ML20129J827

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Public Watchdogs 10 CFR 2.206 Petition - NRC Response to Petitioner E-mail Dated April 29, 2020, Regarding Request to Meet with Petition Review Board, May 7, 2020
ML20129J827
Person / Time
Site: HI-STORM 100
Issue date: 02/05/2020
From: Chris Bajwa
NRC/NMSS/DFM/CTCFB
To: Langley C
Public Watchdogs
CSBajwa NMSS/DFM/CTCF 415.5341
Shared Package
ML20036E926 List:
References
2.206
Download: ML20129J827 (3)


Text

From: Bajwa, Chris To: Charles Langley

Subject:

RE: Re: Follow-up on notification of Petition Review Board Initial Assessment of Public Watchdogs 2.206 Petition dated 02/05/2020 Date: Thursday, May 07, 2020 9:27:00 AM Attachments: image001.png

Dear Mr. Langley,

Good morning. Thank you for your e-mail of April 29, 2020. You indicated in your e-mail that you wish to meet with the Petition Review Board (PRB) to clarify and supplement your petition. Based on your request, I will schedule a public meeting with the PRB and include the contacts you provided.

In your e-mail you requested that the NRC provide you a copy of the flood analysis for the Holtec HI-STORM UMAX system. The document you request contains proprietary information and, as such, is not publicly available. If you wish to obtain a redacted version of the document, we refer you to the NRC Freedom of Information Act (FOIA) Guide specified in NRC Management Directive 8.11 Section II.A.2(d)(viii).

In your e-mail you further requested that the NRC provide documentation related to an issue that you describe as multiple thermal cycling. Your request introduces a new term that is different from what was provided in the original petition. As such, we recommend that you discuss this in further detail at the public meeting in order for the NRC to consider it as additional information.

Documentation of the NRC staffs analysis of the Holtec UMAX system may be found in the Agencywide Documents Access and Management System [ADAMS] Accession Nos.

ML15093A510, ML15252A423, and ML16341B129, for Amendments 0, 1 and 2, respectively. The Final Safety Analysis Report (FSAR) for the Holtec HI-STORM UMAX dry cask storage system may be found at ML18192B094.

Please do not hesitate to contact me if you have any questions.

Best regards, Chris Bajwa Division of Fuel Management (DFM)

Containment, Thermal, Chemical and Fire Protection Branch (CTCFPB)

Office of Nuclear Material Safety and Safeguards (NMSS)

  • T4-A60 l ( 301-415-5341 lFAX 301-415-0020 Chris.Bajwa@nrc.gov From: Charles Langley <langley@publicwatchdogs.org>

Sent: Wednesday, April 29, 2020 6:01 PM To: Bajwa, Chris <Chris.Bajwa@nrc.gov>; Paul <pmblanch@comcast.net>

Cc: Buckberg, Perry <Perry.Buckberg@nrc.gov>; Carpenter, Robert <Robert.Carpenter@nrc.gov>;

Williams, Kevin <Kevin.Williams@nrc.gov>; Hamdan, Latif <Latif.Hamdan@nrc.gov>; La Bella, Chuck

<CLaBella@btlaw.com>; Nina Babiarz <ninababiarz@outlook.com>

Subject:

[External_Sender] Re: Follow-up on notification of Petition Review Board Initial Assessment of Public Watchdogs 2.206 Petition dated 02/05/2020

Dear Mr. Bajwa,

Public Watchdogs is pleased to accept your invitation to "clarify and supplement" our 2.206 Petition in a public meeting with the Nuclear Regulatory Commission Petition Review Board, as referenced in your April 20, 2020 email to me, which I have attached as a pdf.

Please schedule the meeting and be sure to copy our technical consultant, Paul Blanch

( pmblanch@comcast.net ), our attorney, Chuck La Bella ( CLaBella@btlaw.com ), and my colleague, Nina Babiarz ( ninababiarz@outlook.com ) in your response.

It would be extremely helpful to us to receive a copy of the redacted flood analysis identified in the image embedded below as 4.6.2.5 Flood "PROPRIETARY INFORMATION WITHHELD IN ACCORDANCE WITH 10 CFR 2.390" from the Hi-Storm UMAX System Final Safety Analysis Report, Revision 5, June 27, 2018.

Second, in advance of this meeting, we also request a copy of the analysis demonstrating the ability of Holtec's pressurized MPC-37 canisters to withstand multiple thermal cycling.

This is not discussed in any of the licensing basis documentation.

In the attached letter you stated:

... SONGS ISFSI are manufactured from austenitic stainless steels, which are not susceptible to pressurized thermal shock; therefore, the canisters would remain intact for the accident events postulated in the petition. The response of spent fuel canisters to accident conditions has been evaluated and addressed in the FSAR. The NRC staff reviewed the FSAR for the UMAX system and found that the system meets all applicable NRC regulations for both structural and thermal aspects of the storage system design. In the NRC safety evaluation report (SER) for the UMAX Storage System (Amendment 0, ML15093A510) the staff concluded that:

The applicant has met the requirements of 10 CFR Part 72.236(b). The SSCs ITS* are designed to accommodate the combined loads of normal or off-normal operating conditions and accidents or natural phenomena events with an adequate margin of safety. Stresses at various locations of the cask for various design loads are determined by analysis. Total stresses for the combined loads of normal, off-normal, accident, and natural phenomena events are acceptable and are found to be within limits of applicable codes, standards, and specifications.

Please provide documented evidence that the selected materials of the casks have been demonstrated to withstand these postulated thermal cycles.

Cordially, Charles Langley, Executive Director Public Watchdogs (858) 384-2139 www.publicwatchdogs.org 7867 Convoy Court, Suite 302, San Diego CA 92111 On Tue, Apr 28, 2020 at 6:08 AM Bajwa, Chris <Chris.Bajwa@nrc.gov> wrote:

Dear Mr. Langley,

On April 20, 2020, I provided to you, via e-mail, the results of the initial assessment of the Petition Review Board (PRB) on your 2.206 Petition, submitted on February 5, 2020. As I have not received a response to this correspondence from you, I am reaching out to confirm that you received my initial communication of the PRB decision. Please confirm that you received the e-mail dated April 20, 2020 (available in the Agencywide Documents Access and Management System [ADAMS], Accession No. ML20119A047).

If you have any further questions regarding this communication, please do not hesitate to contact me.

Best regards, Chris Bajwa Division of Fuel Management (DFM)

Containment, Thermal, Chemical and Fire Protection Branch (CTCFPB)

Office of Nuclear Material Safety and Safeguards (NMSS)

  • T4-A60 l ( 301-415-5341 lFAX 301-415-0020 Chris.Bajwa@nrc.gov