ML21060B312

Acceptance Review of the Renewal Application to Certificate of Compliance No. 1026 for the Fuelsolutions Spent Fuel Management System - Request for Supplemental Information

ML21060B312
Person / Time
Site:	07201026
Issue date:	03/01/2021
From:	Yen-Ju Chen Storage and Transportation Licensing Branch
To:	Quinn R Westinghouse
YChen - NMSS/DFM/STL - 301.415.1018
References
CAC 001028, EPID: L 2020-RNW-0035 EPID: L 2020-RNW-0035
Download: ML21060B312 (7)

Text

March 1, 2021 Robert D. Quinn, Director Nuclear Material Management Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, PA 16066

SUBJECT:

ACCEPTANCE REVIEW OF THE RENEWAL APPLICATION TO CERTIFICATE OF COMPLIANCE NO. 1026 FOR THE FUELSOLUTIONS' SPENT FUEL MANAGEMENT SYSTEM (DOCKET NO. 72-1026, CAC NO. 001028, EPID:

L-2020-RNW-0035) - REQUEST FOR SUPPLEMENTAL INFORMATION

Dear Mr. Quinn:

By letter dated November 6, 2020 [Agencywide Document Access and Management System (ADAMS) Accession No. ML20315A012], Westinghouse Electric Company (Westinghouse) submitted to the U.S. Nuclear Regulatory Commission (NRC) a request to renew the Certificate of Compliance (CoC) No. 1026 for the FuelSolutions' Spent Fuel Management System.

The staff has performed an acceptance review of your application to determine if the application contains sufficient technical information to begin a detailed technical review. The staff has determined that the application does not provide sufficient technical information to begin a detailed review and that supplemental information is needed. The information needed to continue our review is described in the enclosed request for supplemental information (RSI).

In order to schedule our technical review, responses to the enclosed RSI should be provided within 30 days from the date of this letter. If Westinghouse is unable to meet this response date, please notify us, at least one week prior to the due date, of your new submittal date and the reasons for the delay. If Westinghouse is not able to respond within this timeframe or the RSI responses do not provide sufficient information, the application may not be accepted for review.

R. Quinn Please reference Docket No. 72-1026, CAC No. 001028, and EPID No. L-2020-RNW-0035 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.: 72-1026 CAC No.: 001028 EPID: L-2020-RNW-0035

Enclosure:

RSI Yen-Ju Chen Digitally signed by Yen-Ju Chen Date: 2021.03.01 11:23:47 -05'00'

R. Quinn

SUBJECT:

ACCEPTANCE REVIEW OF THE RENEWAL APPLICATION TO CERTIFICATE OF COMPLIANCE NO. 1026 FOR THE FUELSOLUTIONS' SPENT FUEL MANAGEMENT SYSTEM (DOCKET NO. 72-1026, CAC NO. 001028, EPID: L-2020-RNW-0035) - REQUEST FOR SUPPLEMENTAL INFORMATION DOCUMENT DATE: March 1, 2021 ADAMS Accession Number: ML21060B312

• concur via email OFFICE:

DFM DFM*

DFM*

DFM*

NAME:

YChen WWheatley ASotomayor-Rivera JWise DATE:

2/26/2021 2/03/2021 2/9/2021 2/9/2021 OFFICE:

DFM*

DFM*

DFM*

NAME:

RChang TBoyce JMcKirgan DATE:

2/16/2021 2/16/2021 2/26/2021 OFFICIAL RECORD

Enclosure Request for Supplemental Information Docket No. 72-1026 Westinghouse Electric Company FuelSolutions' Spent Fuel Management System Certificate of Compliance No. 1026 Renewal Application By letter dated November 6, 2020 [Agencywide Document Access and Management System (ADAMS) Accession No. ML20315A012], Westinghouse Electric Company (Westinghouse) submitted to the U.S. Nuclear Regulatory Commission (NRC) a request to renew the Certificate of Compliance (CoC) No. 1026 for the FuelSolutions' Spent Fuel Management System.

