ML23229A516

Enclosure - FW A9 Request for Additional Information

ML23229A516
Person / Time
Site:	07201032
Issue date:	10/04/2023
From:	Storage and Transportation Licensing Branch
To:	Holtec
Shared Package
ML23229A515	List: ML23229A516 ML23229A517
References
EPID L-2022-LLA-0027, CAC 001028
Download: ML23229A516 (4)

Text

Enclosure Request for Additional Information Docket No. 72-1032 Holtec International HI-STORM Flood/Wind Multi-purpose Canister Storage System Certificate of Compliance No. 1032 Amendment No. 9 The graded approach was developed to improve the spent fuel dry storage licensing process by applying risk insights to clarify the information required in the certificate of compliance (CoC) and removing or relocating details that are not risk significant to safety, thereby providing additional flexibility for licensees. The NRC endorsed the graded approach on January 8, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19353D337). Applicants requesting an amendment using the graded approach must demonstrate that there are no technical changes being requested as part of the transition to the new CoC format and content. The staff used the graded approach criteria in the endorsement letter for this review.

RAI-1 Form: CoC-Des Update the certificate of compliance (CoC) description and consider providing additional details to the description of multi-purpose canisters (MPCs).

Since Amendment No. 9 of the HI-STORM FW storage system is based on Amendment No. 7 of the HI-STORM FW, some of the changes in the CoC from Amendment No. 7 should be included in the reorganized CoC for Amendment No. 9 (e.g., revise the third sentence in the third paragraph in the description section of the CoC). Also, the new continuous basket shim (CBS) version of MPCs should be included in the CoC since it is a relevant component of the cask design.

In addition, the CoC should provide sufficient information on the system and components related to the cask design. The CoC should clearly identify the authorized canisters, storage overpack, and transfer cask. For example, consider adding the following statement:

(T)he following three transfer casks are authorized to be used in HI-STORM FW storage system: HI-TRAC VW, HI-TRAC VW Version V, and HI-TRAC VW Version V2.

The staff needs this information to determine compliance with Title 10 of the Code of Federal Regulations (10 CFR) 72.236(a) and 72.244 and to be consistent with the graded approach criteria for the CoC, section I, Technology.

RAI-2 Form: A-1.1 Justify the definition change for BLEU fuel in the technical specification (TS) between Amendments No. 7 and 9.

2 In Amendment No. 7, BLEU FUEL is defined as Blended Low Enriched Uranium (BLEU) fuel material are essentially identical to UO2 fuel except for the presence of small amount of impurities. In Amendment No. 9, BLEU FUEL is defined as Blended Low Enriched Uranium (BLEU) fuel is the same as a commercial spent fuel but with a higher cobalt impurity.

Clarify what is considered higher cobalt impurity in the definition and provide justification for the change. It is important to have clear definition in the TS for the users to implement the CoC. In addition, the applicant should provide sufficient information on the assumptions related to the cask design. This change seems to be a technical change, which is outside of the scope of the graded approach.

The staff needs this information to determine compliance with 10 CFR 72.236(a) and 72.244.

RAI-3 Form: A-1.1 Provide additional definitions in the TS definition section.

To be consistent with NUREG-1745 (ML011940387), Standard Format and Content for Technical Specifications for 10 CFR Part 72 Cask Certificates of Compliance, add the following definitions to improve efficiency and clarity during operations:

1.

canister 2.

intact fuel assembly 3.

operable/operability 4.

spent nuclear fuel The staff needs this information to determine compliance with 10 CFR 72.11(a) and 72.244 and to be consistent with the graded approach criteria for CoC appendix B, section 1, Definition, Use and Application.

RAI-4 Form: A-1.2 Revise appendix B, section 1.2, example 1.2-2 to provide clarity.

The applicant proposed to relocate appendix A, TS 1.2, Logical Connectors, of Amendment No. 7 to appendix B, section 1 of Amendment No. 9. The applicant made some minor changes to the text of this section for clarity. In example 1.2-2, the applicant removed A.2 and A.2.2 from ACTIONS; however, the explanation mentions A.2 and A.2.2. This could cause confusions. Either add A.2 and A.2.2 in the ACTIONS or revise the explanation.

