ML22172A193

Amendment No. 7 to Certificate of Compliance No. 1032 for the HI-STORM Flood/Wind Multipurpose Canister Storage System Request for Additional Information Batch 2

ML22172A193
Person / Time
Site:	07201032
Issue date:	06/30/2022
From:	Yen-Ju C Office of Nuclear Material Safety and Safeguards
To:	Elisio D Holtec
Yen-Ju Chen, NMSS/DFM 415-1018
References
CAC 001208, EPID L-2021-LLA-0053
Download: ML22172A193 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Denise Elisio Holtec International Holtec Technology Campus 1 Holtec Blvd.

Camden, NJ 08104

SUBJECT:

AMENDMENT NO. 7 TO CERTIFICATE OF COMPLIANCE NO. 1032 FOR THE HI-STORM FLOOD/WIND MULTIPURPOSE CANISTER STORAGE SYSTEM -

REQUEST FOR ADDITIONAL INFORMATION SECOND BATCH

Dear Denise Elisio:

By a letter dated May 6, 2021 (Agencywide Documents Access and Management System

[ADAMS] Accession No. ML21126A267) and supplemented by a letter dated October 15, 2021 (ML21288A521), Holtec International (Holtec) submitted to the U.S. Nuclear Regulatory Commission a request to amend the Certificate of Compliance (CoC) No. 1032 for HI-STORM Flood/Wind (FW) Multipurpose Canister Storage System, as Amendment No. 7.

On June 10, 2022, the NRC staff issued the first batch of request for additional information (RAI)

(ML22129A216). The enclosure to this letter contains structural RAIs. We request that you provide the response to the RAI within 30 days from the date of this letter. If you are unable to meet this deadline, please notify us in writing, within 2 weeks of receipt of this letter, of your new submittal date and the reasons for the delay.

Please reference Docket No. 72-1032, CAC No. 001028, and EPID No. L-2021-LLA-0053 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.: 72-1032 CAC No.: 001208 EPID: L-2021-LLA-0053

Enclosure:

RAIJune 30, 2022 Signed by Chen, Yen-Ju on 06/30/22

SUBJECT:

AMENDMENT NO. 7 TO CERTIFICATE OF COMPLIANCE NO. 1032 FOR THE HI-STORM FLOOD/WIND MULTIPURPOSE CANISTER STORAGE SYSTEM -

REQUEST FOR ADDITIONAL INFORMATION SECOND BATCH, DATE:

DISTRIBUTION DFM r/f JChang, DFM HLindsay, DFM ASotomayor-Rivera, DFM DForsyth, DFM LHowe, DFM JWoodfield, DFM DMarcano, DFM MDiaz-Maldonado, DFM ARivera-Varona, DFM ADAMS No.: ML22172A193 OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME YChen WWheatley PKoch JColaccino YDiaz-Sanabria DATE 06/24/2022 06/24/2022 06/24/2022 06/27/2022 06/28//2022 OFFICE USE ONLYJune 30, 2022 Request for Additional Information Second Batch

Docket No. 72-1032 Certificate of Compliance No. 1032 Amendment No. 7 to the HI-STORM Flood/Wind Multipurpose Canister Storage System

The staff identified additional information needed in connection with its review of the application of Amendment No. 7 to the Certificate of Compliance (CoC) No. 1032 for HI-STORM Flood/Wind (FW) Multipurpose Canister (MPC) Storage System as provided in the request for additional information (RAI) discussed below. Each question describes information needed by the staff to complete its review of the application and to determine whether the applicant has demonstrated compliance with regulatory requirements in Title 10 of the Code of Federal Regulations (10 CFR), Part 72.

Structural RAI

RAI 3-1Provide descriptions of the evaluations of the Version unventilated high density (UVH) cask in chapter 3.I of the safety analysis report (SAR). These descriptions should include the methodologies and acceptance criteria used in the evaluations as well as the results and discussions of those results that supports the stated conclusions. Specifically include the following evaluations:

a) The evaluation of the MPC containment boundary in the Version UVH cask,

b) The evaluation of Version UVH cask under internal and external pressure loads mentioned in section 3.I.3.2 of the SAR,

c) The evaluation of Version UVH closure lid under lifting and snow load conditions mentioned in section 3.I.3.3 of the SAR,

d) The evaluations of Version UVH casks stability in the event of flood, explosion, and earthquake mentioned in sections 3.I.3.4 through 3.I.3.6 of the SAR,

e) The evaluation of Version UVH cask in the event of tornado (wind and missile impacts) mentioned in section 3.I.3.7 of the SAR, and

f) The evaluation of Version UVH cask in the event of non-mechanistic tip-over mentioned in section 3.I.3.8 of the SAR.

