Letter Sequence RAI |
|---|
CAC:001028, SR 3.5.1.2 Notation (Approved, Closed) EPID:L-2018-NEW-0001, International, Issuance of Materials License SNM-2516 for the HI-STORE Consolidated Interim Storage Facility ISFSI (Approved, Closed) |
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, Request, Request, Request, Request, ... further results|Request]]
- Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, 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, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, ... further results|Supplement]]
Administration
- Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, 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, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, ... further results|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, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, ... further results|Approval]]
Other: L-18-006, ISFSI - Site-Specific License Renewal Application, Revision 0, July 2018, L-23-005, Independent Spent Fuel Storage Installation License Renewal Application, Revision 1 (Cac/Epid No. 001028/L-2022-RNW-0007), ML17311A450, ML18018A018, ML18022A077, ML18022A078, ML18022A079, ML18087A056, ML18087A057, ML18087A058, ML18087A059, ML18087A060, ML18087A061, ML18087A062, ML18100A185, ML18100A188, ML18100A190, ML18100A191, ML18100A193, ML18101A024, ML18108A052, ML18131A047, ML18131A048, ML18141A561, ML18141A562, ML18141A563, ML18141A564, ML18141A565, ML18141A567, ML18179A258, ML18179A260, ML18179A266, ML18201A455, ML18205A179, ML18222A351, ML18228A530, ML18228A531, ML18228A532, ML18228A533, ML18234A012, ML18248A121, ML18255A093, ML18255A094, ML18255A096, ML18255A097, ML18255A098, ML18255A101, ML18255A102, ML18324A577, ML18324A594... further results
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MONTHYEARML19255E7911997-05-31031 May 1997
Enclosure 1 - Ecological Assessment of the Low Level Waste Depository, Andrews County, Tx
Project stage: Other
ML19255E7952004-10-25025 October 2004
Enclosure 2 - Habitat Characterization and Rare Species Survey for the Proposed Low Level Waste Repository, Andrews County, Tx
Project stage: Other
ML19255E7982007-03-16016 March 2007
Enclosure 3 - Supplemental Survey to Ecological Assessment of the Low Level Waste Depository, Andrews County, Texas
Project stage: Supplement
ML19337B5182007-03-16016 March 2007
Enclosure 10 - Applicable Sections of LLRW License
Project stage: Other
ML19217A2112007-04-30030 April 2007
Enclosure 1 - Report on Mapping of a Trench Through Pedogenic Calcrete (Caliche) Across a Drainage and Possible Lineament, Waste Control Specialists Disposal Site, Andrews County, Tx (Public)
Project stage: Other
ML19255E8002008-07-0303 July 2008
Enclosure 4 - Environmental Assessment Report Prepared for Application for Renewal of Radioactive Material License R04971 Waste Control Specialists LLC Andrews County, Texas
Project stage: Request
ML19217A2142008-07-28028 July 2008
Enclosure 4 - Report on Activities to Satisfy Byproduct RML Conditions 41A, 41C, and 43, July 2008 (Public)
Project stage: Other
ML19217A2132011-02-22022 February 2011
Enclosure 3 - Oag Water Levels: Empirical and Modeled Relationships Between Precipitation and Infiltration, 2011 (Public)
Project stage: Other
ML18100A1882013-04-11011 April 2013
Enclosure 7 - Procedure 12751-MNGP-QP-9.201, Revision 0, Visual Weld Examination
Project stage: Other
ML18100A1852013-04-11011 April 2013
Enclosure 6 - Procedure 12751-MNGP-OPS-01, Revision 0, Spent Fuel Cask Welding: 61BT/BTH NUHOMS Canisters
Project stage: Other
ML18100A1912014-01-30030 January 2014
Enclosure 9 - Structural Integrity Associates, Inc. Report 130415.402, Revision 0, Review of Trivis Inc. Welding Procedures Used for Field Welds on the Transnuclear NUHOMS 61BTH Type 1 & 2 Transportable Canister for BWR Fuel
Project stage: Other
ML18100A1902014-05-22022 May 2014
Enclosure 8 - Structural Integrity Associates, Inc. Report 130415.403, Revision 2, Assessment of Monticello Spent Fuel Canister Closure Plate Welds Based on Welding Video Records
Project stage: Other
ML18011A1582017-12-22022 December 2017
International HI-STORE Cis (Consolidated Interim Storage Facility) License Application Responses to Safeguards Related Requests for Supplemental Information
Project stage: Supplement
ML17249A1572018-01-11011 January 2018, 16 January 2018
