ML21201A028

Handout for Meeting with Holtec on HI-STORM 100 Amendment No. 16 (July 27, 2021)

ML21201A028
Person / Time
Site:	Holtec
Issue date:	07/23/2021
From:	Office of Nuclear Material Safety and Safeguards
To:
YJChen NMSS/DFM/STL 301.415.1018
References
Download: ML21201A028 (34)

Text

Public Meeting with Holtec International on HI-STORM 100 Amendment No. 16 Conference Line: 301-576-2978 Conference ID: 342 181 124#

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Meeting Agenda

1. Introduction and Meeting Logistics Fuel Cladding

2. Gross Rupture and Discussion NRC Presentation

3. Opportunity for Public Comments

4. Summary and Closing Remarks 2

Introduction and Opening Remarks 3

HI-STORM 100 Amendment No. 16 and Graded Approach 4

HI-STORM 100 Amendment No. 16

• Submitted application on March 9, 2021 (ML21068A360)

• The application includes both technical changes and changes to reorganize the CoC and appendices

• Reorganization included using graded approach evaluation forms

• NRC staff completed acceptance review and issued request for supplemental information (RSI) for technical changes (ML21179A179)

• Discuss staffs feedback on CoC and appendices reorganization in this public meeting 5

Purpose of Graded Approach Streamline the content and format of storage certificates of compliance (CoCs) and their appendices by focusing mainly on:

• safety-related/significant items

• risk-significant content

• reorganize CoC format

• remove duplicative items, as appropriate

• relocate non-safety related items to other licensing basis documents, as appropriate 6

Endorsement of Graded Approach

• NRC endorsed the graded approach in January 2020 (ML19353D337) as developed and described in RIRP-I-16-01 (ML17138A119)

• This streamlined content allows vendors of spent fuel storage systems to be able to make some non-safety-related changes through the existing regulatory process rather than having to request a new or amended certificate, which would require rulemaking.

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Expectation on Graded Approach Evaluation

• Each existing individual CoC requirement receives a written evaluation against the CoC format and content guidance and selection criteria using risk insights and expert knowledge.

• The Evaluation Form records the decision-making process and justification for retaining a CoC requirement in the CoC or relocating it.

• In performing the risk insight, think about subsequent changes to a relocated CoC requirement. Specifically, ask the question "what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction"?

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Expectation on Graded Approach Evaluation (Cont)

The evaluation form should clearly provide the information in a manner that allows the staff to make the needed determination that, after applying graded approach, the CoC and appendices continue providing the needed information or requirements to the necessary level of detail to ensure the design and operations of the cask system will continue to meet the regulatory requirements for safe storage of spent nuclear fuel as set forth in 10 CFR Part 72.

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Pilot Safety Evaluation Report (ML20226A080)

Table 2.1. New CoC format and content and corresponding evaluation criteria Sub New CoC Goal of Criterion Criterion Evaluation Criteria Location the Evaluation No.

No.

Identify and evaluate:

Include in the CoC a concise

• if future modifications would be considered a significant deviation to the type CoC Body, description of the of technology, components, or fundamental way the cask system operates.

Section I, technology, components, 1

• if the modification to this section could not be performed through an Sections I and II Technology and functionality of the dry amendment under 10 CFR 72.244, Application for amendment of a certificate cask storage system.

of compliance.

Identify and evaluate:

CoC Body,

• design features that would have a significant effect on safety if altered or Include in the CoC design Section II, modified (e.g., materials of construction, geometric arrangement).

features that would have a 2 Design

• if the modification to this section could not be performed through an significant effect on safety.

Features amendment under 10 CFR 72.244, Application for amendment of a certificate of compliance.

• Identify the applicable ITEs, and acceptance criteria.

Include in the CoC the

• Evaluate if ITEs, and acceptance criteria are necessary and sufficient to provide inspections, tests, and reasonable assurance that a cask manufacturing and operation will conform evaluations (ITE), and with the certified design.

CoC Appendix A, Appendix A acceptance criteria, that

• Ensure that the safety functions of confinement, sub-criticality and shielding are Inspections, ensure that a dry storage 3 maintained.

Tests, and cask system has been Evaluations manufactured and will NOTE: Assuming ITEs are performed and the acceptance criteria is met.

operate in conformance with the certified design.

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Sub Goal of Criterion New CoC Location Criterion Evaluation Criteria the Evaluation No.

No.

Identify the key definitions and administrative rules that should reside in CoC CoC Appendix B, Appendix B, Technical Specifications, Section 1, that allows for understanding Include in the CoC the Technical AND implementing the logic of the Limiting Conditions for Operation (LCOs) and key definitions and Specifications, Surveillance Requirements (SRs) in the TSs.

administrative rules 4 Section 1, for implementing the Definitions, Use, TSs.

and Application A1 Evaluate if the information provided in CoC Appendix B, Technical Specifications, Appendix B Section 2, Approved Contents, meets one or more of the following criteria:

Include in the CoC the A2

• Criterion A1: The characteristic or parameter is identified in 10 CFR 72.236(a).

minimum set of

• Criterion A2: A characteristic or parameter for which verification is a necessary CoC Appendix B, parameters needed to condition to provide reasonable assurance that the cask safety functions of Technical define the approved confinement, sub-criticality, and shielding will be performed.

Specifications, contents in the

• Criterion A3: A characteristic or parameter that has a significant impact on 5

Section 2, certified design that, if public health and safety, based on risk insights and expert knowledge.