In accordance with 10 CFR 72.230(a), the applicant for a CoC must submit a SAR describing the proposed cask design and how the cask should be used to store spent fuel safely. However, the description of the design of the Version UVH cask in the SAR, specifically for the structural evaluations listed above, merely refences other reports in lieu of describing the methodology, acceptance criteria, results, and discussion for the structural evaluations. For example, the description of the tornado missile penetration analysis in SAR section 3.I.3.7 is a single sentence, The

Enclosure

penetration analysis for Version UVH cask using the wind and missile characteristics defined in Tables 2.2.4 and 2.2.5 is presented in Appendix J of [3.4.15]

demonstrating all results are acceptable. This statement does not describe the penetration analysis; it references other tables and reports. The staff requests descriptions of the structural evaluations of Version UVH cask be added to the HI-STORM FW SAR that include the methodologies used in the evaluations, the acceptance criteria considered for the evaluations, the results of the analyses, discussions of those results that support the conclusions, and the conclusions of the evaluations.

This information is needed to determine compliance with the regulatory requirements in 10 CFR 72.230(a) and 10 CFR 72.236(l).

RAI 3.2Provide full versions of the following reports: (1) Holtec proprietary report HI-2094418, Structural Calculation Package for HISTORM FW System, revision 37 and (2) Holtec proprietary report HI-2094392, Tornado Missile Analysis for HI-STORM FW System, revision 13.

The applicant submitted change pages of the three documents requested to assist the staff in the review. However, some of the changes in this amendment rely on or reference information in sections of these documents that were not included in the change pages versions. For example, table 2.I.2.1 of the SAR states, the lifting analysis of Version E cask using bounding lifted weight in Table 3.2.8 remains applicable for Version UVH cask. To verify this statement, the staff needs to review the lifting analysis of the Version E cask, which was not included in the change pages versions of HI-2094418.

This information is needed to determine compliance with the regulatory requirements in 10 CFR 72.236(l).

RAI 3.3Clarify the editorial changes with regard to handling and short-term operations made in sections 2.2.3 and 9.1 of the SAR. Specifically, address the followings:

a) Discuss the intent of the editorial changes, including which regulatory requirements, if any, these statements are addressing, and explain the view that the changes are merely editorial.

In the Summary of Proposed Changes for this amendment, the applicant listed these changes in the last two bullets under editorial changes. However, it appears to the staff that the applicant may be defining new methods of evaluation for loadings, operations, and equipment. If these changes are intended to define new methods of evaluation, they would be considered technical changes, not editorial changes. NRC Regulatory Information Summary 2017-05, Administration of 10 CFR Part 72 Certificate of Compliance Corrections and Revisions, and section 4.3 of NEI 12-04, Guidelines for 10CFR 72.48 Implementation, provide guidance on editorial changes.

The staff requests clarification on the intent of these editorial changes and the reasoning for listing them as editorial.

b) Describe in the SAR the methods of evaluation and acceptance criteria for the analyses of the loadings, handling operations, and equipment used for the safety analysis mentioned in section 2.2.3 of the SAR and for the reports referenced in section 9.1.

The changes in sections 2.2.3 and 9.1 of the SAR state that the method of analysis shall follow prior established precedent and a series of generic reports [9.1.4 thru 9.1.7] that address various loading scenarios have been adopted in Holtecs configuration control system. The staff requests the applicant supplement these statements to describe in the SAR the methodologies and acceptance criteria used in these analyses.

c) Clarify the statement in section 2.2.3 of the SAR, To perform the site-specific safety analysis of the handling evolutions, the magnitude of the incident load should be informed by its frequency of likely occurrence and the mitigative measures employed.

