ML20205L502

Amendment No. 15 to Certificate of Compliance No. 1014 for the HI-STORM 100 Multipurpose Canister Storage System - Second Request for Additional Information

ML20205L502
Person / Time
Site:	Holtec
Issue date:	08/04/2020
From:	Yen-Ju Chen Storage and Transportation Licensing Branch
To:	Manzione K Holtec
YJChen NMSS/DFM.STL 415.1018
References
CAC 001028, EPID L-2019-LLA-0059
Download: ML20205L502 (4)

Text

August 4, 2020 Ms. Kimberly Manzione Licensing Manager Holtec International One Holtec Boulevard Camden, NJ 08104

SUBJECT:

AMENDMENT NO. 15 TO CERTIFICATE OF COMPLIANCE NO. 1014 FOR THE HI-STORM 100 MULTIPURPOSE CANISTER STORAGE SYSTEM -

SECOND REQUEST FOR ADDITIONAL INFORMATION

Dear Ms. Manzione:

By letter dated March 20, 20190F1, and supplemented by letters dated September 16, 20191F2, April 28, 20202F3, May 15, 20203F4, June 12, 20204F5, and June 22, 20205F6, Holtec International submitted an amendment request to the U.S. Nuclear Regulatory Commission for the HI-STORM 100 Multipurpose Canister Storage System Certificate of Compliance (CoC)

No. 1014.

The NRC staff reviewed your application and determined the need for additional information as identified in the Second Request for Additional Information (RAI) in the enclosure to this letter.

We request that you provide the response to the RAI by August 14, 2020, in order to meet your timeliness needs for this amendment.

1 Agencywide Document Access and Management System (ADAMS) Accession No. ML19092A189.

2 ADAMS Accession No. ML19277H035.

3 ADAMS Accession No. ML20128J292.

4 ADAMS Accession No. ML20136A475.

5 ADAMS Accession No. ML20164A294.

6 ADAMS Accession No. ML20174A397.

K. Manzione 2

Please reference Docket No. 72-1014, CAC No. 001028 and EPID No. L-2019-LLA-0059 in future correspondence related to this licensing action. If you have any questions, please contact me at 301-415-1018.

Sincerely, Yen-Ju Chen, Sr. Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-1014 CAC No.: 001028 EPID No.: L-2019-LLA-0059

Enclosure:

2nd Request for Additional Information Yen-Ju Chen Digitally signed by Yen-Ju Chen Date: 2020.08.04 17:22:24 -04'00'

K. Manzione 3

SUBJECT:

AMENDMENT NO. 15 TO CERTIFICATE OF COMPLIANCE NO. 1014 FOR THE HI-STORM 100 MULTIPURPOSE CANISTER STORAGE SYSTEM -

SECOND REQUEST FOR ADDITIONAL INFORMATION DATED: August 4, 2020 DISTRIBUTION:

DFM r/f ADAMS Accession Number: ML20205L502

• via email OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME YChen WWheatley*

RRodriguez*

VWilson*

DATE 7/20/2020 7/15/2020 7/20/2020 7/10/2020 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME TBoyce*

RChang*

JMcKirgan*

AKock*

DATE 7/20/2020 7/20/2020 7/22/2020 8/4/2020 OFFICIAL RECORD COPY

Enclosure Second Request for Additional Information Docket No. 72-1014 Holtec International HI-STORM 100 Multipurpose Canister Storage System Certificate of Compliance No. 1014 Amendment No. 15 The U.S. Nuclear Regulatory Commission staff issued a request for additional information (RAI) on March 6, 2020, and Holtec provided its response on April 28, 2020, May 15, 2020, June 12, 2020, and June 22, 2020. The staff identified additional information needed in connection with its review of the application as provided in the second round of RAI discussed below. The question describes information needed by the staff to complete its review of the application and to determine whether the applicant has demonstrated compliance with regulatory requirements in 10 CFR Part 72.

RAI 3-6. Provide a dose rate analysis associated with the non-mechanistic tipover accident.

In Proposed Change #9, the applicant proposes to remove the dose evaluation from the accident analyses for the non-mechanistic tipover event. The applicant states that the basis for this removal is that the event is not credible.

The original RAI 3-6 requested that the applicant define credible and provide an assessment that this event meets that definition or provide the dose analysis. In its response to RAI 3-6, the applicant provided some information to justify that the event is not credible. The staff evaluated the response and found that it is not sufficient in that it only considered the risk of seismic events rather than a broader spectrum of possible initiating events.

The tipover event is a part of the design basis for this system as the non-mechanistic tipover event is identified as a design basis accident in the Final Safety Analysis Report Sections 2.2.3.2 and 11.2.3. The definition of Design Basis is provided in 10 CFR Part 72.3, which requires, in part, controlling parameters for the effects of a postulated event under which a structure, system, or component must meet its functional goals.

Thus, in order to support Amendment No. 15 for the HI-STORM 100, the staff is requesting that the applicant include the dose evaluation of the non-mechanistic tipover event. The regulations in 10 CFR 72.236(b) require, design bases and design criteria must be provided for structures, systems, and components important to safety. Further, 10 CFR 72.236(d) requires that the applicant for a CoC demonstrate that the shielding is sufficient to meet the requirements of 10 CFR 72.106, which includes maximum dose limits from any design basis accident.

Based on the aforementioned statements, the staff requests that the applicant provide the dose evaluation associated with the non-mechanistic tipover event.

This information is needed to ensure compliance with 10 CFR 72.236(b) and (d).