Package: Vermont Yankee Nuclear Power Station ISFSI Environmental Assessment and Finding of No Significant Impact Related to Issuance of Exemption to Allow a New Loading Pattern and Loading Fuel Cooled for at Least 2 Years
Project stage: Request
ML18022A1512018-01-16016 January 2018
Memo to A. Hsia Summary of December 12, 2017, Meeting with Pacific Gas & Electric Company to Discuss the Upcoming Submittal of the Application for Renewal of the Humboldt Bay Independent Spent Fuel Storage Installation License
Project stage: Meeting
ML18022A1532018-01-16016 January 2018
Enclosure 2: Agenda (Memo to A. Hsia Summary of December 12, 2017, Meeting with Pacific Gas & Electric Company to Discuss the Upcoming Submittal of the Application for Renewal of the Humboldt Bay ISFSI License)
Project stage: Meeting
ML17249A1592018-01-16016 January 2018
Letter to C. C. Chappell Vermont Yankee Nuclear Power Station ISFSI Environmental Assessment and Finding of No Significant Impact Related to Issuance of Exemption to Allow a New Loading Pattern and Loading Fuel Cooled for at Least 2 Years
Project stage: Approval
ML18022A1522018-01-16016 January 2018
Enclosure 1: Meeting Attendees (Memo to A. Hsia Summary of December 12, 2017, Meeting with Pacific Gas & Electric Company to Discuss the Upcoming Submittal of the Application for Renewal of the Humboldt Bay ISFSI License)
Project stage: Meeting
ML18022A1542018-01-16016 January 2018
Enclosure 3: Handout-PG&E Presentation on Humboldt Bay ISFSI LRA (Memo to A. Hsia Summary of December 12, 2017, Meeting)
Project stage: Meeting
ML18018A0182018-01-17017 January 2018
Letter to K. Manzione Application for Holtec International HI-STORM Umax Multipurpose Canister Storage System License Amendment Request No. 3 to Certificate of Compliance No. 1040 - Accepted for Review
Project stage: Other
ML18018A0192018-01-17017 January 2018
Enclosurequest for Additional Information (Ltr to K. Manzione Application for Holtec International HI-STORM Umax Multipurpose Canister Storage System License Amendment Request No. 3 to Certificate of Compliance No. 1040-Accepted for Review)
Project stage: RAI
ML18018B2972018-01-19019 January 2018
Federal Registered Notice: Correction of Certificate of Compliance No. 1004, Renewed Amendments No. 11, Revision 1 and No. 13, Revision 1
Project stage: Request
ML18022A6122018-01-19019 January 2018
Letter to K. Manzione Amendment No. 4 to Certificate of Compliance No. 1032 for the HI-STORM Flood/Wind Multipurpose Canister Storage System-Request for Additional Information
Project stage: RAI
ML18022A0762018-01-22022 January 2018
Package: Correction to Title of Figure 1-15 in Technical Specifications for Certificate of Compliance 1004 Renewed Amendments No. 11, Revision 1 and No. 13, Revision 1
Project stage: Request
ML18022A0772018-01-22022 January 2018
Letter to J. Bondre Correction to Tn Americas LLC Technical Specifications for Renewed Amendments No. 11, Revision 1 and No. 13, Revision 1 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks
Project stage: Other
ML18022A0782018-01-22022 January 2018
Enclosure 1: Revised Title for Figure 1-5 Corrected Technical Specifications for Certificate of Compliance No. 1004 Renewed Amendment No. 11, Revision 1 Enclosure 1
Project stage: Other
ML18022A0792018-01-22022 January 2018
Enclosure 2: Revised Title for Figure 1-5 Corrected Technical Specifications for Certificate of Compliance No. 1004 Renewed Amendment No. 13, Revision 1
Project stage: Other
ML18024A2732018-01-24024 January 2018
Letter to D. G. Stoddard U.S. NRC Approval of Virginia Electric and Power Company Request for Withholding Information from Public Disclosure for North Anna Power Station ISFSI (Cac/Epid Nos. 001028/L-2017-RNW-0010 and 000993/L-2017-LNE-0008
Project stage: Withholding Request Acceptance
ML18031A4572018-01-31031 January 2018
Submittal Date for Response to NRCs Requests for Additional Information (Rais) for License Amendment Request 1032-4 to HI-STORM FW CoC No. 1032 (CAC No. 001028)
Project stage: Request
ML17311A4502018-01-31031 January 2018
ISFSI License Renewal Final Environmental Assessment
Project stage: Other
ML18036A2222018-02-0101 February 2018
International - Transmittal of HI-STORM Umax License Amendment Request No. 3 - Administrative RAI Response
Project stage: Request
ML17298A1352018-02-0202 February 2018