It appears to the staff that this statement is introducing a new method of evaluation for analyzing handling operations that includes considerations of the likelihood of certain loads and potential mitigative measures. Clarify the followings: (1) what was the intent of this statement; (2) what loads does this statement apply to; (3) how are these likelihoods and mitigative measures determined; (4) how are the likelihood and mitigative measures considered in or affect these site-specific safety analyses; and (5) what regulatory requirement, if any, does this statement address.

d) Define the terms short-term operations and transitional transitory steps as they are used in the statement from section 2.2.3 of the SAR, All short-term operations, except the transitional transitory steps (such as upending or down-ending of the cask, placement of the Closure Lid on HI-STORM), shall be subject to safety analysis under the postulated environmental loads.

e) Justify the exception of transitional transitory steps to the conditions that require safety analysis, as stated in section 2.2.3 of the SAR.

In accordance with 10 CFR 72.236(l), an applicant for a CoC shall evaluate the Important to Safety (ITS) Systems, Structures, and Components (SSCs) under normal, off-normal, and credible accident conditions, and the definition of ITS SSCs in 10 CFR 72.3 includes features that prevent damage to the spent fuel during handling. Given these regulatory requirements, its not clear to the staff what transitional transitory steps are or why they do not require safety analysis.

f) Describe in the SAR the method of evaluation and acceptance criteria for the probabilistic risk assessment (PRA) discussed in the statement from section 2.2.3 of the SAR, With respect to short-term operations in dry storage campaigns, a [PRA] may be employed at a geologically stable and low return frequency site, characterized by a small number of annual loadings, to evaluate the risk associated with a simultaneous earthquake event.

Additionally, clarify: (1) how this PRA would be considered in or affect the safety evaluation of operations; (2) which operations would be affected; (3)

how the PRA would be used to address regulatory requirements, if any; (4) which regulatory requirements would the PRA address; (5) the definitions of geologically stable and low return frequency site; and (6) the justification for those definitions.

It appears to the staff that the quoted sentence from SAR section 2.2.3 is attempting to establish a new method of evaluating operations using a risk assessment, however, the applicant has not provided any information on this analysis.

g) Describe in the SAR the methods of evaluation and acceptance criteria for the sliding analysis mentioned in the statement from section 2.2.3 of the SAR, Safety against potential sliding of the assemblage leading to an impact with a safety significant structure proximate to the haul path shall also be ascertained.

h) Justify the statement in section 9.1 of the SAR that characterizes loading configurations and ancillary equipment as being outside of the scope of the final safety analysis report (FSAR). Additionally, clarify which loading configurations and ancillary equipment are being discussed in the editorial change in section 9.1 of the SAR and which regulatory requirements this editorial change is addressing, if any.

In section 9.1 of the SAR, the applicant stated, The safety evaluation of the various loading configurations and ancillaries is outside the scope of this FSAR because such equipment and analyses must, of necessity, be site specific to accord with the exigencies of the architecture of each plant. Its not clear to the staff which loading configurations and ancillary equipment the applicant is referring to. The staff notes that 10 CFR 72.236(l) requires an applicant for a CoC to evaluate the ITS SSCs under normal, off-normal, and credible accident conditions and the definition of ITS SSCs in 10 CFR 72.3 includes features that prevent damage to the spent fuel during handling.

Given these regulatory requirements, its not clear to the staff why the applicant considers the safety evaluation of certain loading configurations and equipment outside the scope of this FSAR. The staff recognizes the site-specific nature of handling operations at individual independent spent fuel storage installations, but its not clear to the staff how the presence of site-specific characteristics preclude the applicant from meeting the regulatory requirements applicable to CoC holders in 10 CFR Part 72.

This information is needed to determine compliance with the regulatory requirements in 10 CFR 72.230(a) and 10 CFR 72.236(l).

ML22172A193 OFFICE NMSS/DFM/STLB NMSS/DFM/STLB NMSS/DFM/MSB NRR/DEX/ESEB NAME YChen YC WWheatley WW PKoch PK JColaccino JC DATE Jun 24, 2022 Jun 27, 2022 Jun 24, 2022 Jun 27, 2022 OFFICE NMSS/DFM/STLB NMSS/DFM/STLB NAME YDiaz-Sanabria YChen YC BWhite for BW DATE Jun 28, 2022 Jun 30, 2022