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Letter to K. Manzione - Third Request for Additional Information, Holtec International'S Application for the HI-STORE Consolidated Interim Storage Facility
	ML22062B669
Person / Time
Site:	HI-STORE
Issue date:	03/23/2022
From:	Jose Cuadrado-Caraballo; Storage and Transportation Licensing Branch
To:	Manzione K; Holtec
Shared Package
ML22062B670	List: ML22062B669;
References
	CAC 001028, EPID L-2018-NEW-0001
	Download: ML22062B669 (17)
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OFFICIAL USE ONLY - PROPRIETARY INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 23, 2022 Ms. Kimberly Manzione, Licensing Manager Holtec International Holtec Technology Campus One Holtec Boulevard Camden, NJ 08104

SUBJECT:

HOLTEC INTERNATIONALS APPLICATION FOR SPECIFIC INDEPENDENT SPENT FUEL STORAGE INSTALLATION LICENSE FOR THE HI-STORE CONSOLIDATED INTERIM STORAGE FACILITY FOR SPENT NUCLEAR FUEL - THIRD REQUEST FOR ADDITIONAL INFORMATION

Dear Kimberly Manzione:

By letter dated March 30, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17115A431), as supplemented, Holtec International (Holtec) submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for a specific independent spent fuel storage installation license to construct and operate the HI-STORE Consolidated Interim Storage Facility (CISF), in Lea County, New Mexico, in accordance with the requirements of Part 72 of Title 10 of the Code of Federal Regulations (10 CFR 72),

Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste and Reactor-Related Greater than Class C Waste. The license application seeks NRC approval to store up to 8,680 metric tons of commercial spent nuclear fuel in the HI-STORM UMAX Canister Storage System for a 40-year license term.

As discussed in our letter dated November 19, 2021 (ML21322A219), the NRC staff has reviewed your responses to its second requests for additional information (RAIs) and determined that additional information is necessary to complete its detailed review and make the required regulatory compliance findings. The information needed by the staff is discussed in the enclosed third RAIs. We request that you notify NRC staff in writing, within two weeks of receipt of this letter, of your proposed schedule for submitting responses to the staffs RAIs.

The NRC staff expects to publish a revised schedule for the completion of its safety review, environmental review, and final licensing decision approximately 30 days after it receives your responses to these RAIs.

In order to ensure that your responses to the staffs third RAI is complete and adequately resolves the remaining issues, the staff strongly recommends that Holtec staff meet with NRC to discuss the proposed answers prior to their submission.

Upon removal of Enclosure 2, this document is uncontrolled

OFFICIAL USE ONLY - PROPRIETARY INFORMATION K. Manzione 2 If you have any questions regarding these matters, please contact Mr. Jose R. Cuadrado, Project Manager, at (301) 415-0606.

Sincerely, Signed by Cuadrado-Caraballo, Jose on 03/23/22 Jose R. Cuadrado, Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 72-1051 CAC/EPID No.: 001028/07201051/

L-2018-NEW-0001

Enclosures:

1. Third RAI (Non-Proprietary)

2. Third RAI (Proprietary)

Third Request for Additional Information Docket No. 72-1051 Application for specific independent spent fuel storage installation license for the HI-STORE Consolidated Interim Storage (CIS) Facility in Lea County, New Mexico By letter dated March 30, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17115A431), as supplemented on April 13 (ML17109A386),

October 6 (ML17310A218), December 21 (ML17362A097) and 22 (ML18011A158), 2017; February 23 (ML18058A617), May 24 (ML18150A319), July 27 (ML18213A206), November 30 (ML18345A153), 2018; January 31 (ML19037A280), March 15 (ML19081A083) and 30 (two submissions, ML19094A271 and ML19106A183), May 13 (ML19143A268) and 16 (ML19143A319), and August 26 (ML19248C140), 2019; March 3 (ML20065H155), June 1 (two submissions, ML20153A783 and ML20153A777), July 17 (ML20198M638), September 16 (ML20260H139), October 9 (two submissions, ML20283A789 and ML20290A505), and November 20 (ML20326A005), 2020; January 4 (ML21004A241), June 30 (ML21224A105),

August 16 (ML21228A201), August 31 (ML21243A525), and October 31, 2021 (ML21304A003),

Holtec International (Holtec) submitted to the U.S. Nuclear Regulatory Commission (NRC) an application for a specific independent spent fuel storage installation license to construct and operate the HI-STORE Consolidated Interim Storage Facility (CISF), in Lea County, New Mexico, in accordance with the requirements of Part 72 of Title 10 of the Code of Federal Regulations (10 CFR 72), Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste and Reactor-Related Greater than Class C Waste.

