ML25254A231
| ML25254A231 | |
| Person / Time | |
|---|---|
| Site: | 07201032 |
| Issue date: | 09/11/2025 |
| From: | Holtec |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML25254A228 | List: |
| References | |
| 5018126 | |
| Download: ML25254A231 (1) | |
Text
Holtec Response to Request for Additional Information Batch 2 Non-Proprietary Docket No. 72-1032 Holtec International HI-STORM FW Multipurpose Canister Storage System Certificate of Compliance No. 1032 Amendment No. 10 Technical Specifications and Operating Controls and Limits RAI RAI 17-1:
Revise the Technical Specification (TS) Bases for Limiting Condition for Operation (LCO) 3.1.2 to be consistent between the HI-STORM FW system and HI-STORM FW Extended Configuration, and with the Note in LCO 3.1.2 of the TS.
In the TS Bases for LCO 3.1.2 in appendix 13.A of the final safety analysis report, it states that [o]perability is defined as at least 50% of the inlet air ducts available for air flow (i.e., unblocked). It then states for the HI-STORM FW Extended Configuration that [o]perability is defined as 50% or more of each of the inlet and outlet vent areas unblocked and available for flow. There appears to be an inconsistency between the operability definitions for each configuration. Comparing these definitions to the Note in TS LCO 3.1.2, which states, [t]he SFSC Heat Removal System is operable when 50% or more of each of the inlet and outlet vent areas are unblocked and available for flow, it appears that the operability definition for the standard HI-STORM FW system should be revised to meet the operability definition in the TS.
This information is necessary to demonstrate compliance with 10 CFR 72.236(f) and (l).
HOLTEC RESPONSE:
Holtec acknowledges the differences between the operability definition for the standard HI-STORM FW system in the TS Bases (LCO 3.1.2, Appendix 13.A of the FSAR) and the Note in LCO 3.1.2 of CoC Appendix A. The TS Bases definition for the standard HI-STORM FW system has been revised to ensure consistency with the Note in LCO 3.1.2 of CoC Appendix A.
RAI 17-2:
Define Note 1 in table 5-1 of appendix A of the TS or remove if not necessary.
Note 1 is not defined in the TS.
This information is necessary to demonstrate compliance with 10 CFR 72.236(b) and (c).
HOLTEC RESPONSE:
Note 1 in Table 5-1 of the CoC Appendix A TS has been defined. Table 5-1 in CoC Appendix A does not define a lifting height limit for horizontal lifting of the transfer cask. Thus, the note points to Section 5.2.c.4.b of CoC Appendix A which requires a site-specific drop analysis to be performed in accordance with item No.7. in Section 3.4 of CoC Appendix B to demonstrate the safe operation of the system. to Holtec Letter 5018126 NON-PROPRIETARY INFORMATION Page 1 of 1