that are evaluated and compared. NAG systems h ve used the approa-ch that the normal, off-normal and accident temperatures must be calcu ated using measured temperatures over different periods of time.
The site-specific ambient temperatures are derived from meteorological data presented in Safety Analysis eport (SAR) Table 2-2, Summary of Maximum and Minimum Temperatures for Andrews, TX (Period of Record: 1962 to 2010). The table includes the seasonal variation in ambient temperatures.
The ambient temperature range presented in Table 1-2 is 44.1 to 81.5 °F. These values represent the lowest mean monthly temperature at Andrews (from Table 2-2), which occurs in January (44.1 °F), anti the highest mean monthly temperature (81.5 °F), which occurs in July.
The design and licensing basis incorporated by reference into the WCS CISF SAR for the NAG storage casks use the yearly average temperature to evaluate the system for normal ambient environmental conditions. SAR Sections E.3.1.1.6, E.3.2.1.6, F.3.1.1.6, and G.3.1.1.6 have been revised to clearly demonstrate how the design basis thermal analysis incorporated by reference from each of the NAG General Licenses remain bounding for the site-specific temperature data included Chapter 2 of the SAR.
Page 1 of 5
RAls and Responses - Public to E-56011 Going beyond the design and licensing basis, ISP reviewed NUREG-2174, which looked at the use of yearly average temperature for the normal condition ambient temperature, which is accepted by the NRC, and reviewed the effects on vertical and horizontal storage systems using this more conservative approach for normal ambient conditions by use of higher m summer temperatures such as those listed in Table 1-2 of the WCS CISF. NUR,...,... "'..,.
determined that for every 1 O °F increase in ambient temperature; there is an a increase in the peak cladding temperature (PCT) for systems similar to the systems. Table NP-8-1-2 lists the resulting maximum PCT for each syste the PCT when the 14.4 °F PCT increase per 10 °F ambient is applied.
Finally, the thermal analysis incorporated by reference into the W systems includes conservatism. For instance, for the MAGNA thermal analyses utilized a 35.5 kW design basis heat load, ~-th However, the highest heat load that can be transported in is 23 kW. Thus, transporting a MAGNASTOR canister having a minimum heat load margin of 12.5 kW whe CISF (i.e., 35.5 kW minus 23 kW). This is a reduction,.,:1-.:i the licensing basis analytical heat load value. Taking th1 concluded that margins for MAGNASTOR will be higher w received at the WCS CISF for normal conditions of storage.
NAC-UMS systems are licensed for le that has all been significant amount of time, the margins her for thes analyzed heat load and what will eventu e WCS Impact:
SAR Sections E.3.1.1.6,........,..~..,_,""
the response.
Page 2 of 5 d and in storage for a ms with respect to
RAls and Responses - Public to E-56011 Table NP-8-1-1 Licensing Basis Temperature Data for NAC and NUHOM NUHOMS-Standardized MP187 Advanced Standardized Cask NUHOMS NUHOMS-NAC-System System 61BTSystem UMS CISF Site Data Condition System
("F)
("F)
("F)
("F)
("F)
Design Parameter Temperature Normal Temperature 0-101 0-104 X
X 44.1-81.5 Normal Average Annual Ambient X
X 76 °F 76 67.1 Temperature Minimum temperature
-20.0
-40.0 X
X 30.1 Maximum temperature 120 117 X
X 113 Off-Normal Minimum 3-day avg.
X X
-40
-40 27.9 temperature Maximum 3-day avg.
106 106 89.4 temperature Accident Maximum temperature 125 125 133 133 113 Page 3 of 5
RAls and Responses - Public to E-56011 Table NP-8-1-2 Calculated PCT Using NUREG-2174 Methodology System MPC-LACBWR MPC-CY MPG-Yankee UMS (PWR Fuel)
MAGNASTOR (PWR Fuel)
Zr= Zircalloy Clad Fuel Yearly Average Normal Ambient (OF) 75 75 75 76 76 SS = Stainless Steel Clad Fuel Calculated PCT Calculated PCT for 81.5 Of Normal Ambient (Of) 449 629 563 648 718 752 (Zr)
Page 4 of 5
RAls and Responses - Public to E-56011 RAI NP-8-2:
Provide thermal evaluation, analysis, and results to demonstrate that all cask systems meet the WCS CISF site specific environmental conditions.
