ML22331A004

Attachment 1 - HI-STORE Responses to Action Items

ML22331A004
Person / Time
Site:	HI-STORE
Issue date:	11/23/2022
From:	Holtec
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML22331A002	List: ML22331A003 ML22331A004 ML22331A005 ML22331A008 ML22331A009 ML22331A010 ML22331A011 ML22331A012 ML22331A014 ML22331A015 ML22331A017 ML22331A020
References
5025076
Download: ML22331A004 (1)

Text

Attachment 1 to Holtec Letter 5025076 Action Items for HI-STORE CISF (November 2022):

Action Status

1. Holtec Bearing Capacity and Settlement Calculation The identified Package: Holtec has given the same figure in Attachment A.1 for calculation ISFSI storage pad and Attachment B.1 for CTF foundation to package has been describe the subsurface profiles underneath each site. Figure in updated.

A.1 has been repeated in B.1. (this is in Attachment 6 of Holtecs 4/15/22 submittal, HI-2188143, Revision 3). Holtec should also correct the MathCad file in the Report No. HI-2188143, HI-STORE Bearing Capacity and Settlement Calculations, on Page B.4 of B.15 (or, PDF Page 36 of 53). Part of the calculation to estimate the modified cohesion and friction angle is missing and, consequently, resulted in unrealistic static and seismic bearing capacity on Page B.5 of B.15 (or, PDF Page 38 of 53).

2. Long-term settlement of the pad (25x10) with UMAX FSAR is HI-2188143 has limited to 0.2 in, application calculates settlement assuming a 5x5 been updated/

array with site parameters. NRC confirmatory calculation shows long-term settlement would be 0.2 in using the site data and 25x10 ISFSI array. Holtec could conduct this analysis using MathCad quickly and confirm.

3. The SAR pagination is off in the Table of Contents, at least for Table of contents Section 5.4. has been updated throughout, including Section 5.4

4. License Condition 16 for physical security needs to be updated to License Condition cite specific revision number for the PSP. 16 has been updated with specific revisions for all reports.

License Condition 15 has also been similarly updated.

5. License Condition 20 for insurance needs to indicate a specific License Condition version number of HI-2177593 (Revision 2). The License Condition 20 has been and HI-2177593 also need to be specific about the effective date of updated with the insurance. specific revision and effective date of insurance.

6. Holtec needs to submit a public version of their financial assurance A non-proprietary document, HI-2177593: version of HI-2177593 Rev 2 is Page 1 of 7

Attachment 1 to Holtec Letter 5025076 Current latest revision is Rev.2, ML22227A162 included in this submittal Latest public revision found in ADAMS is Rev.1, ML18345143

7. Holtec needs to submit a public version of their UMAX/HI-STORE A non-proprietary thermal evaluation, HI-2177591: version of HI-2177591 Rev 2 is Current latest revision is Rev.2, ML21304A005 included in this Latest public revision found in ADAMS is Rev.0, ML18191B013 submittal

8. Holtec needs to submit a public version of their CTF thermal A non-proprietary evaluation, HI-2177597: version of HI-2177595 Rev 2 is Current latest revision is Rev.2, ML21228A215 included in this Latest public revision found in ADAMS is Rev.0, ML18191B014 submittal.

9. Holtec needs to submit a public version of their thermal evaluation A non-proprietary for the HI-TRAC CS Transfer Cask, HI-2177553: version of HI-2177553 Rev 3 is Current latest revision is Rev.3, ML22108A130 included in this Latest public revision found in ADAMS is Rev.0, ML18191B012 submittal

10. Decommissioning Funding Plan Report cites MOX and GTCC as An updated version authorized contents for storage at HI-STORE, although the license of HI-2177565 is does not authorize those contents. included in this submittal.

11. License Condition 12 to be deleted License condition 12 has been deleted.

12. Paragraph (e) of SAR section 1.2.1: This paragraph has been updated to As can be ascertained from the design information in this SAR, the acknowledge the HI-STORM UMAX CIS features no above-ground important-to-Cask Transfer safety building structure. All canister transfer facilities are below-building as an ground.

above ground important to safety facility.

