ML24159A040
| ML24159A040 | |
| Person / Time | |
|---|---|
| Site: | Holtec |
| Issue date: | 06/17/2024 |
| From: | Bernie White Storage and Transportation Licensing Branch |
| To: | Roman C Division of Fuel Management |
| References | |
| EPID L-2024-LRM-0051 | |
| Download: ML24159A040 (1) | |
Text
OFFICIAL USE ONLYPROPRIETARY INFORMATION OFFICIAL USE ONLYPROPRIETARY INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 MEMORANDUM TO:
Cinthya Román, Deputy Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards FROM:
Bernard White, Senior Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF APRIL 24, 2024, PRE-APPLICATION MEETING WITH HOLTEC INTERNATIONAL ON PROPOSED AMENDMENT 19 TO THE HI-STORM 100 STORAGE SYSTEM
Background
On January 30, 2024 (Agencywide Documents Access and Management System [ADAMS]
Accession No. ML24016A190), the U.S. Nuclear Regulatory Commission (NRC) issued Notice of Violation (NOV) EA-23-044 (ML24016A190). The NOV issued a Severity Level IV violation to Holtec for failing to obtain a certificate amendment for the HI-STORM 100 storage system prior to implementing proposed design changes to multi-purpose canister (MPC) continuous basket shims (CBS). This failure resulted in a departure from the method of evaluation (MOE) in the HI-STORM 100 final safety analysis report (FSAR) as described in Title 10 of the Code of Federal Regulations Section 72.48, Changes, tests, and experiments.
On April 24, 2024, a meeting was held, between the Holtec International (Holtec) and the NRC staff to discuss Holtecs proposed amendment to Certificate of Compliance No. 1014, for the Model No. HI-STORM 100 storage system. The meeting was noticed on April 10, 2024 (ML24101A165). The list of meeting attendees, including those participating via telephone, is provided as Enclosure 1. The non-proprietary presentation slides are Enclosure 2 and the proprietary meeting slides are as Enclosure 3.
Discussion In the open portion of the meeting, Holtec provided the NRC an overview of its proposed amendment to add a new MOE for the cask tipover evaluation as a corrective action for the violation.
CONTACT:
Bernard White, NMSS/DFM (301) 415-6577 transmitted herewith contains proprietary information. When separated from the sensitive conditions in Enclosure 3, this memorandum, and Enclosures 1, 2, and 4 are decontrolled.
June 17, 2024 Signed by White, Bernard on 06/17/24
OFFICIAL USE ONLYPROPRIETARY INFORMATION C. Román 2
OFFICIAL USE ONLYPROPRIETARY INFORMATION In its presentation, Holtec provided a summary of the Metamic-HT fuel baskets in the HI-STORM 100; discussed the current tipover methodology and proposed changes to the tipover methodology; and listed the proposed LS-DYNA tipover runs to be included in the proposed amendment.
Holtecs proposed Amendment No. 19 will revise the principal design criteria and the structural analysis chapters to include the revised MOE for the tipover calculations for the Metamic-HT baskets. The revised MOE will align the HI-STORM 100 MOE with Amendment No. 7 to Certificate of Compliance No.1032 for the Model No. HI-STORM flood and wind (FW) MPC Storage System (see Holtec documents dated February 16, 2024 [ML24047A323], and April 8, 2024 [ML24100A027]). As part of the amendment Holtec will be adding new stress-based acceptance criteria and using LS-DYNA to show compliance with the criteria.
Holtec requested an expedited review of the amendment so that it can be used by licensees that scheduled loading campaigns using one of the CBS baskets in the second half of calendar year 2025, rather than the licensees requesting exemptions. In discussing expediting the review, Holtec mentioned items that since this request is similar to that in HI-STORM FW Amendment No. 7, staff should have familiarity with it. Holtec also discussed the NRCs Office of Nuclear Reactor Regulations Risk Informed Process for Evaluation (RIPE) (ML21180A011) that can be used for approving items that are low safety significance. RIPE is designed to use each nuclear reactors probabilistic risk assessment, which does not exist for independent spent fuel storage installations. Holtec did point to the NRCs safety determination memo dated January 31, 2024 (ML24018A085) and stated that the NRC staff determined that the safety significance is low. Holtec asked whether the NRC staff could use the safety significance determination to expedite the technical review similar to use of the RIPE process. The NRC responding by discussing the Risk Tool (ML22353A565) that NRC staff is piloting.