WCS CISF SAR Appendices A.8, 8.8, C.8, and D.8 of the application provide temperature design criteria for the NUHOMS-MP187, Standardized Advan"_.. _
Standardized NUHOMS-61 BT, and Standardized NUHOMS-618TH Ty respectively. Appendices E.8, F.8, and G.8 of the application state that UMS, and MAGNASTOR, the maximum average yearly temperatur..,_,.....,_
- and 76°F, respectively. A definition of normal ambient temperatur fo e site is no application but according to the monthly averaged values provi ean monthly ter"Oll!lw of 81.5°F [considering seasonal variations] on SAR Table 2-mary of Maximum a Minimum Temperatures for Andrews, TX, Period of Recor 2 to 2010"), SAR Table 1-would provide a value that seems to bound seasonal v s and the lue seems to boun storage systems described in Appendices A-D of the able 1-2 is not bounded by the systems described in Appendices E.,
efore, a thermal evaluation is needed for these systems based on the no mperature presented in Table 1-2.
The NRC staff needs this information to,.,..r.""'.u cask systems stored at WCS CISF.
This information is needed to determine c Response to RAI NP-8-2:
As described in the re~DM1e..te:fiui.J.
G.3.1.1.6 have beerAllliiilfi::.
incorporated by r*1111111""
specific tempeni-ie report systerrN-~
average tempera--c the value reportea'1111>aPJilllt.
ections E.3.1.1.6, E.3.2.1.6, F.3.1.1.6, and trate how the design basis thermal analysis ral licenses remain bounding for the site R. SAR Table 1-2 has been revised to CISF site. The maximum three-day as also been corrected to be consistent with have been revised as described in the response.
Page 5 of 5
WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Table 1-2 Summary of WCS CISF Principal Design Criteria Design Parameter Type of fuel Storage Systems Fuel Characteristics Tornado (Wind Load)
Tornado (Missile)
Floods Seismic (Ground Motion)
Vent Blockage Fire/Explosion (3 pages)
Design Criteria Commercial, light water reactor spent fuel Transportable canisters and storage overpacks docketed by the NRC Criteria as specified in previously approved CoCs and licenses for included systems Max translational speed:
40mph Max rotational speed:
160 mph Max tornado wind speed:
200 mRh Radius of max rotational speed:
150 ft Tornado pressure drop:
Rate of pressure drop:
Automobile Schedule 40 Pipe Solid Steel Sphere 40 hrs Inlet and outlet vents blocked 24 hrs AGNASTOR Systems:
Inlet vents blocked 58 hrs or NUHOMS Systems:
Equivalent fire 300 gallons of diesel fuel For Vertical Systems:
Equivalent fire 50 gallons of fuel Page 1-23 Applicable Codes, Condition Sta dards and Basis NIA See Table 1-1 Normal See Table 1-1 Reg Guide 1.76 Accident
[1-5]
NUREG-800[1-6]
NUREG-800[ 1-7]
Accident Section 2.4.2.2 AECOM Study Accident Number WCS 05-100-001 [1-1 O]
WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Table 1-2 Summary of WCS CISF Principal Design Criteria (3 pages)
Applica le Codes, Design Parameter Design Criteria Condition Standards and For NUHOMS Systems:
Transfer Cask Horizontal side drop or slap down 80 inches Cask Drop VCCs for MPC Systems:
Accident NIA Drop height VCCs for UMS and MA GNAS TOR Systems:
Drop height For NUHOMS Systems only:
Transfer Load Normal insertion load NA Normal extraction loacl For NUHOMS System only:
ff-Transfer Load Maximum insertion Joa 80 kips Normal/
NIA Maximum extraction foa 80 kips Accident Ambient
- 81.5°F Normal Section 2.3.3. l Temperatures!
