Letter Sequence RAI |
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Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance
- Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement
Administration
- Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance
- Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting
Results
- Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval
Other: L-23-005, Independent Spent Fuel Storage Installation License Renewal Application, Revision 1 (Cac/Epid No. 001028/L-2022-RNW-0007), ML19150A559, ML19182A107, ML20002A442, ML20009D008, ML20010D564, ML20015A450, ML20015A451, ML20015A454, ML20028E845, ML20028E846, ML20049A082, ML20052E146, ML20052E154, ML20065N281, ML20071F156, ML20076D696, ML20099A180, ML20104C015, ML20104C018, ML20104C019, ML20105A135, ML20105A136, ML20105A137, ML20105A138, ML20105A139, ML20105A173, ML20111A240, ML20136A050, ML20136A051, ML20150A335, ML20150A421, ML20155K741, ML20155K743, ML20155K744, ML20161A088, ML20163A702, ML20163A703, ML20163A704, ML20181A211, ML20181A212, ML20192A328, ML20192A329, ML20212L768, ML20212L769, ML20261H420, ML20269A259, ML20279A577, ML20279A586, ML20289A493... further results
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MONTHYEARML20052D9362018-07-0303 July 2018 Response to Nrg Request for Additional Information (RAI) Regarding NAC Magnastor Cask Loaded to Incorrect Helium Backfill Density Project stage: Request ML18267A2142018-08-29029 August 2018, 25 September 2018 Package: Summary of August 29, 2018, Public Meeting with Interim Storage Partners to Discuss Consolidated Emergency Response Plan for Its Proposed WCS Consolidated Interim Storage Facility (W/Enclosure 1 and 2) Project stage: Request ML18267A2112018-09-25025 September 2018 Memorandum to A. Rivera-Varona Summary of August 29, 2018, Public Meeting with Interim Storage Partners to Discuss Consolidated Emergency Response Plan for Its Proposed WCS Consolidated Interim Storage Facility (W/Enclosure 1 and 2) Project stage: Meeting ML18320A1842018-11-16016 November 2018 Letter to J. Isakson Interim Storage Partners' License Application to Construct and Operate the Waste Control Specialists Consolidated Interim Storage Facility, Andrews County, Texas, Dkt No. 72-1050 - First RAI, Part 1 (W/Enclosure 1) Project stage: RAI ML18362A3032018-12-28028 December 2018 E-Mail from K. Banovac to K. Manzione Acknowledgement of NRC Receipt of HI-STAR 100 CoC Renewal Application Project stage: Other ML19032A2302019-02-0404 February 2019 Summary of Closed Public Meeting to Discuss RAI Issued in Connection with Nrc'S Review of the Interim Storage Partner Consolidated Isfs Application for a Facility at Andrews County, Texas (W/Encl. 1&2) Project stage: RAI ML19065A0192019-03-0606 March 2019 Letter to J. Isakson Interim Storage Partners Llc'S License Application to Construct and Operate the WCS Consolidated Interim Storage Facility, Andrews County, Texas, Docket No. 72.1050 - First Request for RAI Part 2 (W/Enclosure 1) Project stage: RAI ML19072A1562019-03-14014 March 2019 Summary of Partially Closed Public Meeting to Discuss Request for Additional Information Issued in Connection with Nrc'S Review of the ISP Cisf Application for a Facility at Andrew'S County, Tx (W/Encl. 1&2) Project stage: RAI ML19086A1352019-03-26026 March 2019 E-Mail from K. Banovac to K. Manzione Starting Acceptance Review of HI-STAR 100 CoC Renewal Application Project stage: Acceptance Review ML19126A0682019-04-0303 April 2019, 6 May 2019 Summary of April 16, 2019, Partially Closed Public Meeting to Discuss RAI Issued in Connection with Nrc'S Review of the ISP Consolidated Isf Application for a Facility at Andrews County, Texas Project stage: Request ML19094A7402019-04-0303 April 2019 4/3/19, E-Mail from K. Banovac/Nrc to K. Manzione/Holtec Holtec Letter 5014860 - Question About Proprietary Information - Follow-up Information Project stage: Other ML19105B2172019-04-19019 April 2019 Memorandum to C. Regan Summary of