ML21132A298
| ML21132A298 | |
| Person / Time | |
|---|---|
| Site: | 07201032, HI-STORM 100, 07201008, Holtec |
| Issue date: | 05/12/2021 |
| From: | Anton S Holtec |
| To: | Christopher Regan Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| 5018082 | |
| Download: ML21132A298 (2) | |
Text
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Document ID 5018082 Page 1 of 2 May 12, 2021 Chris Regan - Acting Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Docket No.:
72-1008, Certificate of Compliance (CoC) No. 1008 72-1014, Certificate of Compliance (CoC) No. 1014 72-1032, Certificate of Compliance (CoC) No. 1032 72-1040, Certificate of Compliance (CoC) No. 1040
Subject:
Extreme Environmental Phenomena During Short Term Operations Within 10CFR72 Jurisdiction
Dear Mr. Regan:
The purpose of this letter is to request clarification on the consideration of extreme environmental phenomena during short term operations (STO) within Part 72 jurisdiction.
The guidance documents for Dry Storage operation, namely NUREG-1536 and now NUREG-2215, state with respect to consideration of tornado missile impact that:
an earthquake or tornado may occur at any time and in combination with any normal condition.
And The NRC staff considers that tornados and tornado missiles may occur without warning.
While the NUREGs are understood to be guidance documents, the wording in these sections appears to preclude any administrative approach to address tornado missile impacts. However, the application of administrative actions to restrict operations during risk of tornados has apparently been considered acceptable by NRC in the context of the inspections of the loading procedures for
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Document ID 5018082 Page 2 of 2 some of our clients. This situation results in regulatory uncertainty that we believe should be addressed generically, not on a case-by case basis.
Holtecs FSARs contain the safety analyses that show that the mechanical integrity of the SNF and continued confinement effectiveness of the MPCs during their residence in the transfer cask or the storage overpack in the principal physical states of short or long duration configurations is assured, and site-specific projectiles are also considered if need be. However, that does not extend to transient states during STOs, when the cask may be undergoing a transition from one configuration to another during transport operations, such as during upending or down ending activities, change out of the rigging, or installation of the closure lid outside the truck bay. These transient states are of very short duration and often involve multiple indeterminate configurations of ancillaries, and as such, have not been explicitly modeled, and are not included in the FSAR.
Based on this short duration, it should therefore be acceptable to utilize the current and forecasted local meteorological information to inform planning of short term operations to avoid tornado missile impact and hence maximize operational and crew safety, without the need to explicitly analyze the transitional evolutions for safety confirmation.
As stated above, we request written clarification on this subject, through docketed correspondence.
As there are licensees currently loading or in preparation to load dry storage systems, we request a timely response so they can continue with the necessary regulatory clarity. Please inform us of when we should expect such a response.
If you have any questions, please contact me at (856) 296-9219 or s.anton@holtec.com.
Sincerely, Stefan Anton, Dr.-Ing.
Vice President of Engineering Holtec International cc:(via email)
John McKirgan (NRC)
Paul Peduzzi (NRC)
Mark Richter (NEI)
Zita Martin (HUG)
Suzanne Leblang (HUG)