ML23108A278

Comment (006) from Michael Ford on PR-72 - List of Approved Spent Fuel Storage Casks: Holtec International HI-STORM 100 Cask System, Certificate of Compliance No. 1014, Renewal of Initial Certificate and Amendment Nos. 1 Through 15

ML23108A278
Person / Time
Site:	Holtec
Issue date:	04/14/2023
From:	Monica Ford - No Known Affiliation
To:	NRC/SECY
References
NRC-2022-0109, 88FR9195 00006
Download: ML23108A278 (1)

Text

4/17/23, 4:54 PM blob:https://www.fdms.gov/95301426-69e9-49a2-b121-88453c09e938

As of: 4/17/23, 4:54 PM Received: April 14, 2023 PUBLIC SUBMISSION Status: Pending_Post Tracking No. lgh-b75a-x8hs Comments Due: April 14, 2023 Submission Type: Web

Docket: NRC-2022-0109 List of Approved Spent Fuel Storage Casks: Holtec International HI-STORM 100 Cask System, Certificate of Compliance No. 1014, Renewal of Initial Certificate and Amendment Nos. 1 through 15

Comment On: NRC-2022-0109-0007 List of Approved Spent Fuel Storage Casks: Holtec International HI-STORM 100 Cask System, Certificate of Compliance No. 1014, Renewal of Initial Certificate and Amendment Nos. 1 Through 15

Document: NRC-2022-0109-DRAFT-0013 Comment on FR Doc # 2023-05831

Submitter Information

Name: Michael Ford Address:

Amarillo, TX, 79109 Email: michael@healthphysics.com Phone: 806-459-9979

General Comment

See attached comments from Micheal Ford of HealthPhysics.com

Attachments

Healthphysics.com Comments on Docket ID NRC-2022-0109

blob:https://www.fdms.gov/95301426-69e9-49a2-b121-88453c09e938 1/1 14 April 2023

Mr. James Firth & Ms. Kristina Banovac, Project Manager s Storage and Transportation Licensing Branch D ivision of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission

Subject : RE : Docket ID NRC -2022 -0109, List of Approved Spent Fuel Storage Casks: Holtec International HI -STORM 100 Cask System, Certificate of Compliance No. 1014, Renewal of Initial Certificate and Amendment Nos. 1 Through 15

Dear Mr. Firth & Ms. Banovac,

The foll owing comments a pply to all 68 documents released for public comment as NRC Proposed Certificates of Compliance and Proposed Technical Specifications on the subject docket. Attach ment 1 ide ntifi es the d ocuments and associated ADA Ms numbers.

General Comment :

Given that the applica nt seeks rene wal of the s ubject Certificates of Complian ce (CofC s) for an unpre ceden ted period of 40 years and given the history of the substandard quality control pr ocesses in which H olt ec dry storage canisters (DSCs) were manufacture d 20 y ea rs ago, it is not unreasonable to demand that ext raordi nary ca re and vigilance be requir ed and described in the saf ety bases for these multiple authorizations, especially as regards the Aging Management Plans (AMPs) deployed for these systems.

U nfortunately, such is not the case. There is no provision within the rudimentary Aging Management Pl an (AMP) template developed by the industry to create a condition for responding to discoveries in the causes and mitigations for chloride -induced stress corrosion cracking (CI -SCC). The NRC has specified the minimum possible scrutiny on a population of canis ters that will be at three (3) times their initial designed life span at the end of the proposed reauthorization period.

Indeed, the proposed Holte c AMP only requires the assessment of a single dry stora ge c anister (DSC) every 5 +/- 1.25 yrs., which could result in the inspection of one single cont ainer out of a

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population of dozens or hundre ds of containers (proposed CIS F ) eight times ove r the pr oposed 40 y ear reauthorization period. This is unacc eptable.

The NRC and the Department of Energy (DOE) take very different approaches to managing the risk of CI -S CC in spent nuclear fuel DSCs. The NRC attempts to establish the minimum acceptable regulatory requirements for Aging Management Programs (AMPs). In contrast, the DOE conducts research to better understand the causes and consequences of CI -SCC and identify knowledge gaps that must be filled.

The NRC's de mi nimus AMP Requirements :

The NRC's AM P requirements, such as inspection frequency and visual indicators, may not e ven be the bare minimum needed to protect the public and the environment and do not acknowledge the potential need to integ rate discoveries on the cause and mitigation of CI -SCC into the CofC AMP.