March 20, 2019, Public Meeting to Discuss Request for Additional Information Issued in Connection with Nrc'S Review of the Interim Storage Partners Consolidated Isf Application (W/Enclosures 1 and 2) Project stage: RAI ML19120A4282019-04-23023 April 2019 Letter to J. Isakson Interim Storage Partners Llc'S License Application to Construct and Operate the Waste Control Specialists Consolidated Interim Storage Facility, Andrews County, Texas, Dkt No. 72-1050 - First RAI (W/Enclosure) Project stage: RAI ML19126A0662019-05-0606 May 2019 Memorandum to C. Regan Summary of April 16, 2019, Partially Closed Public Meeting to Discuss RAI Issued in Connection with Nrc'S Review of the ISP Consolidated Isf Application for a Facility at Andrews County, Texas (W/Enclosure 1 & 2) Project stage: RAI ML20015A4502019-05-31031 May 2019 Sprint Andrews County Disposal Facility, Andrews County, Texas- Railroad Commission of Texas Commercial Processing and Disposal Facility Permit Application Project stage: Other ML19150A5592019-06-0303 June 2019 Letter to J. Isakson Site Audit Plan for Interim Storage Partners Proposed Application for a Site-Specific License of an Away-from-Reactor Independent Spent Fuel Storage Installation Project stage: Other ML19182A1072019-07-0101 July 2019 Letter to J. Isakson Interim Storage Partners Llc'S Application for a Specific ISFSI for the Waste Control Specialists Consolidated Interim Storage Facility for Spent Nuclear Fuel - Revised Review Schedule Project stage: Other ML20015A4512019-08-22022 August 2019 Report No. R1432-01, Acoustical Analysis of ISP Cisf Project stage: Other ML19317D5782019-11-0606 November 2019 HI-STAR 100 CoC Renewal Acceptance Letter Project stage: Acceptance Review ML20015A4542019-11-30030 November 2019 Socioeconomic Impacts of the Proposed Spent Nuclear Fuel Consolidated Interim Storage Facility, Andrews County, Texas, Revision 5 Project stage: Other ML19357A1762019-12-18018 December 2019 NAC International - Submission of a Request to Renew the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1025 for the NAC-MPC Cask System Project stage: Request ML20002A4422019-12-20020 December 2019 International _Affidavit Project stage: Other ML19354A7142019-12-20020 December 2019 Approval of Tn America Request for Withholding Information from Public Disclosure for Coc 1029 Renewal Request for Supplemental Information Responses (CAC No. 001028) Project stage: Withholding Request Acceptance ML19360A0472019-12-26026 December 2019 Internationals Application for Specific Independent Spent Fuel Storage Installation License for the Hi-Store Consolidated Interim Storage Facility for Spent Nuclear Fuel - Request for Clarification of Responses Related to Emergency Response Project stage: Approval ML20009D0512020-01-0606 January 2020 Notification of NRC Acceptance of the Standardized Advanced NUHOMS CoC 1029 Renewal Application for Review Project stage: Acceptance Review ML20009D0082020-01-0606 January 2020 Acknowledgement of NRC Receipt of CoC 1025 (NAC-MPC) Renewal Application Project stage: Other ML20015A4522020-01-0606 January 2020 Interim Storage Partners LLC - Submittal of Supplemental Information in Support of RAI, Part 3 - Clarification Related to the Response to RAI AQ-6 Project stage: Supplement ML19354B6372020-01-0707 January 2020 Exemption Request for NAC Magnastor Cask Loaded to Incorrect Helium Backfill Density Request for Additional Information Project stage: RAI ML20010D5642020-01-10010 January 2020 Proprietary Determination Letter for HI-STAR 100 CoC Renewal Submittals Project stage: Other ML20028E8462020-01-17017 January 2020 Enclosure 3 - RAIs and Responses Project stage: Other ML20028E8452020-01-17017 January 2020 Enclosure 1 - Affidavits Project stage: Other ML20031D0562020-01-29029 January 2020 Interim Storage Partners, LLC - Submittal of ISP Updated Draft Responses for Rals NP-8-1, NP-8-2 and Associated SAR Markups from First Request for Additional Information, Part 2, Docket 72-1050 