Off-Normal l l3°F Off-Section 2.3.3. l Temperaturel Normal l l3°F Accident Section 2.3.3.l 2949.4 BTU/day-ft2 Normal 10 CFR Part 71 1474.7 BTU/day-ft2 10 psf Normal Section 2.3.2.4 Normal NIA Per tlesign basis for systems listed in Table 1-1 Normal NIA Per design basis for systems listed in Table 1-1 Normal NIA Operating Loads Per design basis for systems listed in Table 1-1 Normal NIA Live Loa s Per design basis for systems listed in Table 1-1 Normal NIA Page 1-24 All Indicated Changes are in response to RAI NP-8-2
WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Design Parameter Radiological Protection Radiological Protection Confinement Nuclear Criticality Decommissioning Materials Handling and Retrieval Capability Cask Handling Building Note:
I.
within the region.
Table 1-2 Summary of WCS CISF Principal Design Criteria (3 pages)
Applicable Codes, Design Criteria Condition Standards and Public wholebody Public deep dose plus individual organ or tissue Public shallow dose to skin or extremities Public lens of eye
- 5 Rem
- 50Rem Public wholebody
- 25 mremlyr <1>
Public thyroid
- 75 mremly ( I )
Public critical organ
- 25 mremlyr<
Per design basis for systems listed in Table 1-1 Per design basis for systems listed in Table 1-1 Basis ccident 10 CRR 72.106 ormal 10 CFR 72.104 NIA NIA NIA NIA annal 10 CFR 72.130 Minimize potential c ntam* ation
~-=- --~---+--~- ~-+---------I Cask/canister handling system prevent breach of confinement boundary under all conditions Storage system allows ready retriev I of canister for shipi;nent off-site der Normal 10 CFR 72.122(1)
Accident Section 7.5.3.2 FR 72.104 (a)(3) limits include any other radiation from uranium fuel cycle operations Page 1-25
WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Measurements for all parameters, listed in Table 2-11, are taken at IO-minute, 60-minute and 24-hour averages and recorded/stored on a dedicated Campbell Scientific data logger at each station. Routinely the data loggers automatically download their content to a server in Dallas, TX for long-term storage. Data loggers can be remotely accessed via password protected radio telemetry; and the se ver can be securely accessed via a password protected Internet connection. Table 2-11 lists the meteorological parameters measured and at what heights. Information for the Met One Towers and the WeatherHawk Series regarding range, accuracy, and resolution is listed in Table 2-12.
2.3.3.1 Maximum and Minimum Temperatures The Western Regional Climate Center (www.wrcc.df".edu) has historic temperat e data for Andrews, TX. The temperature data currently available spans from 1962 until 2010. The average maximum and minimum temperatures, the record high temperature and low temperature for each month, and the annual high and low temperature for these years is shown on Table 2-2.
able 2.::2 was used to provide normal, off-normal, and extreme temperature informatio for the WCS CISP site.
Normal Temperature (NUHOMS System): The norma terrtr.erature range is taken as the low and high mean monthly temperature ( 4.1 °P to 8 !.§°F).
Normal Temperature (NAC System): The normal ambient temperature is taken as the maximum yearly average temperatur. In addi ion to the temperature information provided in Table 2-2, temperature data from the Midland-Odessa monitoring station between 2000 and 2015 as used to provide yearly average temperatures (Table 2-13).
The maximum yearly average temperature is 67.1 °P.
Off-No mal Temperatur (NUHOMS System): The NUHOMS System uses the extre e high temperature to evaluate tha system for off-normal temperature condit ons. J'ha value is taken as the highest temperature recorded over the time period (1 lJ°F) i the data set represented in Table 2-2. The off-normal minimum temperature is 3.l 0P, which is the minimum mean daily temperature shown in Table 2'-2.
