ML24296A020

E-mail HI-STAR 180 Amd 5

ML24296A020
Person / Time
Site:	07109325
Issue date:	02/16/2023
From:	Pierre Saverot Storage and Transportation Licensing Branch
To:	Manzione K, O'Mullane C Holtec
References
Download: ML24296A020 (1)

Text

From:

Pierre Saverot To:

Kimberly Manzione; Christopher O"Mullane

Subject:

HI-STAR 180 Amd 5...what I am writing....no second thoughts that could be misinterpreted, just facts and asking you to support a complete review Date:

Thursday, February 16, 2023 10:59:00 AM This letter is to advise you that the sta has identi"ed major de"ciencies in your application package; it does not contain the scope and depth of technical information to support the proposed changes that would allow the sta to begin a review. As an example, sta did not "nd:

(1)

Hypothetical Accident Condition (HAC) Puncture evaluation for the Optional MonolithicShield Cylinder (MSC),

(2)

HAC Free Drop evaluation for the Continuous Basket Support (CBS) shim variant inconjunction with the Optional MSC, (3)

Normal Conditions of Transport (NCT) Free Drop evaluation for the CBS shim variant inconjunction with the Optional MSC, (4)

Evaluations considering a decreased thickness of CBS shim variant as well as alternatematerials, (5)

Evaluations considering Optional MSC alternate materials, (6)

Complete drawings of the F-32CBS and F-37CBS baskets, drawings No. 12951 and 12955,respectively. Examples of missing information include basket part details and quantities, bolt quantities, and exact bolt locations.

Sta believes it is in the best interest of Holtec to withdraw this application to ensure that, when resubmitted, it will include all analyses and references necessary to support the regulatory "ndings the sta has to make.

From: Kimberly Manzione <K.Manzione@holtec.com>

Sent: Wednesday, February 15, 2023 3:29 PM To: Pierre Saverot <Pierre.Saverot@nrc.gov>; Christopher O'Mullane <C.OMullane@holtec.com>

Subject:

[External_Sender] RE: RE: RE: RE: Re: HI-STAR 180 Amd 5

Pierre, Thank you! We are on the same page here, I think that will work for everyone, much appreciated!

Thanks, Kim From: Pierre Saverot <Pierre.Saverot@nrc.gov>

Sent: Wednesday, February 15, 2023 3:28 PM To: Kimberly Manzione <K.Manzione@holtec.com>; Christopher O'Mullane

<C.OMullane@holtec.com>

Subject:

RE: RE: RE: RE: Re: HI-STAR 180 Amd 5

CAUTION: This email came from a source OUTSIDE of Holtec!!

Do not click any links or open any attachments unless you trust the sender and know the contents to be safe.

Clicking links or opening attachments could lead to infecting your computer or Holtecs servers with malicious viruses.

Kim, I will NOT use the word rejection or any similar wording because it has an awful connotation and your competitors can or could enjoy or gloat about it. It will not happen.

I will use the words Sta believes it is in the best interest of Holtec to withdraw this application, complete it (see non exhaustive list attached), and resubmit it for stas detailed review.

You will respond that you are withdrawing your application, make sure it has all the analyses needed for stas review, and resubmit it by March 31 (March 15? April 10?)

Thanks Pierre From: Kimberly Manzione <K.Manzione@holtec.com>

Sent: Wednesday, February 15, 2023 3:21 PM To: Christopher O'Mullane <C.OMullane@holtec.com>

Cc: Pierre Saverot <Pierre.Saverot@nrc.gov>

Subject:

[External_Sender] RE: RE: RE: Re: HI-STAR 180 Amd 5

Pierre, I just want to double check, I think the language we would be sensitive to in a letter from you would be anything that uses the term rejection, or similar, so if we need to pre-emptively issue a letter withdrawing to avoid that language, we would be happy to do so.

If your letter is more a statement of what additional information you need, and we can just respond withdrawing until a time when we include that information, then the order you describe makes sense.

Thanks, Kim From: Pierre Saverot <Pierre.Saverot@nrc.gov>

Sent: Wednesday, February 15, 2023 2:50 PM To: Christopher O'Mullane <C.OMullane@holtec.com>

Subject:

RE: RE: RE: Re: HI-STAR 180 Amd 5 CAUTION: This email came from a source OUTSIDE of Holtec!!

Do not click any links or open any attachments unless you trust the sender and know the contents to be safe.

Clicking links or opening attachments could lead to infecting your computer or Holtecs servers with malicious viruses.

Chris, This is the best (and most reasonable) course of action. Drafting a letter in that sense to preserve Holtec status as a premier engineering company but you need to ensure your applications are complete!!

My letter should be out Friday and you will reference it in yours..