Safety Evaluation Report (Letter to C. C. Chappell Vermont Yankee Nuclear Power Station Independent Spent Fuel Storage Installation, Issuance of Exemption (CAC No.: 001028, Docket Nos. 50-271, 72-59, and 72-1014; EPID L-2017-LLE-0005)
Project stage: Approval
ML17298A1342018-02-0202 February 2018
Letter to C. C. Chappell Vermont Yankee Nuclear Power Station Independent Spent Fuel Storage Installation, Issuance of Exemption (CAC No.: 001028, Docket Nos. 50-271, 72-59, and 72-1014; EPID L-2017-LLE-0005)
Project stage: Approval
ML18031A2282018-02-0606 February 2018
Enclosure 2: Safety Evaluation Report (Letter to D. G. Stoddard Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station ISFSI)
Project stage: Approval
ML18031A2272018-02-0606 February 2018
Enclosurenewed License SNM-2507 Technical Specifications (Letter to D. G. Stoddard Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station ISFSI)
Project stage: Approval
ML18031A2252018-02-0606 February 2018
Enclosurenewed License SNM-2507 (Letter to D. G. Stoddard Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station Independent Spent Fuel Storage Installation)
Project stage: Approval
ML18031A2242018-02-0606 February 2018
Enclosure 1: Preamble-SNM-2507 License Renewal Order (Letter to D. G. Stoddard Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station Independent Spent Fuel Storage Installation)
Project stage: Approval
ML18031A2222018-02-0606 February 2018
Letter to D. G. Stoddard Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station Independent Spent Fuel Storage Installation (Cac/Epid Nos. 001028/L-2017-RNW-0010 and 000993/L-2017-LNE-0008)
Project stage: Approval
ML18031A2312018-02-0808 February 2018
Federal Register Notice - Notice of Issuance for License Renewal (Letter to D. G. Stoddard Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station ISFSI)
Project stage: Approval
ML18053A2222018-02-15015 February 2018
Application for Amendment 1 to the NUHOMS Eos System, Revision O (Docket No. 72-1042)
Project stage: Request
ML18053A2332018-02-15015 February 2018
Enclosure 4: CoC 1042 Amendment 1 Proposed Technical Specifications, Revision 0
Project stage: Request
ML18053A2342018-02-15015 February 2018
Enclosure 6: Proposed Amendment 1, Revision 0 Changes to the NUHOMS Eos System Updated Final Safety Analysis Report, Chapters 1 to 14
Project stage: Request
ML18058A6082018-02-23023 February 2018
HI-2177593, Rev 0, Holtec International & Eddy Lea Energy Alliance (Elea) Underground CISF - Financial Assurance & Project Life Cycle Cost Estimates
Project stage: Request
ML18058A0242018-02-23023 February 2018
Enclosurequest for Additional Information (Letter to G. Van Noordennen Request for Additional Information Regarding Zionsolutions, LLCs Decommissioning Funding Plan Update for Zion Independent Spent Fuel Storage Installation)
Project stage: RAI
ML18058A0572018-02-23023 February 2018
Enclosurequest for Additional Information (Letter to J. Giddens Request for Additional Information Regarding Entergy Operations, Inc.S Decommissioning Funding Plan Update)
Project stage: RAI
ML18058A0232018-02-23023 February 2018
Letter to G. Van Noordennen Request for Additional Information Regarding Zionsolutions, LLCs Decommissioning Funding Plan Update for Zion Independent Spent Fuel Storage Installation
Project stage: RAI
ML18058A0562018-02-23023 February 2018
Letter to J. Giddens Request for Additional Information Regarding Entergy Operations, Inc.S Decommissioning Funding Plan Update
Project stage: RAI
ML18057A2182018-02-23023 February 2018
Enclosurequest for Additional Information (Letter to A. Zaremba Request for Additional Information for Review of Duke Energys Decommissioning Funding Plan Update)
Project stage: RAI
ML18058A6072018-02-23023 February 2018
HI-2177565, Rev 0, Holtec International & Eddy Lea Energy Alliance (Elea) Cis Facility - Decommissioning Cost Estimate and Funding Plan
Project stage: Request
ML18057A2172018-02-23023 February 2018
Letter to A. Zaremba Request for Additional Information for Review of Duke Energys Decommissioning Funding Plan Update
Project stage: RAI
2018-01-11
[Table View] |
Text
1 Audit Plan NRC Staff Audit of Holtecs Responses to Second Request for Additional Information, issued in connection with NRCs Review of the HI-STORE Consolidated Interim Storage Facility (Docket No. 72-1051)
December 8, 2021 A.