Off-Normal Tempera ure (NAC System): The NAC System uses a rolling average temperature to evaluate that system for the off-normal temperature condition. In addition to the temperature information provided in Table 2-2, temperature data from the Mid laod-©dessa monitoring station between 2000 and 2015 was used to provide 3-day ave age ambient temperatures. These temperatures are determined by taking the daily average temperature averaged over three consecutive days for each day of the year. i; e lowest average 3-day temperature and the highest average 3-day tern erature is shown in Table 2-13. The minimum average and maximum average va ues averaged over the data set represented in Table 2-13 are 27.9°P and 93.5°P.
Page 2-16 All Indicated Changes are in response to RAI NP-8-2
WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim E.3.1.1.6 Environmental Temperatures A temperature of 75°F was selected to bound all annual average temperatures in the United States, except the Florida Keys and Hawaii, with full insolation. The annual average temperature takes into account day and night and summer an wi ter temperatures throughout the year. The annual average temperatur s t principle design parameter in the NAC-MPC design analysis, because it e Jabli es the design basis for demonstration of long term spent fuel integrity. The on t rm
- tegrity of the spent nuclear fuel cladding is a function of the average mb
- nt te er ure over the entire storage period, which is assumed to be at the Jl.W~
- um annua ve, u e temperature in every year of storage for conservatisw The evaluation of tflis environmental condition is discussed along with the thermal analysis models in Chapter 4.0 of Reference E.3-1. The thermal stress evaluation for the normal operating conditions is provided in Section 3.4.4 of Reference E.3-1. Normal temperature fluctuations are bounded by the severe ambient emperature cases that are evaluated as off-normal and accident conditions.
Off-normal, severe environmental conditions were defined as -40°F with no solar loads and I00°F with solar loads An extreme enviro mental condition of 125°F with maximum solar loads is evaluated as an accident case to ho compliance with the maximum heat load case required by ANSI-57.9 (Section l l.2.10). Thermal performance was also evaluate foli the cases of: (1) half the air inlets blocked; and (2) all air inlets and outlets blocked. Thermal analyses forthese cases are presented in Sections 11.1.1 and 11.2.8 of Reference E.3-1. The evaluation based on ambient temperature conditions is presented in Section 4.4 of Reference E.3-1. Solar insolance is as specified in 10 CFR 71.71 and e~latory Guide 7.8.
Y. average ambient temperature allowed is 100°F All of th e c nditions re met at the WCS site and are addressed in WCS SAR Section 2.3.3.1 an WCS SAR Tables 2-2 and 2-13. Specifically, SAR Table 2-2 gives a maximum ea ly average temperature for the site of 63.5°F, which is less than the 75°F Jim'.
'his table also gives the maximum temperature extremes/or the site of
-l.0°F.. n 13°F, which is within the 3-day average temperature extreme limits of a 'd 125°F. WCS SAR Table 2-13 gives a maximum 3-day average temperature o/93 °F, which is less than the 100°F limit. Therefore, all environmental t
iperature limits for the NAC-MPC system at the WCSfacility are met.
Page E.3-5 All Indicated Changes are in response to RAI NP-8-1
WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim E.3.2. l.4 Snow and Ice Loadings The snow and ice loadings design criteria that are defined in Section 2.2 of Reference E.3-1 for the NAC-MPC apply to the MPC-LACBWR system in their entirety. These design criteria are described in WCS CISF SAR Appendix E, Section E..1.1.4.
Therefore, no further site-specific evaluations are required.
E.3.2. l.5 Combined Load Criteria The combined load design criteria that are defined in Section.2 ofRefe enc E.3-1 for the NAC-MPC apply to the MPC-LACBWR system in their entirety. These design criteria are described in WCS CISF SAR Appendix E, Section E.3.1.1.5.
Therefore, no further site-specific evaluations are re uired.
