ML23324A094

Request for Additional Information

ML23324A094
Person / Time
Site:	Holtec
Issue date:	12/06/2023
From:	Storage and Transportation Licensing Branch
To:	Holtec
Shared Package
ML23324A093	List: ML23324A094 ML23324A095
References
CoC No. 1014, EPID L-2022-LLA-0028, CAC 001208
Download: ML23324A094 (7)

Text

Docket No. 72-1014 Holtec International HI-STORM 100 Multi-purpose Canister Storage System Certificate of Compliance No. 1014 Amendment No. 19 Request for Additional Information

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 U.S. Nuclear Regulatory Commission (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-1.b

a. Update the CoC description and consider providing additional details to the description of multi-purpose canisters (MPCs).

Since Amendment No. 19 of the HI-STORM 100 storage system is based on Amendment No. 16 of the HI-STORM 100 system, some of the changes in the CoC from Amendment No. 16 should be included in the reorganized CoC for Amendment No. 19 (e.g., revise the third sentence in the third paragraph in the description section of the CoC).

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 and explain the meaning of the extensions:

(T)he following five transfer casks are authorized to be used in HI-STORM 100 storage system: HI-TRAC 100, HI-TRAC 100D, HI-TRAC 125, HI-TRAC 125D, and HI-TRAC 100G.

b. Justify the deletion of the following statements in CoC condition 1.b:

1) The higher weight HI-TRAC transfer casks have thicker shielding and larger outer dimensions than the lighter HI TRAC transfer casks.

2) The HI-STORM 100S is a variation of the HI-STORM 100 overpack design.

Holtec indicated that these statements are overly prescriptive and unnecessary in the CoC. However, the staff considers these statements provide necessary information about the system and components related to the cask design as described below:

Enclosure

1) Consistent with the questions in part (a) above, the description on HI-TRAC transfer cask with thicker shielding and larger outer dimensions provides necessary information to understand the differences between different variants of HI-TRAC transfer casks.

2) The identification of HI-STORM 100S as a variant of the HI-STORM 100 overpack allows anyone to recognize what HI-STORM 100S is.

The staff needs the information for parts a and b above 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: CoC-16

Justify the deletion of Amendment No. 16 CoC condition 16, Amendments and Revisions for Renewed CoC. When retaining CoC condition 16, ensure the languages are the same as those in the renewed CoC.

Once a CoC is renewed, it is the new licensing/design bases for the renewed CoC. Any post-renewal amendments to the CoC would need to address any effects on the renewed design bases, including any aging management programs or activities in effect.

The guidance in NUREG-1927, Rev. 1, Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry Storage of Spent Nuclear Fuel (ML16179A148) explains how a future amendment request can appropriately consider the renewed design bases of the CoC, including any approved aging management programs and whether they encompass the new materials or structures, systems, and components introduced in the amendment.

A CoC may continue to be amended after it has been renewed. To clarify the need to evaluate the impacts to aging management activities, the staff has added condition 16 to all renewed CoC. This is to ensure that future amendments to a CoC address the renewed design bases for the CoC, including aging management impacts that may arise from the changes to the system in proposed future amendments.

The staff needs this information to determine compliance with 10 CFR 72.244 and to be consistent with the graded approach criteria for the CoC.

RAI-3 Forms: A-1.1 and C-1.1

Provide additional definitions in the technical specification (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 in Amendment No. 19, appendices B and D, to improve efficiency and clarity during operations:

• canister

• operable/operability

• spent nuclear fuel

2 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. 16 to appendix B, section 1 of Amendment No. 19. In example 1.2-2, there is no A.2 and A.2.2 in 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.

RAI-5 Forms: B-3.4(10) and D-3.4(11)

Provide information to support deletion of TS, appendix B (TS-B), section 3.4(10) and appendix D (TS-D), section 3.4(11) from the HI-STORM 100 Amendment No. 19.

The applicant proposed to delete TS-B section 3.4(10) and TS-D 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: (a) part of TS-B section 3.4(10) and TS-D section 3.4(11) is mentioned elsewhere in the CoC, limiting condition for operation (LCO) 3.1.1, specifically that the dry MPC will be helium filled; (b) the procedures in the updated final safety analysis report 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 (c) 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(10) and TS-D section 3.4(11) do 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(10), and TS-D section 3.4(11), i.e.,

fuel cladding is covered by water. TS-B section 3.4(10) and TS-D 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 criteria for CoC appendix B, section 3, Limiting Conditions for Operation (LOCs) and Surveillance Requirements.

3 RAI-6 Form: C-1.2

Revise appendix D, section 1.2, example 1.2-2 to provide clarity.

The applicant proposed to relocate appendix C, TS 1.2, Logical Connectors, of Amendment No. 16 to appendix D, section 1 of Amendment No. 19. In example 1.2-2, there is no A.2 and A.2.2 in 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.

RAI-7 Form: D-2.1

Revise the title for Amendment No. 19, section D, section 2.1.1 to correctly reflect the content of the section or provide information to justify the title.

Amendment No. 19, section D, section 2.1.1 is titled Fuel To Be Stored In MPC-32M.

However, section 2.1.1 contains information other than MPC-32M. It would be more appropriate to title this section as Fuel To Be Stored in HI-STORM 100 System. Revise the title or justify the title.

The staff needs this information to determine compliance with 10 CFR 72.244 and to be consistent with the graded approach criteria for CoC appendix B, section 2, Approved Contents.