Location The audit will be held virtually on December 8, 2021, from 9:00 am - 4:00 pm EST B.
Background
The NRC staff is conducting a detailed safety, security, and environmental review of Holtec Internationals application for a site-specific independent spent fuel storage installation license to construct and operate the HI-STORE Consolidated Interim Storage Facility (CISF). In connection with its safety review, the staff has identified several issues related to Holtecs responses to NRC staffs second request for additional information (ML21124A308). Holtecs responses were submitted on June 30 (ML21224A105), August 16 (ML21228A201), and August 31 (ML21243A525), 2021. During the audit, NRC staff will discuss these issues and examine detailed proprietary calculations and analyses referenced in the responses. The audit will inform NRCs understanding of the remaining issues and support the preparation of a third request for additional information.
C.
Audit Scope The staff expects to discuss the following topics during the audit:
1.
Holtec Responses to SAR Chapter 2 RAIs on Pipeline, Rail, Highway Hazards; Geotechnical Data (RAI 2-7-S, RAI 2-14-S, and RAI 2-33-S)
Response to RAI 2-14-S and Report No. HI-2210620, Rev. 0, HI-STORE Highway 62/180 Hazardous Chemicals Risk Evaluation:
o
[Contains Proprietary Information - See enclosure]
Response to RAI 2-14-S and Report No. HI-2210619, Rev. 0, HI-STORE Railway Hazardous Chemicals Risk Evaluation:
o
[Contains Proprietary Information - See enclosure]
Response to RAI 2-7-S and Report No. HI-2210487, Rev. 0, HI-STORE Gas Pipelines Risk Evaluation:
o
[Contains Proprietary Information - See enclosure]
Response to RAI 2-33-S and Report No. HI-2188143, Rev. 2, HI-STORE Bearing Capacity and Settlement Calculations:
o
[Contains Proprietary Information - See enclosure]
2.
Holtec Responses to SAR Chapter 2 RAIs on Flooding Hazards (RAI 2-16-S-2, RAI 2-18-S, and RAI 2-19-S)
Response to RAI 2-16-S and Report No. CIS-RP-003-02, Rev. 2, "Probable Maximum Flood Analysis HI-STORE CISF":
2 o
[Contains Proprietary Information - See enclosure]
Response to RAI 2-18-S and Report No. CIS-RP-003-02, Rev. 2, "Probable Maximum Flood Analysis HI-STORE CISF":
o
[Contains Proprietary Information - See enclosure]
Response to RAI 2-19-S:
o The response cites the HISTORM UMAX FSAR, which states that the UMAX System is capable of being submerged up to 125 ft of water. However, the RAI also requested that the applicant clarify the additional impact of the overburden created by backfill materials. In addition, the response does not discuss the effects on spent fuel canister integrity that may result from flood water deposits on the canister surfaces.
3.
Holtec Responses to SAR Chapter 3 RAIs on Site Operations (RAI 3-2-S)
Potential inconsistency between the revised wording in SAR Section 3.1.1, Technical Specification 3.2.1, and the corresponding Technical Specification Bases (Section B3.2.1, Appendix to SAR Chapter 16)
Discussion of facility operations for the HI-PORT transfer vehicle:
o Revision 0O of the HI-STORE SAR proposes the use of the HI-PORT transfer vehicle for canister transfer operations between the proposed Canister Transfer Building (CTB) and the UMAX ISFSI pad at the CISF. However, neither SAR Chapter 3 or SAR Chapter 10, provide a description of facility operations or detailed operation procedures for the HI-PORT transfer vehicle.
4.
