ML21179A179

Acceptance Review of Request for Amendment No. 16 to Certificate of Compliance No. 1014 for HI-STORM 100 Multipurpose Canister Storage System, Request for Supplemental Information

ML21179A179
Person / Time
Site:	Holtec
Issue date:	07/12/2021
From:	Yen-Ju Chen Storage and Transportation Licensing Branch
To:	Seawright B Holtec
YJChen NMSS/DFM/STL 301.415.1018
Shared Package
ML21179A178	List: ML21179A179
References
CAC 001208, EPID L-2021-LLA-0039
Download: ML21179A179 (6)

Text

July 12, 2021 Brian Seawright Licensing Engineer Holtec International Holtec Technology Campus 1 Holtec Blvd.

Camden, NJ 08104

SUBJECT:

ACCEPTANCE REVIEW OF REQUEST FOR AMENDMENT NO. 16 TO CERTIFICATE OF COMPLIANCE NO. 1014 FOR THE HI-STORM 100 MULTIPURPOSE CANISTER STORAGE SYSTEM (DOCKET NO. 72-1014, CAC NO. 001028, EPID: L-2021-LLA-0039) - REQUEST FOR SUPPLEMENTAL INFORMATION

Dear Mr. Seawright:

By letter dated March 9, 2021 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML21068A360], Holtec International (Holtec) submitted to the U.S.

Nuclear Regulatory Commission a request to amend the Certificate of Compliance No. 1014 for HI-STORM 100 Multipurpose Canister Storage System.

The staff has performed an acceptance review of your application to determine if the application contains sufficient technical information to begin a detailed technical review. The staff has determined that the application does not provide sufficient technical information to begin a detailed review and that supplemental information is needed. The information needed to continue our review is described in the request for supplemental information (RSI) in the enclosures to this letter.

In Amendment No. 16, you also proposed to reorganize the certificate of compliance using the process developed and described in RIRP-I-16-01 (ADAMS Accession No. ML17138A119), also referred to as the graded approach. The staff has additional questions regarding this proposed change and plans to discuss this matter in a public meeting.

In order to schedule our technical review, responses to the enclosed RSI should be provided within 30 days from the date of this letter. If Holtec is unable to meet this response date, please notify us, at least one week prior to the due date, of your new submittal date and the reasons for the delay. If Holtec is not able to respond within this timeframe or the RSI responses do not provide sufficient information, the application may not be accepted for review.

B. Seawright Please reference Docket No. 72-1014, CAC No. 001028, and EPID No. L-2021-LLA-0039 in future correspondence related to this licensing action. If you have any questions, please contact me at 301-415-1018.

Sincerely, Signed by Chen, Yen-Ju on 07/12/21 Yen-Ju Chen, Sr. Project Manager Storage & Transportation Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-1014 CAC No.: 001208 EPID: L-2021-LLA-0039

Enclosures:

1. RSI

2. RSI (Proprietary)

Request for Supplemental Information Docket No. 72-1014 Holtec International HI-STORM 100 Multipurpose Canister Storage System Certificate of Compliance No. 1014 Amendment No. 16 Thermal RSI 5-1 See Enclosure 2.

Confinement RSI 9-1 Demonstrate the Proposed Changes #3 and #6 will reasonably maintain confinement of radioactive material under normal, off-normal, and credible accident conditions.

In its Statement of Proposed Changes, the applicant proposed to modify vent and drain penetrations to include the option of second port cover plate (Proposed Change #3).

The applicant also stated that the addition of a second cover plate for these penetrations removes the need to do field helium leak testing of these cover plates (Proposed Change #6).

The weld on the port cover plate cannot be executed under conditions where the root pass might have been subjected to pressurization from the helium filled in the canister itself. When executing vent and drain connection cover plate welds, one should not assume that the fill and drain closure valves quick-disconnects, or similar, are leak tight without performing helium leak testing. It is assumed that mechanical closure devices (e.g., a valve or quick-disconnect) permit helium leaks. Field experience has shown that such leaks occur and have been responsible for causing leak paths through the weld.

Consequently, welds potentially subjected to helium pressure (by way of leakage through a mechanical closure device) during the welding process must be subsequently helium leakage tested in accordance with the method in ANSI N14.5. In addition, ANSI N14.5 does not allow for the elimination of leakage rate testing based on the use of multiple barriers.

This information is required to satisfy 10 CFR 72.236 (d), 72.236 (j), and 72.236 (l).

Observations O-1 The staff recognizes that the HI-STORM 100 Amendment No. 15 (effective on June 14, 2021) and the ongoing renewal may result in additional changes to the Certificate of Compliance (CoC) and safety analysis report (SAR) which may impact Amendment No.

16. All application materials for Amendment No. 16 should be updated accordingly to facilitate staffs review.

Enclosure 1

O-2 Provide description of Note 3 shown on Table 2.4-5a of the proposed CoC Appendix D.

The applicant marked Note 3 to the title of Table 2.4-5a, but without providing any description. The applicant should either remove Note 3 from Table 2.4-5a or provide description on Note 3.

The staff needs this information to determine compliance with 10 CFR 72.236(f).

O-3 Provide cask component temperatures for MPC-32M and MPC-68M with heat load pattern No. 3 to ensure that the uniform heat load pattern is the most bounding pattern for both MPC-32M and MPC-68M.