Pierre From: Christopher O'Mullane <C.OMullane@holtec.com>

Sent: Wednesday, February 15, 2023 2:44 PM To: Pierre Saverot <Pierre.Saverot@nrc.gov>

Subject:

[External_Sender] RE: RE: Re: HI-STAR 180 Amd 5

Pierre, After further internal discussion following this afternoons status call, Holtecs preference would be to voluntarily withdraw the HI-STAR 180 application, and request that the non-exhaustive list of additional documents that would be bene"cial for review be provided for information. If amenable, Holtec would provide a letter proposing this withdrawal this week.

Thank you, Chris From: Pierre Saverot <Pierre.Saverot@nrc.gov>

Sent: Tuesday, February 14, 2023 8:46 AM To: Christopher O'Mullane <C.OMullane@holtec.com>

Subject:

RE: RE: Re: HI-STAR 180 Amd 5 CAUTION: This email came from a source OUTSIDE of Holtec!!

Do not click any links or open any attachments unless you trust the sender and know the contents to be safe.

Clicking links or opening attachments could lead to infecting your computer or Holtecs servers with malicious viruses.

Chris,

Take your time. No hurry!

We are "nding that the application is incomplete and that documents we need for the review have not been submitted. I am writing an ocial letter to Holtec Pierre From: Christopher O'Mullane <C.OMullane@holtec.com>

Sent: Tuesday, February 14, 2023 8:43 AM To: Pierre Saverot <Pierre.Saverot@nrc.gov>

Subject:

[External_Sender] RE: Re: HI-STAR 180 Amd 5

Good Morning Pierre, I just wanted to let you know that I have not forgotten about your questions and apologize for the delay. Ive been having a little trouble getting ahold of the necessary information, but will get back to you as soon as I can.

Thanks, Chris From: Pierre Saverot <Pierre.Saverot@nrc.gov>

Sent: Friday, February 3, 2023 9:54 AM To: Christopher O'Mullane <C.OMullane@holtec.com>

Subject:

RE: Re: HI-STAR 180 Amd 5 CAUTION: This email came from a source OUTSIDE of Holtec!!

Do not click any links or open any attachments unless you trust the sender and know the contents to be safe.

Clicking links or opening attachments could lead to infecting your computer or Holtecs servers with malicious viruses.

Not a problem. I just wanted to be sure I would get a response, not too far out in the future.

What could be a real problem is that there could be documents our technical reviewers may need and that I cannot "nd. I am doublechecking everything now..

From: Christopher O'Mullane <C.OMullane@holtec.com>

Sent: Friday, February 3, 2023 9:49 AM To: Pierre Saverot <Pierre.Saverot@nrc.gov>

Subject:

[External_Sender] Re: HI-STAR 180 Amd 5 Thank you for the additional information, Pierre.

I still have some work to do on my end to make sure I fully understand the history and current state of the FIAs.

Unfortunately, I am working from home today and experiencing some internet issues that are preventing me from getting onto the HOLTEC network. It may take until the beginning of next week for me to get you all responses to your questions.

I apologize for the delay.

Get Outlook for iOS From: Pierre Saverot <Pierre.Saverot@nrc.gov>

Sent: Thursday, February 2, 2023 1:24:54 PM To: Christopher O'Mullane <C.OMullane@holtec.com>

Cc: Kimberly Manzione <K.Manzione@holtec.com>

Subject:

RE: RE: HI-STAR 180 Amd 5 CAUTION: This email came from a source OUTSIDE of Holtec!!

Do not click any links or open any attachments unless you trust the sender and know the contents to be safe.

Clicking links or opening attachments could lead to infecting your computer or Holtecs servers with malicious viruses.

Chris, Thanks. I was anxious after 4 days to get a response.Nothing else.

The only statement I found regarding the FIA was in one of our SERs (Rev. 1 back in 2014):

The primary change to the fuel impact attenuator (FIA) design follows the change in functional performance requirements of the device. Previously, this device acted as a secondary internal impact limiter to mitigate additional damage that may occur with a hard secondary impact following initial deformation of the external impact limiters. The current device, located in the bottom of the package cavity, is now classi"ed as an active-passive device that is designed to limit the gap prior to impact rather than mitigate the impact itself. Functionally, this achieves a similar result in the damage imparted on the fuel assemblies but, practically, the design and therefore the structural evaluation is simpli"ed.