DOE's CI -SCC Research and Knowledge Gaps :

The DOE conducts research to better understand the causes and consequenc es of CI -SCC in DS and identify and prioritize knowledge gaps. The DOE's research typically includes the following components:

1. Investigating the underlying mechanisms: The DOE looks into the factors contributing to the initiation and propagation of CI -SCC, such as material properties, environmental conditions, and stressors.

2. Developing advanced detection methods: The DOE is developing and validating advanced non -destructive examination techniques, such as eddy current testing, ultrasonic testi ng, and remote visual inspection, to detect and characterize CI -SCC.

3. Modeling and simulation: The DOE creates models and simulations to predict DSC long -

term performance and susceptibility to CI -SCC, taking into account a variety of factors such as mat erial properties, environmental conditions, and stressors.

4. Identifying and prioritizing knowledge gaps: The DOE identifies areas where more research is required to better understand CI -SCC and its potential consequences. This could include assessing the efficacy of existing AMPs, inspection methods, or materi al selection strategies.

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The NRC should actively track the DOE's research efforts and results to provide a more comprehensive understanding of CI -SCC and inform regulatory decisions such as modifying AMP requirements or developing new guidance and best practices. 1

Specific Comments:

1. S e ction 7.1, paragraph 3, Holtec International Hi -Storm 100 Cask System Safety Evaluation Report, page 7 -1, the stated lea k rate of 5 E -6 std cc/sec helium is sufficient to allow the release of transuranic o xi des. The DOE leak tight sta nda rd for nuclear w eapon components is 1 E -11 to 1 E -12 std cc /sec because of the desig n l ifetime of nuc lea r weapons. A leak rate of 1 E -6 std cc results in the rejection of the component due to the leak rate.

With the extensi on of the service life of the DSCs by another 40 years (and likely beyond), the NRC should reassess the acceptable lea k rate.

2. S e ction 7. 2 to 7. 4, Holtec International Hi -Storm 100 Cask System Safety Evaluation Report, page 7 -2, given the re search being conducted by the DOE detailed by footno te 1, there is no cr edible basis to

a. S upport the statement in Section 7.4, Since the confinement boundary is welded and the temperature and pressure of the MPC are within the design -

basis limits, no discernable leakage is credible, or

b. Sup port the con clusion s of confinement integr ity, worst -case leak rate, or radionucl ide releases in Sections 7.2 and 7.3.

3. ML20049A083 /Attach ment 2 to Ho ltec L e tter 5014890, Appendix A: Hi -Storm 100 Aging Management Programs, MPC AMP, pages A -2 to A -5, th e AMP intended to be used for ea ch M PC Cof C ha s the following commentary on 4. Det ection of Aging Effects,

a. A visual inspection of the MPC surface shall be performed using a boroscope (or equivalent). The boroscope (or equivalent) inspection shall look at t he accessible areas of the MPC surface while the MPC remains in the overpack with the overpack lid installed. This visual inspection shall meet the requirements of a VT -

1 DOE Spent Fuel Research for Storage & Transportation, Ned La rson, NWTRB Winter 2022,

Meeting Virtual Meeting, March 1, 2022

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3 Examination, as given in the ASME Boiler & Pressure Vessel Code (B&PVC)

Section XI, Article IWA -2200, to the extent practical.

The inspection shall be performed on one canister at each site that uses the HI -

STORM 100 System. Note that if a site has more than one type of canister (for example, MPC -68 and MPC -68Ms), only one canister needs to be inspected. The selection criteria for choosing the canister to inspect should consider the following:

• EPRI Susceptibility Criteria (Technical Report 3002005371)

• Canister Age

• Canister with Lowest Heat Load

• Canister with specific previously identifie d manufacturing deviation

Alternatively, a site may choose to take credit for an inspection done at a different site, as long as the inspection can be shown to have been performed on a reasonably comparable or bounding canister based on the same criteria listed above.

If these detection methods were adequ ate for the discovery of a ctive CI -SCC zones/si tes, the DOE woul d not be spending tens of millions of doll ars to condu ct research on the in itiation phenom ena and mitigation of CI -SCC.

