ML20267A166

Transmittal Letter and Rais: Application for the Model No. HI-STORM FW Storage System, Amendment No. 6 - Staggered First Request for Additional Information, Thermal Evaluation

ML20267A166
Person / Time
Site:	07201032
Issue date:	09/24/2020
From:	Santos N Storage and Transportation Licensing Branch
To:	O'Mullane C Holtec
NGSantos NMSS/DFM/STL 301.415.6999
Shared Package
ML20267A165	List: ML20267A166
References
EPID L-2019-LLA-0231
Download: ML20267A166 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 24, 2020 Christopher OMullane Licensing Engineer Holtec International Holtec Technology Campus 1 Holtec Blvd.

Camden, NJ 08104

SUBJECT:

APPLICATION FOR THE MODEL NO. HI-STORM FW STORAGE SYSTEM, AMENDMENT NO. 6 - STAGGERED FIRST REQUEST FOR ADDITIONAL INFORMATION

Dear Mr. OMullane:

By letter dated October 2, 2019 [Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML19282C357], and as supplemented on June 30, 2020 (ADAMS Package Accession No. ML20182A860), Holtec International (the applicant) requested to amend Certificate of Compliance (CoC) No. 1032, Model No. HI-STORM FW Storage System. The applicant proposes the following changes:

1) Adding an anchored configuration of the HI-STORM FW storage system.

2) Allowing non-single failure proof lifting equipment during handling of heavy loads processes (within the 10 CFR Part 72 jurisdictional boundary).

3) Revising LCO 3.1.2, SFSC Heat Removal System Operability, to allow an engineering evaluation to be performed in lieu of transferring the multi-purpose canister (MPC) into a transfer cask.

4) No longer require the annual submittal of a separate radioactive effluent report for the HI-STORM FW system.

5) For the MPC models MPC-37, -89, and -32ML, revise the following:

a. the allowable contents to clarify the requirements for fuel debris permitted for storage, and

b. the basket Design Features to clarify that the minimum cell inside dimension (ID) and minimum cell wall thickness are nominal dimensions.

The staff is issuing a staggered request for additional information. In connection with our review, we need the information identified in the enclosure to this letter. The enclosure contains only the questions related to the thermal evaluation. All other questions will be transmitted in a separate correspondence. Additional information requested by this letter should be submitted in the form of revised safety analysis report pages, when applicable. Please provide your complete responses to both requests for additional information within the same submittal.

C. OMullane Please reference Docket No. 72-1032 and EPID No. L-2019-LLA-0231 in future correspondence related to this request. The staff is available to meet and discuss your proposed responses. If you have any questions regarding this matter, I may be contacted at (301) 415-6999 or Norma.GarciaSantos@nrc.gov.

Sincerely, Norma Garcia Digitally signed by Norma Garcia Santos Santos Date: 2020.09.24 09:52:03 -04'00' Norma García Santos, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 72-1032 EPID No. L-2019-LLA-0231

Enclosure:

Request for Additional Information

Request for Additional Information HOLTEC International LLC Docket No. 72-1032 Certificate of Compliance No. 1032 Model No. HI-STORM FW Amendment No. 6 By letter dated October 2, 2019 [Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML19282C357], and as supplemented on June 30, 2020 (ADAMS Package Accession No. ML20182A860), Holtec International (the applicant) requested to amend Certificate of Compliance (CoC) No. 1032, Model No. HI-STORM FW Storage System.

This request for additional information (RAI) identifies information needed by the U.S. Nuclear Regulatory Commission (NRC) staff (the staff) in connection with its review of the application.

Each individual 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 10 CFR Part 72.

THERMAL EVALUATION RAI-4-1 Specify the allowable temperature limits are for normal or short term conditions in the HI-STORM FW, Amendment No. 6, Appendix A, Technical Specification (TS), Limiting Condition for Operation (LCO) 3.1.2, SFSC Heat Removal System, required action C.2.3, and in the associated bases B 3.1.2, SFSC Heat Removal System, for action C.2.3, on page 13.A-21 of the application, that are applicable to all components and contents.

In the HI-STORM FW, Amendment No. 6, Appendix A, Technical Specification 3.1.2, required action C.2.3, the applicant describes that an engineering evaluation shall be performed using the models and methods in the HI-STORM FW final safety analysis report (FSAR) to demonstrate, through this analysis, that all components and contents remain below allowable temperature limits and that the completion time is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The allowable temperature limits for normal or short-term conditions for the associated completion time have not been specified.

The bases B 3.1.2, action C.2.2, on page 13.A-20, of the application describes that the completion time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reflects the completion time from required action C.2.1 to ensure that component temperatures remain below their short-term temperature limits for the respective decay heat loads. However, the bases B 3.1.2, action C.2.3, on page 13.A-21, of the application describes the following:

1) an engineering evaluation may be performed to demonstrate that all component and content temperatures remain below temperatures that would prevent the component from performing its design function; and

2) if none of the components (and not described, the contents) exceed the temperatures determined above, the MPC can remain in the overpack.

Enclosure

Therefore, it is not clear in the HI-STORM FW, Appendix A, TS 3.1.2, required action C.2.3, or in the bases B 3.1.2, action C.2.3 of the application, if the temperature limits and the temperatures which would prevent it from performing its design function are short-term.

These clarifications are necessary to provide reasonable assurance that the HI-STORM FW spent fuel storage cask reasonably maintains the following:

1) adequate heat removal capacity without active cooling systems for clearly described temperature limits,

2) intact fuel cladding, and

3) the confinement of radioactive material under normal, off-normal, and credible accident conditions.

This information is necessary to determine compliance with 10 CFR 72.236(f) and 72.236(l).

RAI-4-2 Provide the following regarding HI-STORM FW, Amendment No. 6, Appendix A, TS 3.1.2, required action C.2.3 of LCO 3.1.2:

a) Summarize the technical bases to demonstrate that a completion time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is acceptable to perform an engineering evaluation.

b) Explain how an engineering evaluation is performed to demonstrate that component temperatures are within allowable limits.

c) Describe what type of engineering evaluation is needed to demonstrate that component temperatures are within allowable limits.

The HI-STORM FW, Amendment No. 6, Appendix A, TS 3.1.2, required action C.2.3 of LCO 3.1.2 notes that one option to return the system to operable condition would be to perform an engineering evaluation within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. It is not clear to the staff how an engineering evaluation, and what type of engineering evaluation that includes analysis and results, could be realistically performed in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (especially due to the complexity of the thermal model, if it is used in the evaluation).

The staff needs assurance that no safety limit would be exceeded during normal, short-term, off-normal, or accident conditions. See the response provided to RAI 4-1 in ADAMS Accession No. ML19311C517 and the associated page changes in ADAMS Accession No. ML19311C519.

This information is necessary to determine compliance with 10 CFR 72.236(b) and 72.236(f).