ML20182A805

International Clarification of Response to NRC Follow-Up Inspection and NOV

ML20182A805
Person / Time
Site:	Holtec
Issue date:	06/20/2020
From:	Manzione K Holtec
To:	Earl Love Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML20182A804	List: ML20182A805 ML20182A811
References
5014903, IR 2019201
Download: ML20182A805 (2)

Text

Holtec Technology Campus, One Holtec Blvd, Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 June 20, 2020 Earl Love, Inspections and Operations Branch Division of Spent Fuel Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Clarification of Response to NRC Follow-Up Inspection and NOV Reference(s): [1] Staff Review of Holtec International Response to the U.S. Nuclear Regulatory Commission Follow-Up Inspection Report Number 07201014/2019-201, and Notice of Violation (Letter from Alayna Pearson (NRC) to Dr. Kris Singh (Holtec) dated March 18, 2020)

Dear Mr. Love:

By letter dated March 18, 2020 [1], NRC staff requested that Holtec clarify its response to the previous inspection and NOV. The previous information submitted included discussions of minimum wall thickness per ASME NB-3324. These were intended to be supplemental to the engineering justification by providing an additional comparison to demonstrate available margin.

However, Holtec understands that this minimum wall thickness formula is not to be construed as a formula for acceptable thickness and that it doesnt take into account all of the load conditions for the MPC. Therefore, Holtec has updated the engineering documents (included as Attachments 1 through 4 of this letter) to clarify that the basis for the change is acceptable because the indications are local structural discontinuities. Based on the ASME Code and the material of the MPC, these local structural discontinuities are not of concern for compliance with ASME Section III or any of the design or licensing requirements for the HI-STORM UMAX. A full technical justification is provided in the attached ECOs and 72.48s.

Additionally, Holtec has performed an analysis to demonstrate that any credible scratch is still within the definition of local structural discontinuity. This information is provided to the NRC as additional assurance that any scratch is within the technical justification above.

Because the attached documents are considered proprietary, an affidavit requesting they be withheld from public disclosure is also included.

Document ID 5014903 Page 1 of 2

Holtec Technology Campus, One Holtec Blvd, Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 If you have any questions, please contact me at 856-797-0900 ext. 3951.

Sincerely, Kimberly Manzione Licensing Manager, Holtec International Attachments: : ECO 5021-39 Rev 4 (proprietary) : ECO 5021-42 Rev 3 (proprietary) : 72.48 # 1357 Rev 4 (proprietary) : 72.48 # 1384 Rev 3 (proprietary) : HI-2125228 Rev 15, Calculation 13 (proprietary) : Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure (non-proprietary)

Document ID 5014902 Page 2 of 2