Further, allowing t he inspection of a single M PC, irresp ective of the nu mber of ca nisters a t a p articular site is wholly inad equate for the detection of tr ends or an omali es. This is particularly concerning g iven the impending licensing of the Holtec CISF in N ew Mexico that is li terally surroun ded by four ( 4) sal t playas.

Inspecting a single DSC among dozens at a given site every 5 +/- 1.25 years is in no way sufficient to ensure the prevention of canister failure due to CI -SCC, particularly at location surrounded by four salt playas. The effective ness of inspection frequency depends on several factors, including the quality of canister materials, the local environment, the effectiveness of preventive measures, and the susceptibility of the canisters to CI -SCC.

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T he effectiveness of the NRC gre enlighted inspection frequency produces the following concerns :

a. Limited Sample Size: Inspecting only one canister every 5 years (or 8 canisters over a 40 -year licens ing period) will not provide an adequate representation of the conditions affecting all canisters at the site. With a limited sample size, there is a high risk that potential issues affecting multiple canisters may go undetected.

b. Variability in Environmental Conditions: The environmental conditions affecting the canisters, such as temperature, humidity, and chloride concentrations, will vary across t he site. Inspecting only a single canister will not account for these variations, leading to an underestimation of the risk of CI -SCC.

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c. Progression of CI -SCC: in the area of the co u ntry laden with the highest conce n trations of s urface salts (includ ing sizeable conce ntration s of MgCl) CI -SCC can progress over time, and the time between inspections may be too long to dete ct and mitigate the issue before it leads to canister failure. A larger and more frequent inspection schedule wo uld en sure the detection of early signs of CI -SCC and allow appropriate corrective actions to be taken.

As an alternative, con sider the following Aging Management Program (AMP) elements :

a. A b iennial inspection schedu le and larger sample size a minimum of 2 MPCs that are changed by 50% each b iennium ranging to an optimal 10% of the entire MPC inventory changing by 50% each time to account for potential variability in environmental conditions and canister susceptibility, and ensuring that the enti re canister pop ulation is ev aluated in 10 years or less allowing for broad trends to emerge.

b. A robust environmental monitoring program to track changes in temperature, humidity, and chloride concentrations that may increase the r isk of CI -SCC.

c. A proactive approach to preventive measures, including the selection of materials resistant to CI -SCC, the application of protective coatings, and proper site drainage.

d. Periodic reviews and updates to the AMP based on new information, regula tory changes, or lessons learned from operating experience.

4. ML22098A303 /Section 3.5.2, Preliminary Safety Evaluation Report For The Hi -Storm 100 Cask System Certificate Of Compliance No. 1014 Renewal Docket No. 72 -1014, page 3 -

22, the following statement is made regarding the ev aluation find ings of NRC staff regardin g the AMPs provided by the applica nt:

The staff reviewed the AMPs in the renewal application. The staff performed its review following the guidance in NUREG -1927 and NUREG -2214. The staff evaluated the 10 elements of the applicants MPC AMP, Overpack AMP, Transfer Cask AMP, High Burnup Fuel As sembly AMP, and 100U Concrete AMP that address aging mechanisms and the effects of potential aging that could adversely affect the ability of the SSCs and associated subcomponents to perform their

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intended functions. For each program element, the staff eith er confirmed consistency with the example AMPs in NUREG -2214 or confirmed that the applicants alternative approach was adequate to manage all credible aging effects. Based on its review, the staff determined that the SSCs will continue to perform their in tended functions during the requested period of extended operation. The staff finds the following:

i. F3.4 : The applicant has identified programs that ensure that aging mechanisms and effects will be managed effectively during the period of extended operatio n, in accordance with 10 CFR 72.240(c)(3).

5. Matching pro gram eleme nts of an AMP with AMP program elements developed by industry of which the a pplica nt is a part of does not cons titute sufficient due diligence on the part of NRC staff to reach the state d finding. Base d on the ongoing re search of the DOE, t here is zero basis to reach the conclusion s state d b y NRC sta ff at 3.5.2 or F3.4.

If you have any questions regarding t he comments I have provide d, please con tact me at your earlie st convenience by email m ichael@healthphysics.com or by phone 806 -459 -9979.

Very Respectfully,

Michael S. Ford, CHP Owner /A nal yst Health Physics.com

Attachment

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ATTACH MENT 1

DOCKET ID NRC -2022 -0109 DOCUMENT LIST

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