ML20261H474
| ML20261H474 | |
| Person / Time | |
|---|---|
| Site: | 07109381 |
| Issue date: | 09/17/2020 |
| From: | Pierre Saverot Storage and Transportation Licensing Branch |
| To: | Ngwayah R Holtec |
| Saverot P | |
| References | |
| EPID L-2018-NEW-0007 | |
| Download: ML20261H474 (5) | |
Text
T. Tate UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 17, 2020 Mr. Royston Ngwayah Holtec International 1 Holtec Blvd Camden, NJ 08104
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE MODEL NO. HI-STAR 180L PACKAGE
Dear Mr. Ngwayah:
By letter dated April 10, 2020, you submitted an application for Certificate of Compliance No.
9381, Revision No. 0, for the Model No. HI-STAR 180L package. The staff performed an acceptance review of your application and shared with you Observations by letter dated May 18, 2020.
The staff has determined that further information is needed to complete its technical review.
The information requested is listed in the enclosure to this letter. We request you provide this information by October 31, 2020. If you are unable to meet this deadline, you must notify us in writing no later than October 5, 2020, of your new submittal date and the reasons for the delay.
The staff will then assess the impact of the new submittal date and notify you of a revised schedule.
Please reference Docket No. 71-9381 and EPID- L-2018-NEW-0007 in future correspondence related to this licensing action. If you have any questions regarding this matter, please contact me at 301-415-7505.
Sincerely, Pierre M. Digitally signed by Pierre M. Saverot Saverot Date: 2020.09.17 13:48:17
-04'00' Pierre Saverot, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-9381 EPID No. L-2018-NEW-0007
Enclosure:
Request for Additional Information
- via email OFFICE: NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME: PSaverot* DTarantino* YKim* TBoyce* SFigueroa*
DATE: 09/01/2020 09/04/2020 09//2020 09/04/2020 09/08/2020 OFFICE: NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME: JMcKirgan*
DATE: 09/17/2020 Request for Additional Information HOLTEC INTERNATIONAL Docket No. 71-9381 Model No. HI-STAR 180L Package By letter dated April 10, 2020, Holtec International (the applicant) submitted an application for Certificate of Compliance No. 9381, Revision No. 0, for the Model No. HI-STAR 180L package.
The staff performed an acceptance review of the application and transmitted, by letter dated May 18, 2020, Observations from the acceptance review. On July 31, 2020, Holtec responded to staffs Observations and provided revised thermal evaluations in Holtec Report HI-2177931R3.
Each individual request for additional information (RAI) describes information needed by the staff to complete its review of the application and to determine whether the applicant has demonstrated compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 71.
The requested information is listed by chapter number and title in the package application.
NUREG-1617, Standard Review Plan for Transportation Packages for Spent Nuclear Fuel, was used for this review.
CHAPTER 1 GENERAL INFORMATION 1.1 Specify tolerances on the licensing drawings.
NUREG/CR-5502, Engineering Drawings for 10 CFR Part 71 Package Approvals, provides guidance for preparing drawings of transportation packages and states that engineering drawings should have tolerances that are consistent with the package evaluation. Without tolerances, structural components could, in particular, be fabricated in a way that alters load paths and energy absorption capability of the component, etc.
The applicants desired flexibility in the package design may be achieved by specifying tolerances in the package design drawings that are large enough to bound reasonable variations in fabrication (see guidance in the staffs ISG-20). The package design shall be correctly translated into specifications and drawings with an appropriate consideration of design tolerances for all Important To Safety (ITS) components.
This information is required to demonstrate compliance with 10 CFR 71.33(a) and 71.107(a).
CHAPTER 2 MATERIALS AND STRUCTURAL REVIEW 2.1 Provide (i) maximum and minimum gaps allowed between baseplate and fuel basket and assemblies in the design, and (ii) a calculation package to demonstrate that there are no effects of thermal expansions and gaps on the dynamic behaviors of the package during transient events (drop conditions).
The applicant provided a statement in Subsection 2.6.1 as following: To provide for sufficient clearance during insertion of basket and assemblies, and to account for thermal expansion, carefully calibrated gaps are incorporated in the design between the Enclosure
various components of the package, i.e., the cask body, basket and assemblies. These gaps are small compared to other characteristic dimensions such as the cask diameter, or the crush depth of the impact limiters. Hence they are not expected to have a significant effect on the overall dynamic behavior of the package during transient events (drop conditions).
Thermal expansion, which is closely related to the presence of gaps in the package, is an important factor to affect the dynamic behaviors of the package during transient events (drop conditions), therefore, both thermal expansion and gaps should be considered together in the evaluation. The applicants statement provided above is vague and the applicant needs to provide more detailed information for the staff to complete the thermal expansion and gap reviews.
This information is required to demonstrate compliance with 10 CFR 71.43(f) and 71.71(c)(1).
2.2 Provide the results of the stress analyses with calculations for factor of safety in a tabular form for the following:
(i) Containment shell for an end drop ( = 90°) under NCT, and (ii) Fuel basket for both side drop ( = 0°) and end drop ( = 90°) under NCT.
In Subsection 2.6.4 of the SAR, Revision 1, the applicant provided a paragraph explaining how it evaluated free drop of the HI-STAR 180L under NCT. Table 2.6.6 of the SAR, Revision 1 provided the results of the side drop ( = 0°) analysis for the containment shell under NCT, but it did not provide the results of: (i) end drop ( = 90°)
analysis for the containment shell, and (ii) both side and end drop analyses for the fuel basket under NCT. The applicant needs to provide the information for the NRC staff to complete the review for the package under NCT free drop.
This information is required to demonstrate compliance with 10 CFR 71.43(f) and 71.71(c)(6).
2.3 Clarify the fracture toughness testing acceptance criteria for the procured bolt steel for the HI-STAR 180L outer closure lid and provide a technical basis for any criteria that deviates from the design code.
Table 1.2.1, Major Constituent Parts of the HI-STAR 180L Cask, item 4, of the application stated that the Double Closure Lid System (DCLS) defines the top region of the containment boundary (designed per Section III, Subsection NB of the ASME Code) and must be sufficiently robust to withstand loadings under accident conditions of transport. HI-STAR 180L licensing drawing 10942, Revision 3, sheet 2 of 7, bill of materials, item 26 lists ASME SA-193 Grade B7 as an acceptable specification to fabricate bolt material for the outer closure lid.
ASME Section III Subsection NB-2300 includes testing requirements and acceptance criteria for procured steels to verify that the steels were produced with adequate fracture toughness. Table 8.1.5, Fracture Toughness Test Criteria: Containment System, of the application does not include a description of the toughness testing acceptance criteria for the ASME SA-193 Grade B7 bolt steel. In addition, the applicant provided no basis for not requiring fracture toughness testing of this bolt steel.
In order to complete its review, the staff requires information on the fracture toughness acceptance criteria for the procured SA-193 Grade B7 steel and a technical basis for any
criteria that deviates from the design code. The applicant should revise Table 8.1.5 of the application per the response, as appropriate.
This information is required to demonstrate compliance with 10 CFR 71.33(a)(5).