Cac/Epid 001028/L-2017-NEW-0002 Project stage: Draft Request ML20049A0822020-01-31031 January 2020 International - HI-STORM 100 Storage CoC Renewal Application Project stage: Other ML20049A0812020-01-31031 January 2020 Holtec International - HI-STORM 100 Storage CoC Renewal Application Project stage: Request ML20034E8352020-02-0303 February 2020 Letter-Materials Request for Additional Information Clarification with Enclosure Project stage: RAI ML20034E9872020-02-11011 February 2020 Meeting Summary - Meeting with Westinghouse Electric Company, LLC, Pre-Application Amendment No. 5 of Storage CoC No. 1026 for the Fuelsolutions Spent Fuel Management System, November 21, 2019 Project stage: Meeting ML20052D9962020-02-14014 February 2020 Interim Storage Partners, LLC - Submission of ISP Responses for RAIs and Associated Document Markups from First Request for Additional Information, Part 2, Docket 72-1050 Cac/Epid 001028/L-2017-NEW-0002 Project stage: Request ML20052E1462020-02-17017 February 2020 Interim Storage Partners, LLC - Submittal of Revision 3 of the Environmental Report for the WCS CISF, Docket 72-1050 Cac/Epid 001028/L-2017-NEW-0002 Project stage: Other ML20052E1542020-02-17017 February 2020 WCS Consolidated Interim Spent Fuel Storage Facility Environmental Report, Revision 3 - Part 2 of 3 Project stage: Other ML20064F6162020-02-29029 February 2020 January 15, 2020, Summary of Meeting with Holtec International, Inc., to Discuss the Upcoming Submittal of the Application for Renewal of the Storage Certificate of Compliance No. 1014 for the HI-Storm 100 Cask System Project stage: Meeting ML20063M0152020-03-0303 March 2020 HI-STORM 100 Renewal Presubmittal Meeting (Holtec Slides, 1-15-20) Project stage: Meeting ML20064E6222020-03-0303 March 2020 U.S. Nuclear Regulatory Commission Approval of NAC International Request for Withholding Information from Public Disclosure for Coc 1025 Renewal (CAC No. 001028) Project stage: Withholding Request Acceptance ML20071F1562020-03-0505 March 2020 Interim Storage Partners, LLC - Affidavit Project stage: Other ML20065J4272020-03-0505 March 2020 Submittal of Renewal Application for the TN-32 Dry Storage Cask - CoC 1021 Project stage: Request ML20071F1532020-03-0505 March 2020 Interim Storage Partners, LLC - Supplemental Information in Support of NRCs Environmental Review Project stage: Supplement ML20071J0552020-03-0505 March 2020 Notice of Cancelled Meeting with the U.S. Department of Energy, Idaho Operations Office to Discuss the Upcoming Submittal of the Application for Renewal of the Idaho Spent Fuel Facility License (SNM-2512) Project stage: Meeting ML20066K5782020-03-0606 March 2020 Acceptance Review of Request for Amendment No. 7 to Certificate of Compliance No. 1032 for the HI-STORM Flood/Wind Multipurpose Canister Storage System Project stage: Acceptance Review ML20065L3442020-03-0606 March 2020 Amendment No. 15 to Certificate of Compliance No. 1014 for the Hi-Storm 100 Multipurpose Canister Storage System - Request for Additional Information Project stage: RAI ML20065N2812020-03-0909 March 2020 ISFSI Preamble-License Renewal Order Project stage: Other ML20071D9942020-03-11011 March 2020 Submittal of HI-STAR 100 Updated FSAR, Revision 4 Project stage: Request 2019-05-06
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Category:Letter
MONTHYEARML22257A1072022-09-0707 September 2022 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report ML22063B1362022-03-0404 March 2022 International - Submittal of Updated FSAR for Renewed CoC ML21316A2062021-11-16016 November 2021 Transmittal Letter, Issuance of Renewed CoC No. 1008, HI-STAR 100 Cask System ML21301A1662021-10-28028 October 2021 Inspection, NRC Inspection Report 07201014/2021201 ML21295A3502021-10-22022 October 2021 Submittal of Revision 5 of the Final Safety Analysis Report (FSAR) for the HI-STAR 100 Dry Spent Fuel Storage System ML21194A4042021-07-13013 July 2021 Internationa - Extreme Environmental Phenomena During Short