With respect to a top end drop, the FIA contains a spring (Spring 1) that has sucient stiness to translate the fuel assembly while shifting to a lid-down con"guration, thereby closing any residual gap that may be present and reducing any additional damage from a secondary impact to both

the closure lid and the fuel assemblies. The second component of the FIA is designated a spring (Spring 2) but functionally acts as a rigid spacer. During a bottom down-end drop, the fuel assembly rests on Spring 2, as Spring 1 is not designed to be rigid enough to support the fuel assembly dead load in this con"guration. During freefall, however, it is possible for the spring to unload causing the fuel assembly to contact the closure lid thereby allowing the maximum internal gap to be present. Because of this potential condition, the applicant evaluated the bottom end drop with a bounding 20 mm gap (ignoring the FIA) and demonstrated that the structural integrity of the package or contents would not be compromised including the condition that Spring 2 would not be susceptible to yielding or gross buckling. The applicant did report that the maximum clearance gap was reduced from 20 mm to 18 mm; however, this change does not alter any conclusions with respect to the structural analysis.

The evaluation and justi"cation for the change in the design and function of the FIA are currently satisfactory to the NRC sta such that no requests for additional information were necessary at this time.

It could be considered optional ( and I will agree with that determination) but I did not "nd any formal optional statement in your SAR or justi"cation. In any case, BOM and drawing and note need to be synchronized Pierre From: Christopher O'Mullane <C.OMullane@holtec.com>

Sent: Thursday, February 2, 2023 1:14 PM To: Pierre Saverot <Pierre.Saverot@nrc.gov>

Cc: Kimberly Manzione <K.Manzione@holtec.com>

Subject:

[External_Sender] RE: HI-STAR 180 Amd 5

Pierre, I have passed observation (a) along to the individuals who worked Chapter 2.

For observation (b), I can con"rm the instance in SAR Section 2.1.2.2(iii) was indeed a typo; in addition to SA-352 LCC castings, the optional MSC may be fabricated from SA-105 or SA-350 LF2 forgings. I am also looking into the question about the FIAs.

I will follow up regarding Chapter 2 and get you responses to all comments/observations by the end of the week.

Thank you, Chris

From: Pierre Saverot <Pierre.Saverot@nrc.gov>

Sent: Thursday, February 2, 2023 1:07 PM To: Christopher O'Mullane <C.OMullane@holtec.com>

Cc: Kimberly Manzione <K.Manzione@holtec.com>

Subject:

RE: HI-STAR 180 Amd 5 CAUTION: This email came from a source OUTSIDE of Holtec!!

Do not click any links or open any attachments unless you trust the sender and know the contents to be safe.

Clicking links or opening attachments could lead to infecting your computer or Holtecs servers with malicious viruses.

Chris, When will I get a response to the observations below?

Thanks Pierre From: Pierre Saverot Sent: Monday, January 30, 2023 1:49 PM To: Christopher O'Mullane <C.OMullane@holtec.com>

Cc: Kimberly Manzione <K.Manzione@holtec.com>

Subject:

HI-STAR 180 Amd 5

Chris, If I start to bug you, that is because the review has started as I told Kim earlier with RAI scheduled for June and CoC before the end of the year.if all goes well.

I need you to quickly clarify now some materials questions, i.e., mainly inconsistencies in material call-outs:

a. The new bolted basket shims (CBS) can be the original ASTM B221 2219-T8511 material or a new alternate aluminum alloy. The alternate is called out as 6063-T5 some places (dwgs. and Ch. 2) but as 6063-T6 other places. Whereas Table 2.2.9B, which lists the mechanical properties at various temperatures, does not list a tempering grade at all, it seems that T6 has stronger material properties due to a faster quenching process, so the correct material properties need to be identi"ed for use in the various analyses. Can you look at those sections and proofread those as well as the tables and tell me what we shall review.

b. The optional MSC can be either the original cast material (SA 352, Gr LCC) or new forged materials: SA-105 or SA 350 LF2 (per the dwgs. and other places), but the last material is also called out as SA 350 L2 in SAR section 2.1.2.2 (iii). I think this last case is a typo. Please con"rm.

The SAR still mentions the fuel impact attenuator, which, if memory serves me well is now optional. It is itemized in the BOM and referenced by note on one dwg. set, but the note was deleted !! Please advise.

