ML23321A247

Attachment 1: Holtec International - Summary of Additional Clarifications/Changes Submitted for Review

ML23321A247
Person / Time
Site:	07201032
Issue date:	11/17/2023
From:	Holtec
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML23321A245	List: ML23321A246 ML23321A247 ML23321A249 ML23321A254
References
5018111, EPID L-2021-LLA-0053, CAC 001028
Download: ML23321A247 (1)

Text

Summary of Additional Clarifications/Changes Submitted for Review Page 1 of 2 Between March 29, 2023 and October 4, 2023, the NRC and Holtec discussed clarification requests regarding Holtecs responses to RAI Batch 5 on HI-STORM FW Amendment 7 during several clarification calls [1-4]. Holtec provided clarifications to the NRC as the result of these calls [6-9]. On the September 9 call [4], Holtec and the NRC discussed further clarifications and the meeting minutes described additional actions Holtec would take and information Holtec would submit. The conversation record for a subsequent virtual audit on October 4, 2023 [5] provided further description of the additional work Holtec planned to complete. This additional work included two items: 1) Adopting a stress-based structural design criteria (option 2 in the [4]

meeting minutes) and 2) Establishing specific criteria on allowable interference due to Differential Thermal Expansion (DTE).

Adopting a Stress-Based Structural Design Criteria (Option 2 in the [4] conversation record)

Holtec proposes FSAR changes to add stress-based design criteria in FSAR Chapter 2 alongside the permanent deflection design criteria that already existed in the FSAR. This stress-based criteria are similar to ASME service level D as noted in [4]. The relevant structural evaluations for all MPCs allowed to be loaded under HI-STORM FW Amendment 7 have been updated to ensure compliance with this stress-based design criteria and these structural evaluation calculation packages are contained in Attachments to this submittal.

Applicable Sections/Tables/Figures in the FSAR have been added or updated to incorporate the stress-based criteria and show MPC compliance:

• Sections 2.2.8, 3.4.4.1.4 (items a through d), and 3.I.3.8.

• Tables 3.4.19, 3.4.20, 3.4.21, and 3.I.3.12.

Establishing an Allowable Interference Due to DTE (Item 4 in the [5] conversation record)

Holtec establishes specific criteria for allowable interference values related to DTE in proposed new FSAR Table 3.1.15. The table shows that no axial interference is permitted. The radial value is set to a low value to ensure that no significant distortion occurs. These values will apply to all MPCs licensed for use in the FW System.

FSAR item 3.4.4.a.i and Table 4.4.6 are also updated to support the new allowable interference values.

Holtec Letter 5018111 Attachment 1

Summary of Additional Clarifications/Changes Submitted for Review Page 2 of 2

References:

[1] Clarification Call with Holtec on HI-STORM FW RAI Batch 5 Conversation Record between Holtec and NRC associates dated March 29, 2023. ADAMS Accession No. ML23100A091.

[2] Clarification Call with Holtec on HI-STORM FW Amendment 7 Request for Additional Information (RAI) Batch 5 Response Conversation Record between Holtec and NRC associates dated June 15, 2023. ADAMS Accession No. ML23177A278.

[3] Clarification Call with Holtec on HI-STORM FW Amendment 7 Request for Additional Information (RAI) 3-10 Conversation Record between Holtec and NRC associates dated August 3, 2023. ADAMS Accession No. ML23216A217.

[4] Clarification Questions for HI-STORM Flood/Wind (FW) Storage System Amendment 7 Conversation Record between Holtec and NRC associates dated September 9, 2023.

ADAMS Accession No. ML23303A120.

[5] Clarification Call Regarding Holtecs Planned Responses for HI-STORM FW Amd 7 Conversation Record between Holtec and NRC associates dated October 4, 2023. ADAMS Accession No. ML23278A227.

[6] HI-STORM FW Amendment 7 Responses to Requests for Additional Information Part 5, letter from D. Elisio (Holtec) to Y. Chen (NRC) dated May 8, 2023. ADAMS Accession No. ML23128A302.

[7] HI-STORM FW Amendment 7 RAI Responses Part 5 Clarification Call Action Items, letter from D. Elisio (Holtec) to Y. Chen (NRC) dated June 30, 2023. ADAMS Accession No. ML23181A193.

[8] HI-STORM FW Amendment 7 RAI Responses Part 5 Clarification Corrected Attachments 4 and 5, letter from D. Elisio (Holtec) to Y. Chen (NRC) dated July 10, 2023.

ADAMS Accession No. ML23192A032.

[9] HI-STORM FW Amendment 7 RAI 3-10 response Clarification Call Action Items, letter from D. Elisio (Holtec) to Y. Chen (NRC) dated August 15, 2023. ADAMS Accession No. ML23227A248.

Holtec Letter 5018111 Attachment 1