Term Operations within 10CFR72 Jurisdiction - Update ML21175A0462021-06-23023 June 2021 International, Submittal of Position Paper DS-481, Consideration of Transient Loadings During Short Term Operations ML21132A2982021-05-12012 May 2021 International - Extreme Environmental Phenomena During Short Term Operations within 10CFR72 Jurisdiction ML20351A3712020-12-16016 December 2020 Proprietary Determination Letter for HI-STAR 100 11-13-2020 Submittal ML20329A3222020-11-24024 November 2020 International, Submittal of Clarification RAI Responses on HI-STAR 100 License Renewal - Updated Attachment ML20318A3222020-11-13013 November 2020 Submittal of Clarification RAI Responses on HI-STAR 100 License Renewal ML20267A3452020-09-30030 September 2020 Request for Clarification of Response to RAI for HI-STAR 100 CoC Renewal Application ML20163A7142020-06-11011 June 2020 International Submittal of Responses to NRC RAIs on the Renewal of the HI-STAR 100 Storage CoC ML20153A7692020-06-0101 June 2020 International, Submittal of Responses to NRC RAIs on the Renewal of the HI-STAR 100 Storage CoC ML20104A0402020-04-10010 April 2020 Request for Additional Information for HI-STAR 100 CoC Renewal Application ML20071D9942020-03-11011 March 2020 Submittal of HI-STAR 100 Updated FSAR, Revision 4 ML20010D5642020-01-10010 January 2020 Proprietary Determination Letter for HI-STAR 100 CoC Renewal Submittals ML19317D5782019-11-0606 November 2019 HI-STAR 100 CoC Renewal Acceptance Letter ML19270D3602019-09-27027 September 2019 Amendment No. 3 to Certificate of Compliance No. 1008 for the HI-STAR 100 Storage System SVPLTR 19-0049, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2019-09-10010 September 2019 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report ML18298A0572018-10-23023 October 2018 Letter to K. Manzione Holtec International Certificate of Compliance Nos. 1008, 1014, 1032, and 1040 - Request for Withholding Information from Public Disclosure SVPLTR 18-0025, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2018-08-15015 August 2018 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report ML18192A1572018-07-10010 July 2018 Letter to K. Manzione Holtec International Certificate of Compliance No. 1008 - Request for Withholding Information from Public Disclosure ML18192A6312018-07-10010 July 2018 Letter to K. Manzione Holtec International Certificate of Compliance No. 1008 - Request for Withholding Information from Public Disclosure ML18192B0262018-07-10010 July 2018 Letter to K. Manzione Holtec International Certificate of Compliance No. 1008 - Request for Withholding Information from Public Disclosure ML16251A0762016-09-0101 September 2016 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report ML13228A3992013-08-12012 August 2013 Letter to Holders of Independent Spent Fuel Storage Installation (ISFSI) Licenses Re Rescission of Certain Security Orders Concerning Spent Nuclear Fuel in Transit - Rin 3150-AI64 (NRC-2009-0163) EA-02-109 NL-04-2181, Joseph M. Farley Nuclear Plant, Request for Exemption from 10 CFR 72.124(c) - Criticality Monitors2005-01-19019 January 2005 Joseph M. Farley Nuclear Plant, Request for Exemption from 10 CFR 72.124(c) - Criticality Monitors RS-02-002, Registration of Use of Cask to Store Spent Fuel2002-01-28028 January 2002 Registration of Use of Cask to Store Spent Fuel ML0605903291999-10-21021 October 1999 Correction of Distribution Error on Holtec Hl-STAR 100 Certificate of Compliance 1008 ML0605903151999-10-13013 October 1999 Issuance of Page Changes to Certificate of Compliance for the Holtec HI-STAR 100 Cask System 2022-09-07
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 30, 2020 Ms. Kimberly Manzione Licensing Manager Holtec International Holtec Technology Campus One Holtec Boulevard Camden, NJ 08104
SUBJECT:
REQUEST FOR CLARIFICATION OF RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION FOR THE TECHNICAL REVIEW OF THE APPLICATION FOR RENEWAL OF THE CERTIFICATE OF COMPLIANCE NO.