The staff needs this information to determine compliance with 10 CFR 72.11(a) and 72.244 and to be consistent with the graded approach criteria for CoC appendix B, section 1, Definition, Use and Application.

3 RAI-5 Form: B-2.5 In Amendment No. 7, subsections 2.5.3 and 2.5.4 were added to appendix B as the result of an RAI.

The applicant needs to evaluate and include these two subsections in Amendment No.

9, since this amendment is based on Amendment No. 7.

The staff needs this information to determine compliance with 10 CFR 72.11 and 72.244.

RAI-6 No Form: Appendix B Tables 2.5-4 through 2.5-6 in Amendment No. 7 In Amendment No. 7, tables 2.5-4 through 2.5-6 were added to appendix B as the result of an RAI.

The applicant needs to evaluate and include these tables in Amendment No. 9, since this amendment is based on Amendment No. 7.

The staff needs this information to determine compliance with 10 CFR 72.11 and 72.244.

RAI-7 Form: B-3.4(11)

Provide information to support deletion of the TS in CoC appendix B (TS-B), section 3.4(11) of HI-STORM FW, Amendment No. 7 from the HI-STORM FW Amendment No.

9.

The applicant proposed to delete TS-B section 3.4(11) that states the following:

Users shall establish procedural and/or mechanical barriers to ensure that during LOADING OPERATIONS and UNLOADING OPERATIONS, either the fuel cladding is covered by water, or the MPC is filled with an inert gas.

The applicant states that: (1) part of TS-B section 3.4(11) is mentioned elsewhere in the TS appendix A, limiting condition for operation (LCO) 3.1.1, specifically that the dry multi-purpose canister (MPC) will be helium filled, (2) the procedures in the updated final safety analysis report (UFSAR) already contain cautions that the inert gas must be used any time the fuel is not covered with water to prevent oxidation of the fuel cladding and the fuel cladding is not to be exposed to air at any time during loading operations, and (3) this caution applies to all sites and 10 CFR 72.150 requires that documented procedures be followed. Therefore, the applicant concludes that TS-B section 3.4(11) does not serve any safety purpose in the CoC and may be removed.

The staff notes that the current LCO 3.1.1 and the caution statements do not fully address the functions described in TS-B section 3.4(11), i.e., fuel cladding is covered by water. TS-B section 3.4(11) should be retained or LCO 3.1.1 should be modified to address fuel cladding covered by water.

The staff needs this information to determine compliance with 10 CFR 72.236(f) and to be consistent with the graded approach section 3, "Limiting Conditions for Operation (LCOs) and Surveillance Requirements, criterion L2.

4 Editorial Changes E-1 Amendment No. 9, Appendix B, Section 1.3.

In appendix B, section 1.3, Completion Times, of Amendment No. 9, under DESCRIPTION, the last sentence of the first paragraph states or the HI-STORM 100 System is not within the LCO Applicability. The HI-STORM 100 System should be change to HI-STORM FW System.

E-2 Amendment No. 9, Appendix B, Table 2.1-1 In Amendment No. 9, appendix B, table 2.1-1, page 8 of 10, the section for MPC-37P is labeled as 2.1-1(III). It should be corrected to section 2.1-1(IV).

E-3 Amendment No. 9, Appendix B, Table 3-2, MPC Helium Backfill Limits.

In Amendment No. 9, appendix B, the table for MPC Helium Backfill Limits is labeled as table 3.3-1. It should be corrected to table 3.3-2.

E-4 Amendment No. 9, Appendix A, Section 1.2.2.

The applicant proposed to relocate appendix B section 3.2, Design Features Important for Criticality Control, of Amendment No. 7 to appendix A, section 1.2.2 of Amendment No. 9. The title of appendix A, section 1.2.2 of Amendment No. 9 should be corrected to Design Features Important for Criticality Control."