RAI-8 Update the application per changes in Amendment No. 16

In Amendment No. 16, some changes are made as the result of RAIs. The applicant needs to update the evaluation form and associated CoC or TS sections. In the cases where new information is added to Amendment No. 16, the applicant needs to evaluate the new information and include the new information in Amendment No. 19. Below are some examples:

a. Update Amendment No. 19, appendix B, table 2.2-10 to be consistent with Amendment No. 16, appendix B, table 2.4-9.

b. Update Amendment No. 19, appendix A, table 3-1 to be consistent with Amendment No. 16, appendix B, Table 3-1.

c. Update Amendment No. 19, appendix B, SR 3.1.1.3 to be consistent with Amendment No. 16, appendix A, SR 3.1.1.3.

d. Update Amendment No. 19, appendix D, SR 3.1.1.3 to be consistent with Amendment No. 16, appendix C, SR 3.1.1.3.

e. Update Amendment No. 19, appendix D, table 2.1-4 to be consistent with Amendment No. 16, appendix D, table 2.1-4.

f. Update Amendment No. 19, appendix D, figure 2.1-1 to be consistent with Amendment No. 16, appendix D, figure 2.1-1.

g. Update Amendment No. 19, appendix C, table 3-1 to be consistent with Amendment No. 16, appendix D, table 3-1.

4 Editorial Changes

E-1 Form: CoC-10

The staff noted that the risk insights remain as N/A; however, the answer should be either yes or no.

The Evaluation Summary states that the pre-operational testing and training exercise should be moved to appendix B-100U; however, these requirements were relocated to appendix A-100U. Based on graded approach criteria, appendix A-100U would be the appropriate appendix for relocation, so this appears to be a typo in the Evaluation Summary section.

E-2 Form: D-3.4(3)

In Attachment 11, HI-STORM 100 Amendment 16 Certificate of Compliance, Appendix D Reorganization Evaluation Form (ML22028A383), there is a typo on page 49 of the file. The CoC Condition/TS Identifier should be D-3.4(3) instead of B-3.4(3).

E-3 Listing Style and Table of Content

The styles for listing are not consistent in the appendices. Most listings use the following levels:

First level 1 Second level 1.1 Third level 1.1.1 Forth level 1.1.1.1 fifth level a, b, c, d (letters)

However, they are not consistent. See an example in appendix B-100U, section 3.4. In addition, the first three levels normally are in the table of content; however, its also not consistent.

In general, tables and figures are listed in the table of content. However, not all tables and figures are listed. For example, the following are not in the table of content:

appendix A-100U, table 5-1; appendix B-100U, figures 2.1-1 through 2.1-4, tables 2.1-1 through 2.1-4, and tables 2.4-1 through 2.4-4.

E-4 Amendment Number

Update the amendment number (No. 19) on each page of all appendices.

E-5 Amendment No. 19, CoC

Amendment No. 19 is based on Amendment No. 16 which is issued after renewal.

Revise the CoC to include the renewal information and update the amendment number to 19.

5 E-6 Amendment No. 19, Appendix B

a. The labeling for table 2.1-1, section I.A.1.c.ii, Non-Fuel Hardware, should be I.A.1.c.iii.

b. Section 3.0, Surveillance Requirement (SR) Applicability, SR 3.0.3 has three paragraphs. The third paragraph appears to be separated. Put the three paragraphs together to provide clarity.

E-7 Amendment No. 19, Appendix D

a. In section 1.1, change damaged fuel assemblies in the definition for damaged fuel isolator (lines 5 and 6) to be all capitalized. With the first statement in the definition section that (T)he defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases, it is more appropriate to capitalize damaged fuel assemblies.

b. Delete the blank page on page 2-20.

c. Note 2 to table 3.3-8 is on the following page. It could cause confusion or be missed. Fit the complete table on one page if possible.

E-8 Amendment No. 19, Appendix A-100U

a. There are two 3.0 headings in appendix A-100U. It could cause confusion.

Renumber or combine them.

b. For consistency, change the labeling for SR 3.1.2 to SR 3.1.2.1.

c. For consistency and minimizing confusion, change LCO 3.1.3 condition from B to A.

d. In LCO 3.1.4, correct the first condition from C to A.

E-9 Amendment No. 19, Appendix B-100U

The labeling for table 2.1-1, section I.A.1.c.ii, Non-Fuel Hardware should be I.A.1.c.iii.

E-10 Amendment No. 19, Appendices A-100U, B, and D

In Amendment No. 19, appendix A-100U, section 5.9.1.a describes the dry run training exercise, and the last sentence states, (T)he dry run shall include, but is not limited to the following.

Consider making section 5.9.1.a a stand-alone paragraph under section 5.9.1 as it is not part of the required run dry activities. Then, renumber the list of required run dry activities starting from 5.9.1.a; i.e., the current section b becomes section a, section c becomes section b, and so on. This change is consistent with the previous format for this section in the CoC (Amendment No. 16, CoC condition 10).

6 This same format should also be applied to the same requirements in appendices B and D, section 4.8.

E-11 Amendment No. 19, Appendix A-100U

In Amendment No. 19, section 5.8 of appendix A-100U, the last sentence states, Lifting operations outside of structures governed by 10 CFR Part 50 must be in accordance with Section 4.2 and Sections 2.1.6 and 2.3 (if applicable) of Appendix A. There is no section 2.1.6 in the proposed appendix A. It seems the reference should be section 2.1.1.6 of appendix A.

In addition, the reference to section 4.2 in appendix A-100U is incorrect since there is no section 4.2 in appendix A-100U. It seems the appropriate reference in appendix A-100U should be section 5.5, Cask Transport Evaluation Program.

E-12 Amendment No. 19, Appendices B and D

In Amendment No. 19, section 4.7 of appendices B and D, the last sentence states, Lifting operations outside of structures governed by 10 CFR Part 50 must be in accordance with Section 4.2 and Sections 2.1.6 and 2.3 (if applicable) of Appendix A.

There is no section 2.1.6 in the proposed appendix A. It seems the reference should be section 2.1.1.6 of appendix A.

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