Holtec Responses to SAR Chapter 7 RAIs on Shielding Evaluation (RAI 7-13, RAI 7-14, RAI 7-17, RAI 7-18)
Responses to RAI 7-17:
o Verify and confirm that the output files for shielding calculations are correct for the specific source term and licensing basis or provide the correct files as necessary.
o Justify the uncertainties associated with the calculations for dose and dose rate with different regional sources are applied to the final total dose and dose rates.
o
[Contains Proprietary Information - See enclosure]
Responses to RAI 7-17:
o Justify how the uncertainties and relative errors associated with the different calculations for dose and dose rates were determined and applied to the final total dose and dose rates.
o
[Contains Proprietary Information - See enclosure]
Responses to RAI 7-17:
o Clarify the values used for the fuel assembly characteristic parameters as shown in Table A.1: Fuel Assembly Parameters for ORIGAMI Input, Table A.2:
Reactor Operating Parameters, for the HI-STAR 190 HI-STAR 190 Source Term Calculation Package
3 o
[Contains Proprietary Information - See enclosure]
Responses to RAI 7-17:
o Justify the calculation for the source terms for the spent fuel assembly (FA) with burnup exceeding 60 GWd/MTU and demonstrate that treatments, if any, are appropriate and adequate to assure reliable calculations of the source terms from the spent fuel.
o
[Contains Proprietary Information - See enclosure]
Responses to RAI 7-18:
o Justify the C-14 release limit value used in the C-14 calculation.
o
[Contains Proprietary Information - See enclosure]
Responses to RAI 7-17:
o Justify the 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> per year occupancy estimate of the real individual at the controlled area boundary.
o
[Contains Proprietary Information - See enclosure]
Responses to RAI 7-17:
o Justify the assumption that the concrete component of the HI-TRAC CS transfer cask will only lose the hydrogen under accident conditions. If additional damage mechanisms are plausible, describe how the shielding analysis accounts for the associated decrease in concrete shielding performance and revise the shielding analysis as necessary.
o
[Contains Proprietary Information - See enclosure]
Responses to RAI 7-17:
o Revise the reference for the subgrade backfill material in Drawing No. 10875 and justify why soil is used in the MCNP model for VVM shielding calculations.
o
[Contains Proprietary Information - See enclosure]
Responses to RAI 7-18:
o Justify or revise the C-14 concentration acceptance value.
o
[Contains Proprietary Information - See enclosure]
Responses to RAI 7-13:
o Clarify the definition of non-fuel hardware for BWR fuel or revise the definition of the following item in the Technical Specifications (TS) for the HI-STORE CISF ISFSI.
o Technical Specification (TS) 2-1, item 6, states that For fuel assemblies in the MPC-89, the decay heat limits shown in Table 2-2. Note that these maximum fuel storage location decay heat limits must account for decay heat from both the fuel assembly and any non-fuel hardware. However, the TS does not provide specific definition for BWR non-fuel hardware. If the fuel channel is the only allowable non-fuel hardware to the MPC-89 canister, revise the TS to provide explicit definition for the BWR non-fuel hardware.
4
Responses to RAI 7-13:
o Explain how the gammas from non-fuel hardware are treated in the shielding model or confirm that non-fuel hardware is not part of the authorized contents.
o TS 2.1, Approved Contents, Fuel Specifications and Loading Conditions states, For fuel assemblies in the MPC-37, the decay heat limits shown in Table 2-1.
Note that these maximum fuel storage location decay heat limits must account for decay heat from both the fuel assembly and any non-fuel hardware. These fuel assemblies must also meet the restrictions on burnup, enrichment, and cooling time specified in the HI-STAR 190 SAR, Table 7.C.8 (HI-2146214, Revision 3). Table 7.C.13 of the HI-STAR 190 SAR (HI-2146214, Revision 3) includes specifications for the required cooling times of the allowable non-fuel hardware.
Responses to RAI 7-14:
o Clarify whether the shielding calculations adequately consider non-fuel hardware in the canister.
o
[Contains Proprietary Information - See enclosure]
5.
