ML23069A230

Attachment 1: HI-STORM 100 Amendment 19 Rsi Responses

ML23069A230
Person / Time
Site:	Holtec
Issue date:	03/10/2023
From:	Holtec
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
Shared Package
ML23069A227	List: ML23069A229 ML23069A230 ML23069A231 ML23069A232 ML23069A233 ML23069A234 ML23069A235 ML23069A236 ML23069A237 ML23069A238 ML23069A239 ML23069A240 ML23069A241
References
CoC No. 1014, CAC 001028, EPID L-2022-LLA-0028, 5014959
Download: ML23069A230 (1)

Text

Holtec Letter 5014959 Attachment 1 Holtec Response to Request for Supplemental Information Docket No. 72-1014 Holtec International HI-STORM 100 Multipurpose Canister Storage System Certificate of Compliance No. 1014 Amendment No. 19 RSI-1 Provide justification for not updating appendices A-100U and B-100U.

Holtec International (Holtec, the applicant) stated that it would not update appendices A-100U and B-100U but did not provide any explanation nor justification for the decision.

The U.S. Nuclear Regulatory Commission (NRC) staff notes that not updating appendices A-100U and B-100U could cause inconsistencies and confusion as described below:

1. Per the NRCs endorsement on the graded approach (Agencywide Document Access and Management System [ADAMS] Accession No. ML19353D337), administrative controls technical specifications (TS) would be in appendix B, section 4. The applicant stated that it will not update appendix B-100U, so some administrative controls will remain in the certificate of compliance (CoC) to avoid complication. For example, condition 5, heavy load requirements (Form ID: CoC-5), and condition 10, pre-operational testing and training exercise (Form ID: CoC-10), will remain in CoC instead of moving to appendices B, D, and B-100U.Therefore, some administrative controls will be in the CoC and some in appendices B and D. This practice defeats the goal of streamlining the CoC & TS and could potentially cause confusion.

2. Form ID: CoC-15. CoC condition 15, 72.212 evaluations for renewed CoC use, is being moved to appendix A, section 2 as it is important to site-specific 72.212 evaluations. This information also applies to appendix A-100U, which Holtec decided not to update. By moving it to only appendix A, it creates a regulatory void.

3. Currently, appendix A-100U sections 1.1 through 1.4 refer to appendix A. All the referenced sections in appendix A are being moved to the new appendix B. Appendix A-100U would have several incorrect references if not updated.

4. Currently, appendix B-100U refers to appendices A and B in the following sections:

• Section 1.0, definitions, refers to appendix A.

• Section 3.3.1 refers to table 3-1 of appendix B.

• Section 3.6.2.2 refers to appendix A.

These referenced sections are being moved to other parts of the TS. Appendix B-100U would have several incorrect references if not updated.

The staff needs this information to determine compliance with Title 10 of the Code of Federal Regulations (10 CFR) 72.244.

Holtec RSI Response:

Holtec understands that the decision to not update CoC Appendixes A-100U and B-100U with the rest of the CoC Appendixes has introduced some incorrect cross-references/regulatory voids. Holtec has updated small sections of the CoC and Appendixes below to address these issues as described below. Holtec does not feel reorganization of these Appendixes A-100U and B-100U is worth the effort to propose (Holtec) and review (NRC Staff) at this time. Reorganization of these Appendixes 1 of 4

Holtec Letter 5014959 Attachment 1 may be proposed at a future time in a separate submittal.

1. Per the NRCs request, Holtec has incorporated the administrative controls for condition 5 (Form ID:

CoC-5), and 10 (Form ID: CoC-10) of the CoC to be included in Appendixes B, D, and A-100U. As Appendix A-100U contains the administrative changes section, it is more applicable to contain conditions 5 and 10 in section A-100U rather than in Appendix B-100U. In appendixes B and D, condition 5 and 10 are now located in sections 4.7 and 4.8 respectively. In appendix A-100U condition 5 and 10 are now located in sections 5.8 and 5.9 respectively. In addition, the CoC has been updated to remove sections II.c and II.d which represent condition 5 and 10. The appropriate Evaluation Forms and Matrix are also updated.

2. Per the reorganization matrix, the CoC condition 15 (Form ID: CoC-15) is moved to Appendix A section 2.5. This CoC condition 15 information is now also added to Appendix A-100U as section 2.1.

Adding this section into Appendix A-100U prevents the creation of a regulatory void and maintains consistency with the inclusion of condition 15 in Appendix A. The appropriate Evaluation Forms and Matrix are also updated.

3. Per the NRCs request, Holtec has modified Appendix A-100U to reference Appendix B for sections 1.1-1.4. By modifying the references, A-100U now correctly references the other Appendixes.

4. Similar to Appendix A-100U, Appendix B-100U also referred to Appendix A for definitions. To rectify this, Appendix B has been listed as the correct reference in section 1 of Appendix B-100U.

Section 3.3.1 in Appendix B-100U is now modified to reference Appendix A table 3-1 rather than the previous Appendix B table 3-1. By modifying the reference, this aligns the Appendix B-100U with the applicable data following the reorganization matrix.