E.3.2.1.6 Environmental Temperatures The environmental temperatures design criteria that are defined in Section 2.2 of Reference.3-1 for the N C-MPC apply to the MPC-LACBWR system in their entirety: with exception to the maximum extreme heat limit, which is 105°F. The applicaBle design criteria are described in WCS CISF SAR Appendix E, Section E.3.1. l.6.
er:
e yearly temperature allowed is 75°F um 3-d average temperature extremes shall be greater than -40°F an 125°F um 3-day average ambient temperature allowed is 100°F Page E.3-11 All Indicated Changes are in response to RAI NP-8-1
WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim All of these conditions are met at the WCS CJSF and are addressed in SAR Section 2.3.3.1 and SAR Tables 2-2 and 2-13. Specifically, SAR Table 2-2 gives a maximum yearly average temperature for the site of 63.5°F, which is less than the 75°F limit.
This table also gives the maximum temperature extremes/or the site of-I °F and l J 3°F, which is within the 3-day average temperature extreme limits a -4 and 125°F SAR Table 2-13 gives a maximum 3-day average temperatu,e o 3.5°F, which is less than the 100°F limit. Therefore, all environmental mpe. ature limits/or the NAC-MPC system at the WCS CISF are met.
Page E.3-12 All Indicated Changes are in response to RAI NP-8-1
WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim The transfer cask is a special lifting device. The lifting trunnions and supports are designed and fabricated to the requirements of ANSI N14.6 and NUREG-0612. The remainder of the structure is designed and fabricated to ANSI/ANS-57.9. The combined shear stress or maximum tensile stress during the lift (with 10 percent load factor) shall be :'S Sy/6 and Su/10 for a nonredundant load path, or shall be :'S Sy/3 and Su/5 for redundant load paths. The ferritic steel material used for tne load bearing members of the transfer cask shall satisfy the material toughness requirements of ANSI N14.6, paragraph 4.2.6. The structural evaluations prese ed in Reference F.3-1 demonstrate that the transfer cask meets all of the design criteria. Therefore no further site-specific evaluations are required.
F.3.1.1.6 Environmental Temperatures A temperature of 76°F was selected to bound all annual average temperatures in the United States, except the Florida Keys and Ha ii.
he 76°F normal temperature was used as the basis for thermal evaluations with full
- ola on. The annual average temperature takes into accoun throughout the year. The an ua parameter in the NAC-UMS d i for demonstration of long term spent nuclear fuel cladding is a c *on ient temperature over the entire storage,JJ rio"ii, hich is assume t lJe at the maximum annual average temperatur, i ea ofstorag or conse-rvatism. The evaluation of this environmental condition i discussed along with the thermal analysis models in Chap er !1-.0 of Reference.3-l. The thermal stress evaluation for the normal operating conditions is presented in Section 3.4.4 o Reference F.3-l. Normal temperature fluctuations are bounde by the severe ambient temperature cases that are evaluated as off-normal and accident conditions.
0 -normal, se ere environmental conditions are defined as -40°F with no solar loads and 106° with solar loads. An extreme environmental condition of 133°F with maxi mu olar loads is evaluated as an accident case (Section 11.2. 7 of Reference F.3-1) to sho compliance with the maximum heat load case required by ANSI-57.9.
Thermal _Rerforrnance is also evaluated for the cases of: (1) half the air inlets blocked; and (2) all ai inlets and outlets blocked. Thermal analyses for these cases are presented
- n Sections 11. l.2 and l l.2. 13 of Reference F.3-l. The evaluation based on ambie t temperature conditions is presented in Section 4.4 of Reference F.3-1. Solar insolance is as specified in 10 CPR 71.71 and Regulatory Guide 7.8.