Holtec Responses to RAI 17-2-S, 17-12-S, 17-14-S, and 17-21-S
Response to RAI 17-21-S:
o The SAR was not revised per the applicants response to RAI 17-21-S related to inspections to verify the condition of the incoming canisters.
o The RAI response states that SAR Chapter 18 was revised to reflect the
[a]doption of the HISTAR 190 inspection checklist as a mandatory requirement for all MPCs, including those not containing high-burnup fuel. However, no changes to the SAR were made with respect to the referenced checklist, nor is it clear what exactly is meant by checklist.
o In addition, it is not clear why SAR Chapter 18, Aging Management Program, would be cited for revision for this item (rather than Chapter 10, Conduct of Operations Evaluation, where other such MPC receipt criteria are documented)
Response to RAI 17-12-S:
o SAR Section 18.5, Canister Aging Management Program, was not revised per the response to RAI 17-12-S. The RAI response states that the SAR was revised to state that a minimum of one canister from each originating site will be inspected via remote visual methods (and, as necessary, follow-up surface or volumetric techniques).
o The actual revision to the SAR was to SAR Table 18.5.1, which describes corrosion coupon testing protocols - which is unrelated to the subject of the RAI.
An independent reading of SAR Table 18.5.1 would conclude that corrosion coupons need to be placed near the inlets of one canister from each originating site.
5 o
SAR Section 18.5.1 still discusses the visual inspection of an MPC; this was not revised to state one canister from each originating site:
o SAR Section 18.5 should be revised per the RAI response to clearly state that the external surface of one canister from each originating site will be inspected via the remote visual method.
Response to RAI 17-2-S:
o The response to 17-2-S introduced a new option to qualify the fracture performance of steels for special lifting devices, using a methodology that does not appear to be adequate.
o The response added a new option in SAR Section 4.5.1.2 to verify the fracture performance of steels for special lifting devices (as an alternative to the standard option of simply conforming to the ASME B&PV Code fracture criteria).
o The new option to establish of minimum fracture properties is based on a fracture toughness vs. NDTT curve in NUREG-1815, which is specifically for steels with yield strengths less than 100 ksi. However, it proposes to use this methodology for steels of significantly higher strength (not evaluated in NUREG-1815). For example, the steel for the HI-TRAC lift link is STRENX 900E, which has a minimum yield strength of 120 ksi (but likely in practice would be between 130-140 ksi).
o The response should justify why the new fracture acceptance option (that uses the fracture toughness vs. NDTT curve in NUREG-1815) is relevant to very high strength steels (greater than 100 ksi yield strength).
Response to RAI 17-14-S:
o The SAR was not updated correctly to reflect the response to RAI 17-14-S; rather than revise the SAR aging management description, the applicant revised the SAR maintenance description (these are two different sets of activities with different implementation timelines).
6 o
Per the response, the applicant revised the VVM Aging Management Program (effective when the VVM exceeds 20 years of service) in the Aging Assessment Report (HI-2167378) to require that the internal surfaces to be inspected for all VVMs that house an MPC that is also undergoing remote inspection (i.e., when an MPC is being remotely inspected, also look at the VVM internal cavity surrounding that MPC).
o However, the applicant did not make any changes to the VVM AMP description in SAR Chapter 18 to reflect the change.
o The applicant did make a change to the Maintenance activity description (effective immediately) description in the SAR (SAR Table 10.3.1, item 10):
All VVMs that contain the MPCs used for the MPC AMP shall be inspected This revision suggests that the 5-year VVM inspection begins as soon as the VVM is placed into service.
Editorial Observations:
o SAR Table 4.2.1 was not revised per the response to RAI 17-1. The response stated that special lifting devices will be removed, while HI-TRAC CS lift link will be added.
o Harmonize the name of the MPC AMP between the SAR and Holtec Report No.
HI-2167378, Aging Assessment and Management Program for HI-STORE CIS.
SAR Chapter 18 references Canister AMP, while HI-2167378 references MPC AMP.
D.
Audit Team 1.
Jose Cuadrado, Project Manager 2.
Yoira Diaz-Sanabria, Chief - Storage and Transportation Licensing Branch 3.
Amitava Ghosh, Geotechnical Engineer 4.
John Wise, Senior Materials Engineer 5.
Zhian Li, Senior Nuclear Engineer 6.
Jin-Ping Gwo, Systems Performance Analyst 7.
Jeremy Tapp, Storage and Transportation Inspector 8.
Eli Goldfeiz, Health Physicist E.
Special Requests Appropriate handling and protection of proprietary information shall be acknowledged and observed throughout the audit.
F.
Deliverables NRC staff will issue an audit summary after completing the audit. The audit summary will discuss the outcomes of the audit and outline future actions for the completion of NRC staffs review of the license application.