Approved altered or modified, A3 Contents would have a significant effect on safety.

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Sub Goal of Criterion New CoC Location Criterion Evaluation Criteria the Evaluation No.

No.

• Identify and evaluate functional and operating limits on fuel handling and storage Include in the CoC the conditions necessary to protect the integrity of the stored fuel, employees following information:

L1 against occupational exposures, and prevent the uncontrolled release of

• the lowest radioactive materials.

functional

• Identify the subsequent subsections that will include LCOs for operation of the capability or independent spent fuel storage installation (ISFSI) facility or cask with performance levels CoC Appendix B, appropriate SRs.

Appendix B (Continue) of equipment Technical

• To ensure the safe operation of the ISFSl and cask system, evaluate each LCO and required for safe Specifications, corresponding SR that meet one or more of the following criteria:

operation of the Section 3, Limiting

• Criterion L1: Installed instrumentation that is used to detect and indicate a ISFSl and cask, and 6 L2 Conditions for significant abnormal degradation of the casks confinement boundary.

• functional and Operations and

• Criterion L2: An initial condition of a design basis accident that either assumes operating limits to Surveillance the failure of or presents a challenge to the integrity of a fission product barrier.

protect the Requirements

• Criterion L3: A structure, system, or component that has a significant impact on integrity of the public health and safety, based on risk insights and expert knowledge.

stored fuel, workers, environment, and L3 the public health and safety.

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Sub Goal of Criterion New CoC Location Criterion Evaluation Criteria the Evaluation No.

No.

Include in the CoC the

• This section should include high-level descriptions of the programs and the organization and essential elements of the programs required to assure safe cask or ISFSI management of operation.

• Identify the programs descriptions that include only the essential elements of Appendix B (Continue) procedures, CoC Appendix B, the programs required to assure safe cask or ISFSI operation, with additional recordkeeping, review Technical supporting information relocated to the FSAR, as necessary.

and audit, and reporting Specifications, Implementation details would be included in general licensee procedures.

requirements necessary 7 Section 4, to assure the safe Administrative operations related to Controls the storage of spent fuel and reactor-related greater-than-class-C waste in an ISFSI.

Evaluate the following questions:

8. Will removing this requirement from the CoC result in a significant increase in 8 the probability or consequences of an accident previously evaluated in the cask FSAR?

Risk insight Identify items that

9. Will removing this requirement from the CoC result in the possibility of a new or Not Applicable should not be removed 9 different kind of accident being created compared to those previously evaluated in from the CoC.

the FSAR?

10. Will removing this requirement from the CoC result in a significant reduction in 10 the margin of safety for ISFSI or cask operation?

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Holtecs Application on CoC Reorganization Holtec provided:

• Evaluation forms like graded approach pilot

• Reformatted version of CoC and appendices NRCs observation of the application:

• Reorganized CoC format

• Removed duplicative items

• Not full graded approach evaluation as described earlier 14

NRCs Review & Evaluation

• The NRC welcome any initiative to improve the CoC and its appendices

• Completing the graded approach evaluation is voluntary

• Staff seeks clarification of Holtecs intent

• Reorganize CoC and appendices

• Complete graded approach, similar to the pilot 15

Need Information on Reorganization

• Need a complete set of CoC and appendices prior to reorganization (for easier comparison of before and after)

• Why does the new format have six appendices instead of two appendices as described in RIRP-I-16-01?

• Evaluations of why an item is appropriate in a particular section in the new format:

• Why move Appendix A Section 5.8 to Appendix B Section 4?

• Why keep the first paragraph of the CoC at the same location? (no evaluation form)

• Why move a blank item and remain blank?

• Move Appendix A LCO 3.2.1 to Appendix B LCO 3.2.1 (no evaluation form) 16

Need Information for Graded Approach

• Items discussed on the previous slide

• Evaluations of and bases for what is important enough, i.e., safety-related/significant items and risk-significant content, to retain in the CoC/appendices

• Evaluations and bases for the level of detail of the information that should be retained in the new CoC/appendices versus what could be relocated to the FSAR 17

Need Information for Graded Approach (Cont)

• Evaluations/considerations of what information may need to be included in the new CoC/appendices based on the graded approach criteria (e.g.,

definition of operability)

• Evaluation bases to support yes/no responses in risk insight evaluation

• Inconsistencies (e.g., CoC-6 & CoC-7)

• Justification for content changes and incomplete changes (e.g., CoC-11) 18

Moving Forward Depend on Holtecs intent

• Reorganize CoC and appendices

• Provide clarification

• Graded approach

• Close coordination and communications

• Multiple public meetings to provide feedback Schedule 19

Public Comments Please complete the online public meeting feedback form 20

Summary and Closing Remarks 21

BACKUP SLIDES Examples from Evaluation Forms

Appendix A Section 5.8

Appendix A Section 5.8 (page 2)

First paragraph of CoC Appendix A LCO 3.2.1 Appendix B LCO 3.2.1 Pilot (TN)

Evaluation Form on Leakage Test

Pilot (TN) Evaluation Form on Leakage Test (Page 2)

Pilot (TN)

Evaluation Form on Definitions

HI-STORM FW Amendment 7 Evaluation Form for CoC-4

HI-STORM FW Amendment 7 Evaluation Form for CoC-4 (Page 2)

• Make sure the references are updated

• Retain = No change to language and stay at the same place in CoC or appendix

Evaluation Form for CoC-6

Evaluation Form for CoC-7

Evaluation Form for CoC-11