13. The definitions of ambient temperature in the Tech Specs and the The SAR glossary SAR are different (24-hour average vs. 72-hour average) has been updated to be 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> consistent with the Tech Specs

14. The license number, if issued, would not be SNM-1051. The The proposed number would likely be SNM-2516. Proposed license number can license number be revised to SNM-25XX.

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Attachment 1 to Holtec Letter 5025076 has been updated to SNM-25XX.

15. HI-STORM 100 FSAR Revision 14 (SAR reference [1.3.3] not The HI-STORM found in ADAMS. 100 FSAR Revision 14 is included as an attachment to this letter (both proprietary and non-proprietary versions)

16. HI-STAR 190 and HI-TRAC CS cannot be placed less than 1 inch Considering the away from the edge of any slab. This dimension is limited by the current design of calculation on sliding of the cask under tornado and seismic loads. the slab and cask Set a more reasonable operational edge distance for cask storage transporters it in the operational procedure that is to be used. should be physically impossible to place a HI-STAR 190 or HI-TRAC CS within 1 inch of the edge.

However for full assurance, a note has been added to the operational procedures in Chapter 10 to make sure this distance is considered.

17. The maximum height of the HI-TRAC CS from the ground during its A note has been transport to the ISFSI is limited to 1 ft by analysis. This restriction added to the needs to be captured in the operational procedure. operational procedures in Chapter 10 to ensure the carry height is controlled.

18. HI-STAR 190 and HI-TRAC CS has been evaluated against tip- While the major over and missile impact during a tornado hence no administrative short term control of operation is necessary in using the HI-STAR 190 or HI- operations TRAC CS in a free-standing configuration. involving the HI-TRAC CS and HI-STAR 190 are fully evaluated as Page 3 of 7

Attachment 1 to Holtec Letter 5025076 described in Chapter 15, there may be intermediate activities that are not explicitly analyzed, and so the administrative controls provides assurance that a tornado / tornado missile is not a credible event.

19. In the ISFSI design, the demand due to the increased weight of the A comparison of HI-TRAC CS is enveloped by the UMAX design because the input vertical PGA has design seismic event is higher. While this is a may be the case, the been added to staff notes that only the vertical component of the event plays into Chapter 5.

the vertical load increase. The SAR should have a note that compares the vertical components of both GM to take credit for this claim. Currently only the Newmark summations are compared.

20. SAR Figures 5.3.4 through figure 5.3.6 show comparison at 20% A description of the damping RG 1.60. However, Table 4.3.3 shows the DBE at 5%, damping used for and the DECE at 5% was used for design. What was the design Figures 5.3.4 input at the base of the soil springs? This need to be clearly stated through 5.3.6 has in the SAR, with explanation for why this was chosen. been added to Chapter 5.

21. Add percentage damping to the spectra shown in SAR Chapter 5 The figures have figures. This information is in the calculation package. been updated to provide percentage damping.

22. A representative design of the tilt frame assembly anchoring in the This calculation CTB is shown in Attachment 13A of Holtec Report No. HI-217758. package has been The pictorial shows the tilt frame attached to a floor plate weldment updated and is via Tee bolts and the floor plate weldment attached to the CTB floor included with this slab via J-hooks. This design configuration needs more details submittal.

about the floor plate weldment, Tee bolt design stress and the J-hook design.

23. A design for the crane runway beam could not be found in any of Information on the the submitted documents. The crane vendor has provided a design crane runway that starts at the crane bridge and covers the rest of the crane. beam has been added to Chapter 5.

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Attachment 1 to Holtec Letter 5025076

24. Add an argument why the corbel does not see the torsional load Information on the that arises from seismic and surge loads from crane operation. It torsional load has can be argued that the crane girder at the top is restrained by the been added to truss system and the lateral forces are spread into the RC wall. So, Chapter 5.

there is no torsion in the girder.

25. SAR Section 14.4 mentioned the presence of low-level waste at the Section 14.4 has site. However, there was no mention of its location, no mention of been updated to a fires impact on the low-level radioactive waste, and no mention state that the low-of the means to contain the low-level waste in the event of a fire. In level waste will be addition, there was no discussion regarding its consideration in the stored within Fire Protection Plan (Holtec Report HI-2177938) and Emergency flammable storage Response Plan (Holtec Report HI-2177535) (e.g., fire prevention, cabinets/containers fire detection and control). and a pointer statement to Section 14.4 has been added to SAR Section 6.5.3.