In using the risk tool, the NRC determines the safety significance of individual proposed changes to guide the depth of the NRC review. Items that score a low risk using the Risk Tool, would ideally require a lower amount of review and possibly, no confirmatory analyses. Holtec stated that the Risk Tool might be an option to leverage existing work to develop a RIPE-like process that can be used in storage and transportation package reviews, however that should be a future endeavor and not slow down NRC review of Amendment No. 19.
Holtec stated that it will provide NRC the application for Amendment No. 19 to the HI-STORM 100 storage system by the end of June and will strive to provide it sooner. Holtec also stated that the application will be a focused amendment and the only change will be the revised MOE.
Holtec requested that amendment no. 19 be effective by the end of May 2025. Prior to the meeting, the NRC shared that it developed a draft schedule which allows a 2 month technical review, which will be very tight; one request for additional information with a 2 week turnaround time for Holtec to respond to the request for additional information; allowing NRC to issue a draft certificate (and its associated technical specifications) and safety evaluation report to start the rulemaking process the first week in December. However, the NRC noted that this schedule presumes a very high quality application that can be reviewed expeditiously. The NRC will provide Holtec the schedule for review after receipt of the application.
In the closed portion of the meeting, Holtec discussed which HI-STORM 100 MPCs have Metamic-HT baskets and which overpacks are authorized to store these MPCs. Holtec stated that the non-mechanistic tipover accident is only applicable to the following HI-STORM 100 overpacks: the 100, and the 100 Version S, Version B, Version E/E1, and Version UVH, since these are aboveground, freestanding storage casks.
OFFICIAL USE ONLYPROPRIETARY INFORMATION C. Román 3
OFFICIAL USE ONLYPROPRIETARY INFORMATION Holtec discussed the differences between the tipover analyses for the MPC-32M and the MPC-68M and the current approach used to evaluate the tipover analysis. Holtec briefly discussed the tipover analyses that it submitted for Amendment No. 7 for the HI-STORM FW storage cask, and the analyses it proposes submitting for Amendment No. 19 to the HI-STORM 100, which includes analyses that is not currently in the FSAR.
The NRC staff noted that there are a few differences between the FW Amendment No. 7 and the proposed 100 Amendment No. 19, and inquired about the following items:
a.
{Proprietary information removed).
b.
Whether the Alloy X material fuel baskets would be evaluated using the new enhanced model MOE and the new basket acceptance criteria of permanent deflection and stress limits; Holtec responded that no reanalysis was necessary, as the Alloy X basket analyses were compared to the American Society of Mechanical Engineers Boiler and Pressure Vessel Codes stress-based criteria only.
c.
{Proprietary information removed).
d.
Whether a tabulation of compatible baskets, overpacks, and transfer casks, as was included in FW Amendment No. 7, would be included in the HI-STORM 100 Amendment No. 19; Holtec responded that this would be included as part of this new amendment.
e.
Whether an explanation of active fuel region, as was included in FW Amendment No. 7, would be included in the HI-STORM 100 amendment no. 19; Holtec responded that this would be included as part of this new amendment.
Docket No. 72-1014 EPID No. L-2024-LRM-0051
Enclosures:
1.
Meeting Attendees 2.
Non-Proprietary Meeting Slides 3.
Proprietary Meeting Slides 4.
OFFICIAL USE ONLYPROPRIETARY INFORMATION C. Román 4
OFFICIAL USE ONLYPROPRIETARY INFORMATION
SUBJECT:
SUMMARY
OF APRIL 24, 2024, PRE-APPLICATION MEETING WITH HOLTEC INTERNATIONAL ON PROPOSED AMENDMENT 19 TO THE HI-STORM 100 STORAGE SYSTEM DOCUMENT DATE:
DISTRIBUTION:
NRC Meeting Attendees ADAMS Accession No.: ML24157A048(pkg), ML24157A049 (memo, non-public),
ML24159A040 (memo, public), ML24159A037 (encl 1), ML24157A052(encl 2),
ML24157A051(encl 3, non-public), ML24157A050(encl 4)
OFFICE NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NAME BWhite SFigueroa JSmith TBoyce YDiaz-Sanabria BWhite DATE 6/7/2024 6/7/2024 6/7/2024 6/7/2024 6/10/2024 6/17/2024 June 17, 2024