The staff has performed an acceptance review of the application and determined that the application does not provide sufficient technical information to begin a detailed review and that supplemental information is needed. The information needed to continue the staffs review is described in the request for supplemental information (RSI) below.

Scoping Evaluation RSI 2-1 Revise the renewal application to clarify the subcomponents of the FuelSolutions' Spent Fuel Management System (including the SENTRY' addenda) that were determined to be within and outside of the scope of renewal.

The combined scoping and aging management review tables in Chapter 2 of the renewal application include all subcomponents listed in the drawings for the in-scope structure, system, and components, including those categorized as not important to safety (NITS). It is unclear to the staff which of the NITS subcomponents were determined to be within and outside of the scope of renewal.

The staff notes that some of the tables specifically identify the NITS subcomponents that were determined to be outside the scope of the renewal because their failure would not prevent the fulfillment of an important-to-safety (ITS) function, such as Table 2-6 for the transfer cask.

However, other tables do not address the scoping of NITS subcomponents, such as Tables 2-4a and 2-4b for the canisters. NUREG-1927, Revision 1, Section 2.4.2, provides guidance that the staffs review of the renewal application includes a verification that all NITS components whose failure could affect an ITS function are appropriately scoped into the aging management review.

Revise the renewal application to clearly identify the scoping determination for each of the NITS subcomponents. In addition, if any ITS subcomponents were determined to be outside the scope of renewal (i.e., they no longer have that ITS function during the period of extended operation), clarify that scoping determination in the application as well.

This information is needed to confirm compliance with 10 CFR 72.240(c).

RSI 2-2 Provide a drawing for the SENTRY' W110 Transfer Cask Neutron Shielding Shell that identifies the materials, applicable codes, safety classification, and configuration of the transfer cask subcomponents.

The combined scoping and aging management review table in Chapter 2 of the SENTRY' renewal application references drawing WDD-DW-00126-GEN for the W110 transfer cask neutron shielding shell. The staff notes that the referenced drawing does not appear to be included in the SENTRY' Dry Storage System Safety Analysis Report (Revision 0).

To support the staffs review of the scoping evaluation, provide the subject drawing.

This information is needed to confirm compliance with 10 CFR 72.236(d) and 72.240(d).

Aging Management Review RSI 3-1 In the FuelSoutions' W100 Transfer Cask Aging Management Program (AMP),

describe the activities that will be performed to manage the identified aging effects for the solid neutron shielding material.

The aging management review (AMR) for the FuelSolutions' system concluded that loss of shielding due to boron depletion was a credible aging effect for the neutron shield material in the top and bottom covers of the W100 transfer cask. The AMR table states that the W100 Transfer Cask AMP will be used to manage the aging effect. However, the W100 Transfer Cask AMP does not describe any activities for how that aging effect will be managed. Although the AMP includes dose rate acceptance criteria for the RX-277 solid neutron shield material, the AMP does not include any description of dose monitoring parameters, methodology, or frequency of activities that will be performed to verify that the acceptance criteria are met. In addition, the AMP does not address the NS-3 shielding material that is also managed by the Transfer Cask AMP.

Revise the Parameters Monitored/Inspected and Detection of Aging Effects program elements of the W100 Transfer Cask AMP to describe the activities that will be performed to ensure that the shielding performance of the RX-277 and NS-3 solid neutron shielding materials will be maintained.

This information is needed to determine compliance with 10 CFR 72.236(d), 72.240(c)(3) and 72.240(d).

RSI 3-2 Revise the Reinforced Concrete Structures AMPs for the FuelSolutions' and SENTRY' systems to define the sample size of the exterior inspections of the concrete storage casks.

The Reinforced Concrete Structures AMPs include visual inspections of exterior concrete surfaces; however, the AMPs are not clear on whether the exterior inspections will be performed on all casks or some smaller sample size.

