ML24157A052

Enclosure 2: HI-STORM 100 Amendment 19 Pre-submittal Presentation to the U.S. Nuclear Regulatory Commission - Public Slides

ML24157A052
Person / Time
Site:	Holtec
Issue date:	06/17/2024
From:	Holtec
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML24157A048	List: ML24157A050 ML24157A052
References
EPID L-2024-LRM-0051
Download: ML24157A052 (1)

Text

www.holtecinter national.com

HI-STORM 100 Amendment 19

Pre-Application Presentation to NRC

April 2024 Presentation Agenda Summary of Amendment Request Discussion of Expedited Amendment Questions

l Pa ge 2 Pa ge 2-Holtec Inf ormation Summar y of Amendment Request HI-STORM 100 Amendment 19 request will be a small f ocused amendment relating to the tipover methodology f or Metamic-HT baskets Amendment request is a corrective action from the inspection action related to the CBS baskets HI-STORM FW Amendment 7 provides the road map f or this amendment

l Pa ge 3 Summar y of Amendment Request The amendment request will update Chapters 2 and 3 of the SAR to include a revised methodology f or the tipover calculations f or Metamic-HT baskets (MPC -68M and MPC -

32M, all var iants)

A new acceptance criteria based on stress will be added LS-DYNA models will be used to show compliance with this new cr iter ia

l Pa ge 4 Summar y of Amendment Request Stress criteria based on 90% of ultimate stress Details of LS-DYNA model and combinations of canisters and over packs to be discussed in propr ietar y session No change to any other analyses, very narrow f ocus on non-mechanistic tipover

l Pa ge 5 Expedited Amendment

This amendment request is needed due to the enforcement action related to the CBS var iant baskets Sites are interested in loading these baskets and cannot without licensing action Exemption requests are on-going f or near term users Efficient approval of this amendment will prevent additional exemption requests Using the same methodology as HI-STORM FW Amd 7 that is hopefully in the f inal steps of NRC approval Want to figure out the best process to move forward ef f iciently consider ing the saf ety signif icance to resolve the compliance issue Focus is on quickly resolving this issue, but could inform a future process f or resolving non-saf ety signif icant compliance issues

l Pa ge 6 Expedited Amendment

Office of Nuclear Reactor Regulation (NRR) has a process called Risk-Inf ormed Process f or Evaluations RIPE to address low saf ety signif icance issues Reviewed presentations and NRC memo on that process May be difficult to apply directly to Part 72 scenario, relies heavily on PRA results PRA evaluated prior to submittal to demonstrate that it is in f act a ver y low saf ety signif icance issue Part 72 does not have individualized cask design PRAs

l Pa ge 7 Expedited Amendment

Part 72 doesnt have PRA in the same way as Part 50 However, we have a memorandum from NRC staff concluding, the consequences of a basket f ailure have a ver y low saf ety signif icance provided the conf inement boundar y is maintained.

The revised tipover analyses do not make any changes related to the conf inement boundar y Is there a way to use this safety conclusion approved by NRC staf f to expedite the technical review process similar to RIPE?

l Pa ge 8 Expedited Amendment Holtec understands that NRC has been implementing a r isk tool on new applications The use of that tool is slightly unclear to applicants, but can that be used to expedite review time of a ver y low saf ety signif icant change?

Can Holtec help by including evaluation of the application against that r isk tool at submittal?

applicant does the wThis would somewhat echo the RIPE process where the ork up front to demonstrate low saf ety signif icance implemented r isk tool to dateWould need some clearer examples of how NRC staff has

Risk tool might be an option to leverage existing work and not create a new process from scratch

l Pa ge 9 Schedule

Holtec is committed to submitting this application by the end of June Given the high interest levels and need for the approved amendment to avoid future exemption requests, requested schedule is fully ef f ective by May 2025 This would mean a completed technical review by approximately December 2024

l Pa ge 10 Questions and Discussion

l Pa ge 11Pa ge 9-Holtec Inf ormation