ML22089A085

ISFSI Exemption Request, Final Request for Additional Information

ML22089A085
Person / Time
Site:	07201041
Issue date:	03/31/2022
From:	Donald Habib Storage and Transportation Licensing Branch
To:	Georgeson C South Texas
D HABIB NRC/NMSS/DFM/STLB 3014151035
References
CAC 001028, EPID L-2022-LLE-0009
Download: ML22089A085 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 C. H. Georgeson, General Manager Engineering South Texas Project Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, TX 77483

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR REVIEW OF THE SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION, LICENSE NO. SNM-2514 - COST ACTIVITY CODE/ENTERPRISE PROJECT IDENTIFICATION NUMBER 001028/07201041/L-2022-LLE-0009

Dear Mr. Georgeson:

By letter dated March 11, 2022 (Agencywide Documents Access and Management System

{ADAMS} Accession No. ML22070B140), South Texas Project Nuclear Operating Company (STPNOC, or the applicant) requested the U.S. Nuclear Regulatory Commission (NRC) to grant an exemption for one multipurpose canister (MPC), Model MPC-37, Serial Number 248, in use at the South Texas Project Electric Generating Station (STPEGS). The application specifically requests an exemption from the requirements of Appendix B, Section 3.3, "Codes and Standards," of Certificate of Compliance (CoC) No. 1032 for the HI-STORM FW MPC Storage System. In accordance with Section 3.3 the HI-STORM FW, an MPC-37 must meet the 2007 Edition ASME Code, which requires that 100 percent of the weld seam joining the baseplate to the shell of the canister be inspected by radiography test.

In connection with our review, we need the information identified in the enclosed requests for additional information (RAIs). To assist us in scheduling the NRC staff review of your response, we request that you provide this information 30 calendar days from the date of this letter. Inform us at your earliest convenience, but no later than 30 calendar days from the date of this letter if you are not able to provide the information by that time. If you are unable to provide a response by the stated date, our review may be delayed.

Please reference Docket No. 72-1041 and Cost Activity Code/Enterprise Project Identification No. 001028/07201041/L-2022-LLE-0009 in future correspondence related to this review. The NRC staff is available to clarify these questions, and, if necessary, to meet and discuss your proposed responses.

March 31, 2022

C. H. Georgeson 2

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this communication will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If you have any questions regarding this communication, please contact me at 301-415-1035 or via e-mail at Donald.Habib@nrc.gov.

Sincerely, Donald Habib, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket Nos. 72-1041, 50-498, 50-499 License/Certificate No. SNM-2514

Enclosures:

1. Request for Additional Information RAI M-1

2. Request for Additional Information RAI C-1 Signed by Habib, Donald on 03/31/22

ML22089A085 OFFICE DFM/STLB/PM DFM/STLB/LA DFM/MSB/TR DFM/CTCFB/TR NAME DHabib WWheatley OKhan CBajwa DATE OFFICE DFM/MSB/BC DFM/CTCFB/BC DFM/STLB/BC DFM/STLB/PM NAME TBoyce DMarcano YDiaz-Sarabria DHabib DATE South Texas Project Electric Generating Station Units 1 and 2 Independent Spent Fuel Storage Installation Request for Exemption from Certificate of Compliance Inspection Requirement for One Multipurpose Canister Request for Additional Information RAI M-1 March 31, 2022 FINAL Provide additional information to demonstrate that the stress reduction factor used in the stress analysis for HI-STORM FW multipurpose canister (MPC) adequately bounds the possible weld flaws in the unexamined section of MPC shell to baseplate weld.

The applicant proposed to use a joint efficiency factor from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section VIII, Division 1. However, the joint efficiency factor from ASME Section VIII, Division 1, is not applicable to the HI-STORM FW MPC, which is designed and constructed using ASME Section III, Division I, Subsection NB, with NRC approved ASME B&PV code alternatives.

Subsequently, the applicant re-evaluated calculations of bounding load cases for the MPC using a stress reduction factor described in NRCs interim staff guidance (ISG) -15, Materials Evaluation (NRC ADAMS Accession Number ML010100170). However, the stress reduction factor of 0.8 from ISG-15 is applicable for a lid to shell weld with multiple penetrant testing (PT) in lieu of a volumetric examination. Therefore, the applicants proposed use of the stress reduction factor of 0.8 as a design criterion was not supported by a justification that demonstrates it was appropriate for the analyses of the possible weld flaws in the unexamined section of the repaired MPC shell to baseplate weld. While the stress reduction factor of 0.8 may be adequate to bound possible weld flaws as a result of the unexamined section of the repaired MPC to shell baseplate weld, the applicant did not provide an analysis or supporting information to justify the value of the stress reduction factor used in the re-evaluated calculations of the bounding load cases.

This information is needed to determine compliance with 10 CFR 72.236(b) and (l).

South Texas Project Electric Generating Station Units 1 and 2 Independent Spent Fuel Storage Installation Request for Exemption from Certificate of Compliance Inspection Requirement for One Multipurpose Canister Request for Additional Information RAI C-1 March 31, 2022 FINAL Discuss how the results of the helium leakage testing completed after the weld repair on MPC 248 demonstrate that the MPC meets the required leakage acceptance criteria. of the letter from South Texas Project Nuclear Operating Company, dated March 11, 2022, (NOC-AE-22003877) states the following (on page 1):

Following completion of the weld repair, MPC 248 successfully passed a helium leakage test during factory acceptance testing as well as a hydrostatic test performed at STPEGS during loading operations.

The statement above suggests that the containment boundary for the MPC in question was demonstrated as leaktight for purposes of the confinement review (assuming that fabrication leakage test was conducted in accordance with the SAR for this system); additionally, the applicant asserted that confinement has been maintained for this MPC following the weld repair. Staff review of the results of the leak testing of MPC 248 may provide reasonable assurance that confinement has been maintained for this MPC.

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

Ltr ML22089A085 OFFICE NMSS/DFM/STLB NMSS/DFM/STLB NMSS/DFM/CTCFB NMSS/DFM/MSB NAME DHabib WWheatley CBajwa OKhan DATE Mar 30, 2022 Mar 30, 2022 Mar 31, 2022 Mar 30, 2022 OFFICE NMSS/DFM/MSB NMSS/DFM NMSS/DFM/STLB NMSS/DFM NAME TBoyce DMarcano DHabib AParker-Haynes DATE Mar 31, 2022 Mar 31, 2022 Mar 31, 2022 Apr 1, 2022