1008 FOR THE HI-STAR 100 STORAGE CASK SYSTEM (CAC/EPID NOS.
001028/L-2018-RNW-0030)
Dear Ms. Manzione:
By letter dated December 7, 2018, as supplemented on June 28, 2019, and October 10, 2019, Holtec International (Holtec) applied for renewal of the Certificate of Compliance (CoC) No.
1008 for the HI-STAR 100 Storage Cask System (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML18345A178, ML19184A232, and ML19288A089). The U.S. Nuclear Regulatory Commission (NRC) staff sent a request for additional information (RAI) related to the technical review of the renewal application on April 10, 2020 (ADAMS Accession No. ML20104A040), to which you responded on June 1, 2020 (ADAMS Accession No. ML20153A768). The NRC staff reviewed Holtecs RAI responses and determined that the enclosed clarifications to the RAI responses are needed for the NRC staff to complete its technical review.
In addition, during the staffs review of the renewal application, Holtec submitted Revision 4 of the HI-STAR 100 Final Safety Analysis Report (FSAR), by letter dated March 11, 2020 (ADAMS Accession No. ML20071D992). This FSAR, Revision 4 includes the changes made in Amendment No. 3 to the CoC. The NRC staff considered these additional FSAR revisions in its review of the renewal application and has some questions regarding the revisions, which are included in the enclosed request for clarification.
Discussion of this request for clarification occurred on September 28, 2020. We request that you provide this information within 45 days from the date of this letter. Inform us at your earliest convenience, but no later than 2 weeks before the response date, if you are not able to provide the information by that date. To assist us in rescheduling your review, you should include a new proposed submittal date and the reasons for the delay.
K. Manzione 2
Please reference Docket No. 72-1008 and CAC/EPID Nos. 001028/L-2018-RNW-0030 in future correspondence related to this request. The NRC staff is available to clarify these questions, and if necessary, to meet and discuss your proposed responses. If you have any questions regarding this matter, please contact me at 301-415-7116 or Kristina.Banovac@nrc.gov.
Sincerely, Kristina L. Banovac, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-1008 CAC/EPID Nos.: 001028/L-2018-RNW-0030
Enclosure:
Request for Clarification Kristina L.
Banovac Digitally signed by Kristina L. Banovac Date: 2020.09.30 08:47:12 -04'00'
ML20267A345 OFFICE NMSS/DFM/STL NMSS/DFM/MSB NMSS/DFM/STL NMSS/DFM/MSB NAME KBanovac JWise WWheatley TBoyce DATE 9/16/2020 9/17/2020 9/17/2020 9/22/2020 OFFICE NMSS/DFM/STL NAME BWhite for JMcKirgan DATE 9/23/2020
Enclosure Request for Clarification Holtec International Docket No. 72-1008 Certificate of Compliance Renewal By letter dated December 7, 2018, as supplemented on June 28, 2019, and October 10, 2019, Holtec International (Holtec) applied for renewal of the Certificate of Compliance (CoC) No.