Also, Section 5.3.1 of the Emergency Response Plan has been updated, and HI-2177535 attached to this submittal. The Fire Protection plan is not impacted by this level of detail.

26. Although SAR Section 6.5.3 stated that there are no combustibles Section 6.5.3 of the stored within the ISFSI, the HI-STORE CIS Facility Environmental SAR has been Report (HI-2167521) Section 6.5 mentioned all above ground updated to state diesel storage tanks and Section 4.10.2 mentioned back-up diesel that all fixed generators and Section 1.4.2.3 mentioned fire pump diesel locations with engine. Clarify that the combustibles (e.g., fuel, hydraulic fluid), combustible diesel engine, diesel generators, and the diesel tanks would materials (such as mitigate fire impacts and are not stored in an area that would diesel generators impact radioactive materials (e.g., spent fuel during receipt, and storage tanks) operations within CTB and CTF, and storage of the low-level are not located in radioactive waste (mentioned in SAR Section 14.4)). areas that could impact radioactive materials.

27. Although system details were not provided, Holtec Report HI- HI-2177535 2177535, Section 5.3.1 of the Emergency Response Plan indicated Section 5.3.1 has that fire protection systems are designed in accordance with NFPA been updated to 30 requirements [National Fire Protection Association 30 point at the NFPA Combustible and Flammable Liquids Code]. The response codes in general Page 5 of 7

Attachment 1 to Holtec Letter 5025076 should confirm that this broad statement indicates the fire detection rather than pointing and suppression systems are of sufficient size and performance out a specific one.

and that the facility is in accordance with NFPA 801 Standard for Reference 3.4 of Fire Protection for Facilities Handling Radioactive Materials and HI-2177938 has other relevant NFPA codes, including the automatic sprinklers and been deleted so water spray systems and portable fire extinguishing systems that it does not mentioned in Section 6.3 of Holtec Report HI-2177535. Confirm point at one single that diesel tanks are in accordance with relevant NFPA codes. NFPA code (there previously was no direct reference to that document).

Chapter 4 of the SAR has also been revised to point to the NFPA codes in general. Chapter 19 has been updated to delete the references no longer used (4.5.7 and 4.5.12). Also HI-2177938 Section 7.1.1.2 has been updated to state that all permanent fire loads shall be located, designated, operated, and maintained in accordance with applicable NFPA code guidelines.

Diesel tanks would fall into this category

28. SAR Section 2.2.2 discussed results that indicated a postulated SAR Section 2.1.2 rupture of gas pipelines near the site would not adversely impact has been updated operations of the HI-STORE CIS facility. Using similar to address the gas considerations, clarify that the active gas and oil wells near the site and oil wells.

(e.g., SAR Table 2.1.5) would not adversely impact HI-STORE CIS facility operations.

29. Clarify that the Fire Protection Audits and Self Assessments Section 7.3 of the mentioned in Section 3 include audits and assessments of the Fire Fire Protection Protection Plan document as well as fire hazards analyses that Plan (HI-2177938)

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Attachment 1 to Holtec Letter 5025076 periodically examine the design of systems, operating plans has been revised (including as the site expands), and controls and that these audits to include other and assessments are by qualified fire safety personnel. In addition, activities in the the qualification requirements for qualified fire safety personnel, audit, required the and the bases for the qualifications, should be listed. audit to be performed whenever the site expands or changes significantly, and requires the individuals performing the audit to be qualified per applicable NFPA code guidelines.

30. Clarify the criteria associated with fire protection at the site, such as See responses to being in accordance with NFPA 801 Standard for Fire Protection other comments for Facilities Handling Radioactive Materials. above. The SAR has been updated to point at NFPA codes in general rather than any specific code.

31. Holtec Fire Protection Plan (FPP) Report HI-2177938 Section 6 HI-2177938 has uses the word should when describing the objectives; the Fire been updated to Protection Plan should be clear that objectives are to be met. change should to shall in Section 6.

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