Per the NAC-UMS Certificate of Compliance (CoC), the environmental conditions that are required to be met are the following:
Page F.3-5 All Indicated Changes are in response to RAI NP-8-1
WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim the maximum average yearly temperature allowed is 76°F the maximum 3-day average temperature extremes shall be greater than -40°F and less than 133°F the maximum 3-day average ambient temperature allowed is 106° E All of these conditions are met at the WCS CISF and are address ---
2.3.3.1 and SAR Tables 2-2 and 2-13. Specifically, SAR Table 2-2 This table also gives the maximum temperature extreme o J 13°F, which is within the 3-day average temperatw;e eme limits of-40° 133°F. SAR Table 2-13 gives a maximum 3-day er ge temperature o/93.5°,
which is less than the 106°F limit. Therefore all the NAC-UMS system at the WCS CJSF ar F.3.1.2 Safety Protection Systems The NAC-UMS relies upon passive systems to ensure the protection of public health and safety, except in the case of fire or ex_Rlosion. As discussed in Section 2.3.6 of Reference F.3-1, fire and explosio events are'effectively precluoed by site administrative controls that prevent the introduction offiammable and explosive materials into areas where an exp osion or fire could damage installed NAC-UMS systems. The use of passive systems prov*des protection from mechanical or equipment failure.
F.3.1.2.1 General The NAOUMS is designed for safe, long-term storage of spent nuclear fuel. The NAC-S will s rvive all of the evaluated normal, off-normal, and postulated accident co ditions without release of radioactive material or excessive radiation ex osure to wo ker or the general public. The major design considerations that are incorpora ed in th NA -UMS to assure safe long-term fuel storage are:
I.
Continued confinement in postulated accidents.
- 2.
Thick co crete and steel biological shield.
- 3.
Passi e systems that ensure reliability.
Inert atmosphere to provide corrosion protection for stored fuel cladding and nhanced heat transfer for the stored fuel.
Page F.3-6 All Indicated Changes are in response to RAI NP-8-1
WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim G.3.1.1.6 Environmental Temperatures A temperature of 76°F is defined as the design base normal operations temperature for MAGNASTOR in storage. This temperature conservatively bounds the maximum average annual temperature in the 48 contiguous United States, specifi ally, Miami, FL, at 75.6°F, with full insolation, and meets the normal condition t rmal boundary defined in NUREG-1536. The annual average temperature take mto account day and night and summer and winter temperatures throughout th ye T.
annual average temperature is the principle design parameter in t GN
'O design analysis, because it establishes the design basis for dem n r, tion of Ion er spent fuel integrity. The long term integrity of the spent nu lea ifuel cladding is a nc *on of the average ambient temperature over the entir *to,._age period, which is as -ume to be at the maximum annual average temperatu e in every year of storage for conservatism. Use of this design base establishe a bounding condition for existing and potential ISFSI sites in the United Stat s. 'F e evaluation of this environmental condition along with the thermal analysis models a e presented in Chapter 4 of Reference G.3-1. The thermal stress evaluation or the normal operating conditions is included in Chapter 3 of Reference G.3-1. Normal emperature fluctuations are bounded by the severe ambient temperature cases that are e aluated as off-normal and accident events.
Off-normal, severe environmental events ar defined as -40°F with no solar loads and 106°F with solar loads. An extreme environme fal condition of 133°F with maximum solar loads is evaluated as an accident case t show compliance with the maximum heat load case required by ANSI/ANS-57.9. Thermal performance is also evaluated assuming both tHe alfblockage of the concrete cask air inlets and the complete blockage o the air inlets.
olar insolation is as specified in 10 CFR 71.71 and Regulato y Guide 7.8.
'J)liance (CoC), the environmental conditions rrverage ambient temperature allowed is 106°F c r_ditions are met at the WCS CISF and are addressed in SAR Section R Tables 2-2 and 2-13. Specifically, SAR Table 2-2 gives a maximum yearly a er; e temperature for the site of63.5°F, which is less than the 76°F limit.
This l
lso gives the maximum temperature extremes for the site of-l.0°F and i3 'F.
hich is within the 3-day average temperature extreme limits of-40°F and 33°. SAR Table 2-13 gives a maximum 3-day average temperature of 93.5°F, w ich is less than the 106°F limit. Therefore, all environmental temperature limits for the MAGNASTOR system at the WCS CSIF are met.
Page G.3-6 All Indicated Changes are in response to RAI NP-8-1