Thanks, Pierre The information contained herein is intended only for the person or entity to which it is addressed and may contain con"dential and/or privileged material from Holtec International. If you are not the intended recipient, you must not keep, use, disclose, copy or distribute this email without the author's prior permission. Further, review, retransmission, dissemination, or other use of this information in whole or part for any other purpose by persons outside the recipient's organization is strictly prohibited unless explicit authorization to such eect has been issued by the sender of this message. Holtec International policies expressly prohibit employees from making defamatory or oensive statements and infringing any copyright or any other legal right by Email communication. Holtec International will not accept any liability in respect of such communications. Holtec International has taken precautions to minimize the risk of transmitting software viruses, but we advise you to carry out your own virus checks on any attachment to this message. Holtec International cannot accept liability for any loss or damage caused by software viruses. If you are the intended recipient and you do not wish to receive similar electronic messages from us in the future then please respond to the sender to this eect. The information contained herein is intended only for the person or entity to which it is addressed and may contain con"dential and/or privileged material from Holtec International. If you are not the intended recipient, you must not keep, use, disclose, copy or distribute this email without the author's prior permission. Further, review, retransmission, dissemination, or other use of this information in whole or part for any other purpose by persons outside the recipient's organization is strictly prohibited unless explicit authorization to such eect has been issued by the sender of this message. Holtec International policies expressly prohibit employees from making defamatory or oensive statements and infringing any copyright or any other legal right by Email communication. Holtec International will not accept any liability in respect of such communications. Holtec International has taken precautions to minimize the risk of transmitting software viruses, but we advise you to carry out your own virus checks on any attachment to this message. Holtec International cannot accept liability for any loss or damage caused by software viruses. If you are the intended recipient and you do not wish to receive similar electronic messages from us in the future then please respond to the sender to this eect. The information contained herein is intended only for the person or entity to which it is addressed and may contain con"dential and/or privileged material from Holtec International. If you are not the intended recipient, you must not keep, use, disclose, copy or distribute this email without the author's prior permission. Further,

review, retransmission, dissemination, or other use of this information in whole or part for any other purpose by persons outside the recipient's organization is strictly prohibited unless explicit authorization to such eect has been issued by the sender of this message. Holtec International policies expressly prohibit employees from making defamatory or oensive statements and infringing any copyright or any other legal right by Email communication.

Holtec International will not accept any liability in respect of such communications. Holtec International has taken precautions to minimize the risk of transmitting software viruses, but we advise you to carry out your own virus checks on any attachment to this message. Holtec International cannot accept liability for any loss or damage caused by software viruses. If you are the intended recipient and you do not wish to receive similar electronic messages from us in the future then please respond to the sender to this eect. The information contained herein is intended only for the person or entity to which it is addressed and may contain con"dential and/or privileged material from Holtec International. If you are not the intended recipient, you must not keep, use, disclose, copy or distribute this email without the author's prior permission. Further, review, retransmission, dissemination, or other use of this information in whole or part for any other purpose by persons outside the recipient's organization is strictly prohibited unless explicit authorization to such eect has been issued by the sender of this message. Holtec International policies expressly prohibit employees from making defamatory or oensive statements and infringing any copyright or any other legal right by Email communication. Holtec International will not accept any liability in respect of such communications. Holtec International has taken precautions to minimize the risk of transmitting software viruses, but we advise you to carry out your own virus checks on any attachment to this message. Holtec International cannot accept liability for any loss or damage caused by software viruses. If you are the intended recipient and you do not wish to receive similar electronic messages from us in the future then please respond to the sender to this eect. The information contained herein is intended only for the person or entity to which it is addressed and may contain con"dential and/or privileged material from Holtec International. If you are not the intended recipient, you must not keep, use, disclose, copy or distribute this email without the author's prior permission. Further, review, retransmission, dissemination, or other use of this information in whole or part for any other purpose by persons outside the recipient's organization is strictly prohibited unless explicit authorization to such eect has been issued by the sender of this message. Holtec International policies expressly prohibit employees from making defamatory or oensive statements and infringing any copyright or any other legal right by Email communication. Holtec International will not accept any liability in respect of such communications. Holtec International has taken precautions to minimize the risk of transmitting software viruses, but we advise you to carry out your own virus checks on any attachment to this message. Holtec International cannot accept liability for any loss or damage caused by software viruses. If you are the intended recipient and you do not wish to receive similar electronic messages from us in the future then please respond to the sender to this eect. The information contained herein is intended only for the person or entity to which it is addressed and may contain con"dential and/or privileged material from Holtec International. If you are not the intended recipient, you must not keep, use, disclose, copy or distribute this email without the author's prior permission. Further, review, retransmission, dissemination, or other use of this information in whole or part for any other purpose by

persons outside the recipient's organization is strictly prohibited unless explicit authorization to such eect has been issued by the sender of this message. Holtec International policies expressly prohibit employees from making defamatory or oensive statements and infringing any copyright or any other legal right by Email communication. Holtec International will not accept any liability in respect of such communications. Holtec International has taken precautions to minimize the risk of transmitting software viruses, but we advise you to carry out your own virus checks on any attachment to this message. Holtec International cannot accept liability for any loss or damage caused by software viruses. If you are the intended recipient and you do not wish to receive similar electronic messages from us in the future then please respond to the sender to this eect.