Revise the AMPs to define the number of casks inspected and, if not all casks will be inspected, provide the technical basis for using a smaller sample size for the exterior inspections.

This information is needed to determine compliance with 10 CFR 72.240(c)(3).

RSI 3-3 Provide the test report(s) that demonstrate that the W110 transfer cask neutron shielding epoxy resin material is not subject to radiation-induced aging effects.

Appendix B of the SENTRY' renewal application summarizes the basis for why the W110 transfer cask epoxy resin neutron absorber material is not subject to radiation-induced aging (e.g., embrittlement, loss of hydrogen).

Provide the test reports that support the technical basis for concluding that aging effects for the epoxy resin are not credible.

This information is needed to determine compliance with 10 CFR 72.236(d) and 72.240(d).

OBSERVATIONS Observation 3-1 In the Reinforced Concrete Structures AMPs for the FuelSolutions' and SENTRY' systems, clarify the activities that will be used to verify the shielding performance of the concrete storage casks.

The Reinforced Concrete Structures AMPs include visual inspections and radiation surveys; however, it is unclear to the staff which activities are credited for managing the shielding performance of the concrete.

The AMPs Detection of Aging Effects program elements state that radiation surveys are performed to verify compliance with 10 CFR 72.104 and the Technical Specifications. However, the staff is unable to identify any radiation survey activities that occur in the period of extended operation. In addition, there are no details in the other program elements that describe the surveys, such as the measurement techniques, frequency, locations where radiation is measured, and acceptance criteria, that demonstrate that the surveys are capable of managing the aging of each of the concrete casks.

The AMPs also include visual inspections of the concrete; however, the AMPs are not clear on whether visual inspections are credited for managing shielding effectiveness. NUREG-2214, Managing Aging Processes in Storage (MAPS) Report, recognizes that visual inspection may be an effective means to monitor shielding effectiveness, provided that the visual inspection acceptance criteria (e.g., depth of spalling, width of cracks) are demonstrated to be sufficiently conservative to ensure that degradation will be identified and corrected prior to a loss of shielding. The AMPs do not provide such a demonstration.

Revise the renewal application to clarify which activities are credited to managing the concrete shielding and, as appropriate, provide the additional details described above that demonstrate the activities are capable of managing the aging of each of the concrete casks.

This information is needed to determine compliance with 10 CFR 72.236(d), 72.240(c)(3), and 72.240(d).

Observation 3-2 In the Reinforced Concrete Structures AMPs for the FuelSolutions' and SENTRY' systems, clarify the use of the ACI 349.3R concrete code criteria for the inspection of the internal and external surfaces of the storage cask.

The Reinforced Concrete Structures AMPs include visual inspections to monitor the condition of the concrete. The staff noted potential discrepancies or information gaps as follows:

1. For the cask annular space and interior areas of the vents, the visual inspection acceptance criteria are stated to conform to ACI 349.3R. The application also states that the cask interior surfaces that are covered by a metal liner are addressed by the Metallic Surfaces AMP.

It appears that the entire annular spaces of the FuelSolutions' and SENTRY' storage casks are metallic. In addition, the interior vent areas for the SENTRY' cask are also metallic. As a result, it is unclear which portions of those areas would be subject to the ACI 349.3R concrete code criteria.

2. For the cask exterior, the Detection of Aging Effects program element does not specifically state a code or standard for the visual inspections of the exposed concrete (unlike the annular space criteria described above). Clarify whether the inspections for the cask exterior will conform to ACI 349.3R or some other criteria.

3. The Detection of Aging Effects program element states that inspectors are qualified to ACI 349. It is unclear to the staff if this reference was intended to be ACI 349.3R, which is referenced in the acceptance criteria and defines the qualification requirements in Chapter 7 of that code.

Revise the Reinforced Concrete Structures AMPs, as appropriate, to clarify these details for the annular space and exterior inspections.

This information is needed to determine compliance with 10 CFR 72.240(c)(3).