ML20063M015

HI-STORM 100 Renewal Presubmittal Meeting (Holtec Slides, 1-15-20)

ML20063M015
Person / Time
Site:	Holtec
Issue date:	03/03/2020
From:	Holtec
To:	Office of Nuclear Material Safety and Safeguards
Banovac K
References
CAC 001028, EPID L-2019-LRM-0085
Download: ML20063M015 (18)

Text

www.holtec.com HI-STORM 100 Part 72 License Renewal Pre-Submittal Meeting

www.holtec.com l Page 2 Meeting Purpose To share plans with the NRC staff for the application to review the HI-STORM 100 Storage CoC To obtain feedback from the NRC staff on renewal application prior to submittal

www.holtec.com l Page 3 HI-STORM 100 System Storage system Stainless Steel Canister (MPC)

- MPC-24 / 32 / 68 (including variants)

- Stainless steel baskets with neutron absorber within sheathing

- Metamic-HT baskets (68M and 32M)

Steel-Concrete-Steel cask

- Steel inner and outer shells

- Concrete filled between (no rebar)

- Also includes 100U underground HI-TRAC transfer cask (including variants)

HI-STORM 100S Version B

www.holtec.com l Page 4 HI-STORM 100 Schematics MPC HI-TRAC (125 ton)

www.holtec.com l Page 5 HI-STORM 100 License Expiration Date:

5/31/2020 Timely Renewal Date:

4/30/2020 14 Approved Amendments, 1 in process Number of versions of components, but all are essentially same materials

/ same environment

www.holtec.com l Page 6 Renewal Application Following guidance in NUREG-1927 Rev 1 and NEI-14-03 Have also reviewed the MAPS report, although significant portions of the application were developed prior to issuance of draft NUREG Apply for 40 year extension of the existing license Application requires Aging Management Programs (AMPs) or Time-limited Aging Analyses (TLAAs)

www.holtec.com l Page 7 Renewal Application Overview Chapter 1 - General Information Chapter 2 - Scoping Evaluation Chapter 3 - Aging Management Review Chapter 4 - Aging Management Tollgates Appendix A - AMPs Appendix B - TLAAs Appendix C - System Inspections Appendix D - FSAR Changes Appendix E - CoC / Tech Spec Changes

www.holtec.com l Page 8 HI-STORM 100 Scoping Process - Following NUREG-1927 2 Scoping Questions

- Classified as Important to Safety (ITS)?

- Classified as Not Important to Safety (NITS), but failure could prevent fulfillment of an ITS function?

Applied to major SSCs in HI-STORM 100 System

www.holtec.com l Page 9 HI-STORM 100 Scoping Structure, System, or Component (SSC)

Scoping Results In-Scope SSC Criterion 1Note 1 Criterion 2Note 2 MPC Yes N/A Yes HI-STORM 100 Overpack / 100U Yes N/A Yes HI-TRAC Yes N/A Yes Fuel Assembly Note 3 Yes N/A Yes ISFSI Pad No No No ISFSI Security Equipment No No No Fuel Transfer and Auxiliary Equipment No No No Notes:

1. SSC is ITS

2. SSC is NITS but failure could prevent ITS function from being fulfilled

3. Fuel pellets not included

www.holtec.com l Page 10 HI-STORM 100 Scoping Application breaks down into sub-components and intended function Further evaluation only based on those that have intended safety function

- Safety function based on: confinement, criticality control, heat transfer, structural integrity, shielding, and retrievability

- Example: MPC drain tube, not considered for aging as it does not serve those functions during extended storage period Tables in application go into detail on materials, environment, etc

www.holtec.com l Page 11 AMPs / TLAAs AMPs

- MPC AMP

- Overpack AMP

- HI-TRAC AMP

- Fuel Assembly AMP

- 100U Concrete AMP TLAAs

- Neutron Absorber Depletion

- HI-TRAC Trunnions

- MPC Fatigue

- Fuel Cladding Integrity

www.holtec.com l Page 12 HI-STORM 100 MPC AMP Visual inspection of MPC exterior surface

- VT-3 of accessible areas

- 1 canister at each site, frequency of 5 years

- AMP contains guidance for how to select canister AMP contains criteria for results that do not require further evaluation and results that do require further evaluation All corrective actions / confirmation are referred to the sites QA program

www.holtec.com l Page 13 HI-STORM 100 Overpack AMP Covers both internal and external External continues annual inspection already required in the FSAR - performed annually Internal is recommended to be performed concurrent with the MPC AMP

- Visual inspection of internal overpack components

- One overpack, every 5 years All corrective actions / confirmation are referred to the sites QA program

www.holtec.com l Page 14 Transfer Cask AMP Transfer cask not necessarily in constant use during period of extended storage AMP is focused on pre-use inspections AMP contains acceptance criteria that does not require further evaluation, anything beyond the listed criteria requires additional evaluation Corrective action in accordance with sites program

www.holtec.com l Page 15 High Burnup Fuel AMP Relies on EPRI / DOE High Burnup Dry Storage Cask Research and Development Project Application is based on NRC guidance in NUREG-1927 and NUREG-2214

www.holtec.com l Page 16 HI-STORM 100U Concrete AMP Following Standard in ACI-349 - quantitative three-tier

- Acceptance without further evaluation - free of significant deficiencies

- Acceptance after review - some degradation, but can maintain design basis function

- Acceptance requiring further evaluation - degradation, could prevent design basis function from being maintained Corrective actions from tier 2 and 3 are referred to the sites QA program Also includes groundwater monitoring No HI-STORM 100Us currently in service, but renewal still requested

www.holtec.com l Page 17 HI-STORM 100 Changes -

72.48s / Other CoC Renewal application process will evaluate changes made under 72.48 related to HI-STORM 100 Application also evaluates manufacturing deviations Any changes that impact aging management will be identified No change in aging management across amendments, since materials and environments are the same across all amendments

www.holtec.com l Page 18 Schedule Timely renewal date 4/30/2020 Planned submittal January 2020