1008 for the HI-STAR 100 Storage Cask System (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML18345A178, ML19184A232, and ML19288A089). The U.S. Nuclear Regulatory Commission (NRC) staff sent a request for additional information (RAI) related to the technical review of the renewal application on April 10, 2020 (ADAMS Accession No. ML20104A040), to which you responded on June 1, 2020 (ADAMS Accession No. ML20153A768).
This request for clarification of RAI responses identifies information needed by the NRC staff to complete its technical review of the renewal application and to determine whether the applicant has demonstrated compliance with the regulatory requirements. The requested information is listed by RAI response number.
Chapter 2: Scoping Evaluation RAI 2-3 and RAI 2-4 Follow-up Revise the scoping and aging management review (AMR) tables in the renewal application to clarify the responses to an NRC Observation and RAIs with respect to the subcomponents that were determined to be within scope of renewal.
The responses to NRC Observation 3 (Holtec, 2019) and RAIs 2-3 and 2-4 (Holtec, 2020) were provided to clarify which subcomponents were concluded to be within the scope of the renewal review and subject to an AMR. This clarity was sought to allow the staff to complete its review of the application and to ensure that the scoping and AMR tables (which are referenced in the aging management programs and in the proposed changes to the HI-STAR 100 Final Safety Analysis Report (FSAR) in Appendix D of the renewal application) provided an accurate description of the aging management activities in the period of extended operation.
The staff identified apparent discrepancies in the response to the Observation, responses to RAIs, and the scoping and AMR tables in the renewal application. As a result, revise the renewal application to clarify the following:
- 1. Revise Table 2.1-3 of the renewal application, MPC Basket Subcomponents, to provide a conclusion as to whether the Optional Heat Conduction Elements are within scope of the renewal. If these elements are concluded to not be within the scope (as stated in the response to RAI 2-3), remove them from Table 3.3-2, Aging Management Review of MPC Basket Subcomponents.
- 2. As appropriate, revise the scoping and AMR tables to ensure they accurately state the scoping conclusions of the following items for which the responses to Observation 3 and RAI 2-4 appear to differ:
2 MPC Plugs for Drilled Holes MPC Upper Fuel Spacer Bolt MPC Basket Shim MPC Basket Support (Flat Plate)
Overpack Thermal Expansion Foam This information is needed to confirm compliance with 10 CFR 72.240(c).
References Holtec, 2019. Attachment 1 to Holtec Letter 5014876, Submittal of Responses to NRCs RSIs on the Renewal of the HI-STAR 100 Storage CoC, Holtec International, ADAMS Accession No. ML19184A232. June 28, 2019.
Holtec, 2020. Attachment 1 to Holtec Letter 5014898, Submittal of Responses to NRCs RIs on the Renewal of the HI-STAR 100 Storage CoC, Holtec International, ADAMS Accession No. ML20153A768. June 1, 2020.
RAI 2-5 Revise the renewal application to include the changes to the design bases in the HI-STAR 100 FSAR, Revision 4, which is associated with Amendment No. 3 to the HI-STAR 100 CoC.
By letter dated March 11, 2020, the applicant submitted Revision 4 of the FSAR that includes the changes made in CoC Amendment No. 3 (ADAMS Accession No. ML20071D992).
However, some changes were not addressed in the renewal application. Revise the renewal application to:
- 1. Include the evaluation of subcomponents added in Amendment 3 of the HI-STAR 100 Storage System CoC, updating the scoping and AMR tables accordingly. These SSCs include, but may not necessarily be limited to:
MPC Vent and Drain Tube, Optional MPC Threaded Disc, Plug Adjustment MPC Vent and Drain Plug MPC Thread Shield Cap MPC Retaining Ring
- 2. Update Table 1.3-1 of the renewal application to reference the revision of HI-2012610, the HI-STAR 100 FSAR, that defines the design bases for CoC Amendment No. 3.
Table 1.3-1 of the renewal application lists the FSAR revisions that apply to each amendment of the CoC. However, that table does not include a reference to the FSAR revision that serves as the design-basis FSAR for CoC Amendment No. 3.
This information is needed to confirm compliance with 10 CFR 72.240(c).
