ML23317A123

Application for Revision to Amendment Nos. 0, 1, and 2 of the Certificate of Compliance No. 1040 for the HI-STORM Umax Canister Storage System - Supplemental Information Needed

ML23317A123
Person / Time
Site:	HI-STORM 100
Issue date:	12/18/2023
From:	Kristina Banovac Storage and Transportation Licensing Branch
To:	Manzione K Holtec
References
EPID L-2023-LLA-0070, CAC 001028
Download: ML23317A123 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Kimberly Manzione, Director of Licensing - NMSS Projects Holtec International Krishna P. Singh Technology Campus One Holtec Boulevard Camden, NJ 08104

SUBJECT:

APPLICATION FOR REVISION TO AMENDMENT NOS. 0, 1, AND 2 OF THE CERTIFICATE OF COMPLIANCE NO. 1040 FOR THE HI-STORM UMAX CANISTER STORAGE SYSTEM - SUPPLEMENTAL INFORMATION NEEDED -

ENTERPRISE PROJECT IDENTIFICATION NUMBER L-2023-LLA-0070

Dear Kimberly Manzione:

By letter dated May 5, 2023 (Agencywide Documents Access and Management System

[ADAMS] Accession No. ML23125A237), you submitted an application for Revision to Amendment Nos. 0, 1, and 2 of the Certificate of Compliance (CoC) No. 1040 for the HI-STORM UMAX Canister Storage System. You requested to update the CoC appendix A technical specifications for radiation protection and the associated bases information to clearly articulate the basis for the dose rate limits for the closure lids and modify the description of the location of the dose rate measurements for clarification for the users.

The U.S. Nuclear Regulatory Commission (NRC) staff performed an acceptance review of your application to determine if the application contains sufficient technical information in scope and depth to allow the staff to complete the detailed technical review. This letter is to inform you that, based on our acceptance review, the application does not contain sufficient technical information. The information needed to continue our review is described in the enclosed request for supplemental information (RSI). The enclosure also includes an observation on information that the NRC staff could potentially request later as a request for additional information (RAI) during the detailed technical review. The observation does not require a response for the NRC staff to begin its detailed technical review of the application. However, you may respond to the observation in your response to the RSI, if you so desire, before the NRC staff formally makes any RAI.

In order to schedule our technical review, this information should be provided by January 31, 2024. This letter confirms our e-mail exchange on December 14, 2023, with respect to the supplemental information needed and the date for your submittal.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. The PDR is open by appointment.

To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.gov or December 18, 2023

K. Manzione 2

call 1-800-397-4209 or 301-415-4737, between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except Federal holidays.

If you have any questions regarding this communication, please contact me at (301) 415-7116, or via email to Kristina.Banovac@nrc.gov.

Sincerely, Kristina L. Banovac, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-1040 EPID No.: L-2023-LLA-0070

Enclosure:

Request for Supplemental Information and Observation Signed by Banovac, Kristina on 12/18/23

ML23317A123 OFFICE NMSS/DFM/STLB NMSS/DFM/NARAB NMSS/DFM/IOB NMSS/DFM/STLB NAME KBanovac MCall MDavis WWheatley DATE 11/13/2023 11/14/2023 11/20/2023 11/21/2023 OFFICE NMSS/DFM/NARAB NMSS/DFM/IOB NMSS/DFM/STLB NMSS/DFM/STLB NAME DJohnson ARivera-Varona YDiaz-Sanabria KBanovac DATE 11/27/2023 12/5/2023 12/18/2023 12/18/2023

Enclosure Request for Supplemental Information and Observation Holtec International Docket No. 72-1040 Revision to Amendment Nos. 0, 1, and 2 of Certificate of Compliance No. 1040 By letter dated May 5, 2023 (Agencywide Documents Access and Management System

[ADAMS] Accession Number ML23125A237), Holtec International (Holtec, applicant) submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for Revision to Amendment Nos. 0, 1, and 2 of the Certificate of Compliance (CoC) No. 1040 for the HI-STORM UMAX Canister Storage System. The application requests an update of the CoC appendix A Technical Specifications (TS) for radiation protection and the associated bases information to clearly articulate the basis for the dose rate limits for the closure lids and modify the description of the location of the dose rate measurements for clarification for the users.

This request for supplemental information (RSI) identifies information needed by the NRC staff to begin a detailed technical review of the application. Also provided is an observation on information that the NRC staff could potentially request later as a request for additional information (RAI) during the detailed technical review. The observation does not require a response for the NRC staff to begin its detailed technical review of the application. However, the applicant may respond to the observation before the NRC staff formally makes any RAI.

RSI.

Provide supplemental information that clarifies the scope of the application.

The May 5, 2023, application for Revision to HI-STORM UMAX CoC No. 1040, Amendments 0, 1, and 2 consists of a cover letter, a summary of proposed changes, CoC page changes for the proposed Revision 1 to Amendment Nos. 0, 1, and 2, and corresponding final safety analysis report (FSAR) page changes for proposed FSAR Revisions 2.1, 3.1, and 4.1 that are associated with each CoC amendment.

The May 5, 2023, cover letter states that, Other HI-STORM UMAX users have already chosen to upgrade their casks to Amendment 4, which already includes these changes. The summary of proposed changes in the application notes that the reason for the requested revisions is outlined in referenced Holtec letters, which discuss Amendment No. 4. The September 28, 2023, email from Holtec (see ML23292A347) notes that the intent of the application was to match what was previously approved in Amendment No. 4. Additionally, the proposed CoC page changes in the application match those approved in Amendment No. 4, which reflect measured dose rate limits of 66 millirem (mrem)/ hour (hr) for the Standard Lid and 22 mrem/hr for the Version B Lid (see January 4, 2021, issuance of CoC No. 1040, Amendment No. 4,, at ML20349A209). Therefore, it appears that the intended scope of the application for Revisions to UMAX Amendment Nos. 0, 1, and 2 is intended to match the previous change that was made in Amendment No. 4.