Section 3.6.2.2 in Appendix B-100U currently references Appendix A since table 3-2 in Appendix A contains all the backfill pressures. Since table 3-2 maintains Appendix A as the applicable reference it will be left as is. Appendixes B and D reference the pressure in the MPC cavity during drying, while Appendixes A and C reference the backfill pressure. To align with this, Appendix B-100U will contain the same references to maintain consistency.

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Holtec Letter 5014959 Attachment 1 Observations O-1 Provide risk insight evaluation for the following forms:

• Form ID: A-1.1, definition

• Form ID: A-1.2, logical connectors

• Form ID: A-1.3, completion times

• Form ID: A-1.4, frequency

• Form ID: B-Table 3-1

• Form ID: C-1.1

• Form ID: C-1.2

• Form ID: C-1.3

• Form ID: C-1.4

• Form ID: D-Table 3-1 As noted in the NRCs endorsement (ML19353D337), the graded approach criteria were developed to improve the spent fuel dry storage licensing process by applying risk insights to clarify the information required in the CoC and TS and removing or relocating details that are not risk significant to safety, thereby providing additional flexibility for licensees. Thus, the graded approach makes the contents of the CoC and TS more safety- and risk-focused and the level of detail more appropriate. The risk insight is an important part of the graded approach in providing the bases for removing or relocating the information in the CoC and TS.

The staff needs this information to determine compliance with 10 CFR 72.244.

Holtec RSI Response:

The requested justification for adding risk insight analysis has been updated and incorporated into the latest revisions of the Evaluation Forms. Holtec attempted to use the same level of detail used for similar items during The Pilot Program which has been approved by the NRC. By performing the full evaluation and not leaving N/A as a response Holtec provides a full and clarified evaluation for the NRC to review based upon the update.

O-2 Provide justification or additional information in the evaluation summary. The following are some examples:

• Form ID: A-5.8, fabrication helium leak test. The evaluation answered yes for appendix B section 1, but the summary states to stay in appendix A.

• Form ID: C-5.4, fabrication helium leak test. The evaluation answered yes for appendix D section 1, but the summary states to stay in appendix C.

The evaluation summaries for these forms are inconsistent with the information provided on the rest of the forms. The applicant did not provide sufficient justification to explain the differences.

The staff needs this information to determine compliance with 10 CFR 72.244.

Holtec RSI Response:

Holtec has reviewed the Evaluation Forms completed to ensure consistency between the evaluation rows and the summary statements on each form. The following items have been updated to correct inconsistent statements:

• Form ID: CoC-15

• Form ID: A-5.8

• Form ID: C-5.4 O-3 Provide justification for moving American Society of Mechanical Engineers (ASME) code alternatives to appendix A instead of a new appendix as done in the pilot.

In the pilot, ASME code alternatives were moved to a new appendix C. The applicant moved code alternatives from appendix B to the new appendix A (Form ID: B-Table 3-1) and from appendix D to the new appendix C (Form ID: D-Table 3-1) without justification for the difference from the pilot.

The staff needs this information to determine compliance with 10 CFR 72.244.

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Holtec Letter 5014959 Attachment 1 Holtec RSI Response:

The pilot program provided a lot of good guidance on restructuring/focusing a Part 72 CoC on safety per the graded approach. Holtec applied the guidance as applicable to the structure/content of our CoC.

While the final locations of the ASME code alternative information are different between the pilot program and Holtecs proposed HI-STORM 100 Amendment 19, both the pilot and Holtecs amendment concluded that the ASME code alternatives did need to remain in the CoC and that the evaluation form/proposed outline developed and described in RIRP-I-16-01 (ML17138A119) did not include a standard location for this information, nor does 10CFR72.244 indicate a specific location for this information. Therefore, the appropriate location of the ASME code alternative information is dependent on the specifics of the System being considered.

As explained in the pilot, the ASME code alternatives were moved into a new Appendix C. This was a reasonable decision considering the structure and format of the CoC evaluated in the pilot program. However, based on the current structure and format of the HI-STORM 100 CoC, it seems more straightforward to keep the table in its current location. The HI-STORM 100 CoC contained six Appendices prior to this Amendment 19 effort to reorganize the CoC. These six Appendices were paired in sets of two in order to organize information about various Versions of the HI-STORM 100. The CoC reorganization proposed in this Amendment 19 maintains these three pairs of Appendices (six total) in an effort to keep the separation of information about different versions of the HI-STORM 100 systems to ensure users of the CoC can easily track down information about specific versions.

Creating a new third Appendix for each existing pair of Appendices just to contain the appropriate ASME code alternatives would have resulted in three completely new appendices and a total of nine Appendices to the HI-STORM 100 CoC. Holtec did not think this appropriate for the HI-STORM 100 CoC as the numbering of the Appendices would be thrown off by the attrition of three more and the information can be easily fit into the reorganized Appendices A and C. While the pilot came up with one solution for where to locate the ASME code alternatives, Holtec is proposing a more appropriate location for the ASME code alternatives in the HI-STORM 100 CoC that does not conflict with the evaluation forms.

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