3 Chapter 3: Aging Management Review RAI 3-3 If the thermal expansion foam is in the scope of renewal (based on the response to RAI 2-3 and RAI 2-4 Follow-up), provide the technical basis that supports the conclusion that the foam does not have any credible aging effects due to radiation exposure that could challenge an important-to-safety function in the period of extended operation.
The silicone thermal expansion foam in the HI-STAR 100 Overpack is identified as a not-important-to-safety (NITS) item in the renewal application scoping tables. However, the foam was included in the scope of the aging management review in Chapter 3 of the renewal application, although the application did not identify the basis for including it within scope.
Further, the application concluded that the foam does not have any aging effects requiring management. If the thermal expansion foam is considered to be in the scope of renewal (based on the response to RAI 2-4a), clarify the bases for the results of the scoping and aging management review, as follows:
- 1. Clarify how an important-to-safety function is affected by potential degradation of the thermal expansion foam. HI-STAR 100 FSAR Section 1.2.1.2 states that the foam may be required to alleviate thermal stresses from differential thermal expansion. It is not clear to the staff how a change in the foam properties may prevent it from fulfilling that role (i.e., how an important-to-safety function is (or is not) impacted if the thermal stresses are not alleviated).
- 2. Provide the technical basis for the conclusion that the gamma and neutron exposure throughout the period of extended operation will not challenge the structural integrity function of the foam. As described in NUREG-2214 Section 3.3.1.3, radiation can embrittle polymeric materials, and studies on the effects of gamma and neutron radiation on silicone foams have observed a loss of ductility (Liu, 2017). HI-STAR 100 FSAR Appendix 1.C states that silicone is highly resistant to the radiation exposure levels present in the storage system; however, no support for that statement was provided.
This information is needed to confirm compliance with 10 CFR 72.240(c).
Reference B. Lie, et al., Effects of Combined Neutron and Gamma Irradiation Upon Silicone Foam, Radiation Physics and Chemistry, Vol. 133, pp. 31-36, 2017.
Appendix D: Aging Management FSAR Changes RAI D-1 Follow-up Provide the updated proposed changes to the HI-STAR 100 FSAR in Appendix D of the renewal application (FSAR supplement), including any referenced tables, as revised through the response to this request for clarification, and to incorporate the following clarifications.
Update the FSAR supplement to clarify the following renewal application references:
4 Table 9.2.3 of the FSAR supplement (Independent Spent Fuel Storage Installation (ISFSI) Pad AMP) references Table 3.3.5, which is likely a reference to Table 3.3-5 (with hyphen) of the renewal application that contains the AMR table for the ISFSI pad.
When incorporating by reference the renewal application Tables 3.3-3 and 3.3-5 in the proposed FSAR Tables 9.2.2 and 9.2.3, respectively, provide a clear reference to the specific revision of the renewal application (e.g., Table 3.3-3 of Revision 1C of the HI-STAR 100 CoC Renewal Application).
Clarify these references or fully incorporate the final AMR tables into the FSAR supplement to ensure that the aging management activities are appropriately included in the FSARs for each renewed CoC amendment.
In addition, in Table 3.3-3 of the renewal application, which is referenced in the FSAR supplement, the staff noted an editorial error where the Embedded (in concrete) environment for the overpack bottom plate was placed under the Aging Effects Requiring Management column. Revise the table to clarify the aging effects being managed by the Overpack AMP for this line item.
Appendix D of the renewal application provides the proposed FSAR supplement to document the aging management information associated with the CoC renewal, per 10 CFR 72.240(c).
The CoC renewal will include a condition for the CoC holder to update the FSAR to reflect the changes and commitments resulting from the review and approval of the CoC renewal. The FSAR must clearly reflect the approved design bases, including aging management information in the period of extended operation if the renewal is approved. Therefore, the FSAR supplement in Appendix D of the renewal application must include all FSAR changes related to the renewal of the CoC.
This information is required to demonstrate compliance with 10 CFR 72.240(c).