In Report HI-2210138, Revision 0, the applicant shows in Tables 7-1 and 7-2, the uniform heat load patterns for MPC-32M and MPC-68M, respectively, resulted in highest peak cladding temperatures (PCTs) and cavity temperatures; therefore, the applicant concludes the uniform heat load pattern for the respective MPCs is the most bounding pattern.

Staff reviewed Tables 7-1 and 7-2 and found that the PCT of uniform heat load pattern is higher than the PCT of pattern No. 3 by 2°C for MPC-32M and by 1°C for MPC-68M.

With such small PCT differences between uniform heat load pattern and pattern No. 3, the applicant should provide cask component temperatures, similar to Table 7-3, of the heat load patterns No. 3 for MPC-32M and MPC-68M. The staff needs the information to verify and ensure that the uniform heat load pattern is indeed the bounding heat load pattern for MPC-32M and MPC-68M.

The staff needs this information to determine compliance with 10 CFR 72.236(f).

O-4 See Enclosure 2.

O-5 (A) Provide the derivations of the MPC-32M and MPC-68M annulus pressures, as shown in Report HI-2210138, Revision 0, Tables 7-8 and 7-9; and (B) explain the similarity of annulus pressures between MPC-32M and MPC-68M under long-term normal storage, extreme ambient accident, burial under debris accident, and fire accident.

(A) The applicant presented in Report HI-2210138, Revision 0, Tables 7-8 and 7-9, the annulus pressures of MPC-32M and MPC-68M, respectively, for MPC loaded in the unventilated overpack with the bounding heat load pattern in cask array under long-term normal storage, extreme ambient accident, burial under debris accident, and fire accident.

Provide the derivations of these MPC-32M and MPC-68M annulus pressures under the conditions underlined above. The derivation of annulus pressures should include the assumptions, equations (e.g., ideal gas equation), annulus temperature, and parameters (with units) used in the derivation.

(B) Report HI-2210138, Revision 0, Tables 7-3 and 7-4 present the single cask containing MPC maximum component temperatures with uniform heat load for MPC-32M and MPC-68M, respectively. The cask component temperatures for MPC-32M and MPC-68M are different, and it is expected that the difference, when stored in unventilated overpack, would have impact on the temperature and pressure of the annulus between MPCs and unventilated overpack for normal, off-normal, and accident conditions of storage.

Explain why the MPC-32M annulus pressure (Table 7-8) is identical to the MPC-68M annulus pressure (Table 7-9) under each condition of long-term normal storage, extreme ambient accident, burial under debris accident, and fire accident.

The staff needs this information to determine compliance with 10 CFR 72.236(f).

O-6 Clarify the applicability of Proposed Change #5 to MPC types in the application (see item (A) below) and add a requirement (see item (B) below) in the Technical Specifications or SAR Chapter 9 to ensure the minimum heat load limit is adequate to maintain the water in the HI-TRAC water jacket is above the freezing point (0°C/32°F).

The applicant proposed to use water without glycol in the HI-TRAC water jacket during transfer operations below 32°F ambient (Proposed Change #5). In Report HI-2043317, HI-TRAC Thermal Modeling to Address NRC Review Comments for HI-STORM 100 LAR-9, Appendix N.5.19, the applicant stated that the temperature of water in the HI-TRAC water jacket remains above freezing point (32°F) with heat load equal to or above 10 kW, and therefore, the system of MPC-32 in HI-TRAC does not need to be filled with ethylene glycol under allowable operating short-term conditions. The applicant presented the minimum water temperature in Table N.5.23 and stated that this calculation may be performed using the above set of assumptions for any MPC type and for any site-specific ambient conditions.

(A) Clarify whether the proposed change #5 is applicable only to MPC-32 system (including MPC-32M) with heat load equal to or greater than 10 kW or also applicable to MPC-68 system (including MPC-68M) with heat load equal to or greater than 10 kW.

(B) Add a requirement in Technical Specifications or SAR Chapter 9, Operating Procedures, such as the users need to perform thermal evaluation using the site-specific heat loads and ambient conditions to determine the minimum heat load limit for using water without ethylene glycol in the HI-TRAC water jacket during transfer operations below 32°F. This is to ensure the heat load limit is adequate to maintain the water in the HI-TRAC water jacket above the freezing point (0°C/32°F).

(C) Correct the labeling for N.5.19 on page N-25.

The staff needs this information to determine compliance with 10 CFR 72.236(f).

O-7 See Enclosure 2.

ML21179A178; Ltr ML21179A179 OFFICE NMSS/DFM/STLB NMSS/DFM/STLB NMSS/DFM/STLB NMSS/DFM/IOB WWheatley NAME YChen YC YChen YC HLindsay HL SFigueroa for SF DATE Jun 28, 2021 Jun 28, 2021 Jun 28, 2021 Jun 28, 2021 NMSS/DFM OFFICE NMSS/DFM/NARAB NMSS/DFM/MSB NMSS/DUWP/RDB

/CTCFB JMarcano NAME MCall MC FChang FC ZCruz-Perez ZC ZLi for ZL DATE Jun 29, 2021 Jun 28, 2021 Jun 29, 2021 Jun 29, 2021 OFFICE NMSS/DFM/STLB NMSS/DFM/STLB NAME JMcKirgan JM YChen YC DATE Jul 12, 2021 Jul 12, 2021