However, the proposed FSAR page changes in the application do not reflect those in Amendment No. 4. Holtec submitted the final FSAR page changes for Amendment No. 4 in the March 30, 2020, Holtec submittal 5021060, Attachment 4 (see ML20104C018), which includes FSAR table 5.4.7 design basis dose rate limits of 66 mrem/hr for the Standard Lid and 22 mrem/hr for the Version B Lid. Additionally, the April 13, 2020, Holtec response to a clarification RAI on Amendment No. 4 notes, The dose limits in 5.3.4.a of the CoC Appendix A are revised to be 66 mrem/hr for the standard lid and 22 mrem/hr for the Version B lid. These are the same

2 calculated dose rate values reported in the SAR table 5.4.7 and supporting calculation packages (see ML20111A239). Instead, the application includes design basis dose rate limits in table 5.4.7 of the FSAR page changes, of 180 mrem/hr for the Standard Lid and 60 mrem/hr for the Version B Lid. In response to an NRC staff query on whether the FSAR page changes in the application were correct and intentional as they did not match the CoC page changes in the application, Holtec responded (see ML23292A347) that the CoC and FSAR page changes in the application were intentional to match what was previously approved in Amendment No. 4.

Therefore, it is not clear what is the intended scope of the application. Clarify if the intended scope of the application is to: (a) reflect the changes approved in Amendment No. 4 regarding dose rate limits of 66 mrem/hr for the Standard Lid and 22 mrem/hr for the Version B Lid; or (b) revise dose rate limits to 180 mrem/hr for the Standard Lid and 60 mrem/hr for the Version B Lid.

If (a), submit revised FSAR page changes that reflect Amendment No. 4.

If (b), provide a description of the changes that result in higher FSAR dose rate limits and their measurement locations and the supporting calculation files.

The NRC staff needs this information to begin a detailed review of the application for Revisions to UMAX Amendment Nos. 0, 1, and 2 to determine if it meets the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 72.

Observation.

Justify the proposed TS condition that excepts general licensees from taking additional dose rate measurements to comply with the proposed Revision 1 measurement requirements, if the general licensees took the required dose rate measurements on vertical ventilated modules (VVMs) loaded to Revision 0. Alternatively, remove this proposed TS condition language.

The summary of proposed changes in the application notes:

Note that this change does not modify the requirement under Sections 5.3.2 and 5.3.3

[in CoC Appendix A TS] for the licensee to calculate a site specific surface dose rate limit based on site condition, ISFSI configuration, number of casks, and contents to confirm compliance with 10 CFR 72.104. As stated in Section 5.3.5 [in CoC Appendix A TS], the lower of these limits shall be used to compare with measured values. The revised measurement location ensures that the appropriate location of dose rates is measured. However, it is important to note that as long as the locations for measured and site-specific calculated values are the same, a successful comparison provides reasonable assurance that 10 CFR 72.104 is met.

It is important to recall that the proposed revisions to the TS were found to be necessary not only because of questions about the measurement location. They were also necessary because the dose rate limit value for the VVM lid was non-conservative and not based on the FSAR analyses for demonstrating sufficient shielding to meet 10 CFR 72.104. The FSAR analyses indicated that the TS-identified measurement location on the VVM lid had a significantly smaller dose rate in the FSAR analyses for meeting § 72.104 than the TS limit. Plus, in application of the Revision 0 measurement location description to a new lid design (Version B lid), the identified location for that lid was clearly not an appropriate location for a dose rate that would give any indications regarding the purposes of the measurement limit and location. Further, the NRC staff noted that the general licensees use the TS dose rates to inform their emergency action levels for emergency response following an event. Thus, the appropriateness of the proposed TS condition language is unclear and not adequately justified.

3 With the proposed TS condition language, the applicant is attempting to justify for the general licensees that have loaded UMAX systems under Revision 0 of the CoC that actions taken to comply with Revision 0 are adequate to comply with Revision 1 (minus this proposed condition language). This is something that general licensees are required to do as described in 10 CFR 72.212. For the applicant to be able to adequately justify the proposed condition language, it would need to provide information similar to what the general licensee would include in its

§ 72.212 evaluation report. This information would include evaluations of how the previously performed measurements compare versus the new limit values and locations, including in demonstrating the objectives of the limit are met (e.g., confirm proper system loading and that

§ 72.104 limits will be met). For example, the applicant could provide information that demonstrates that dose rate measurements performed on VVMs loaded to Revision 0 are bounded by the proposed dose rate limits in the application, in terms of dose rate measurements and locations of the measurements. Additionally, the applicant could provide information to demonstrate that the general licensee that previously took dose rate measurements on VVMs loaded to Revision 0 meets the dose limits of § 72.104 and the performed measurements support demonstration of that compliance.

Alternatively, the applicant should remove the proposed TS condition from the application. In this case, the general licensee who previously loaded to Revision 0 would need to implement Revision 1 after it is issued. The general licensee would need to perform an evaluation per

§ 72.212 to determine what is needed to implement the revised CoC, and to establish that the casks conform to the terms, conditions, and specifications of the revised CoC and that the requirements of § 72.104 are met.

This information is required to demonstrate compliance with 10 CFR 72.236(d) and § 72.104.