This request for additional information (RAI) identifies additional information needed by the NRC staff in connection with its safety review of the HI-STORE CISF license application. The requested information is listed by the specific part of the license application, the specific chapter or section number in the safety analysis report, environmental report, or their respective supporting analyses. The staff used the guidance in NUREG-1567, Standard Review Plan for Spent Fuel Dry Storage Facilities, for its review of the application.

Safety Analysis Report (SAR), Chapter 2, Site Characterization RAI 2-7-S-1: Provide the basis of each assumption taken in assessing the explosion hazards and consequences to structures or systems important to safety at the proposed CISF from a rupture of any pipeline resulting in release and subsequent ignition of the natural gas (SAR Section 2.2.2, Pipelines). At a minimum, the bases for the following assumptions should be provided and clarified:

1) [Contains Proprietary Information, see Enclosure 2]

2) [Contains Proprietary Information, see Enclosure 2]

3) [Contains Proprietary Information, see Enclosure 2]

4) [Contains Proprietary Information, see Enclosure 2]

5) [Contains Proprietary Information, see Enclosure 2]

6) [Contains Proprietary Information, see Enclosure 2]

Enclosure 1

7) [Contains Proprietary Information, see Enclosure 2]

8) [Contains Proprietary Information, see Enclosure 2]

9) [Contains Proprietary Information, see Enclosure 2]

10) [Contains Proprietary Information, see Enclosure 2]

11) Provide the correct URL to access the PHMSA Pipeline Incident Data.

This information is necessary to determine compliance with 10 CFR 72.24(a), 72.90(a) through (d), 72.94, and 72.122.

RAI 2-14-S-1: Justify the following assumptions in SAR Section 2.2.4, Ground Transportation, and HI-2210620, HI-STORE Highway 62/180 Hazardous Chemicals Risk Evaluation, that hazardous cargos while being transported by the 62/180 Highway using tank trucks near the proposed site would not pose a credible hazard to the proposed CISF.:

1) [Contains Proprietary Information, see Enclosure 2]

2) Justify the wind directions selected for ALOHA analysis.

3) Provide correct URL to access the relevant data from the accident/incident database from the Federal Railroad Administration.

This information is necessary to determine compliance with 10 CFR 72.24(a), 72.90(a) through (d), 72.94, and 72.122.

RAI 2-15-S: Justify the following assumptions in SAR Section 2.2.4, Ground Transportation, and HI-2210619, HI-STORE Railway Hazardous Chemicals Risk Evaluation, that hazardous cargos while being transported by rail cars near the proposed site would not pose any credible hazard to the proposed CISF:

1) Define the terms accident and incident associated with railway mishaps as used in the SAR and HI-221019.

2) [Contains Proprietary Information, see Enclosure 2]

3) Provide correct URL to access the relevant data from the accident/incident database from the Federal Railroad Administration.

This information is necessary to determine compliance with 10 CFR 72.24(a), 72.90(a) through (d), 72.94, and 72.122.

RAI 2-16-S-3: Provide a technical basis and additional information to justify that the selected probable maximum precipitations (PMPs) are resulted from corresponding probable maximum storms (PMSs) for all PMP durations.

The applicant identified the PMPs of various duration according to two methods - the National Weather Service Hydrometeorological Report (HMR) 51/52 [National Oceanic and Atmospheric Administration, 1980 and 1982] and the CO-NM [Colorado Division of Water Resources, 2018]

methods. In calculating the HMR 51/52 PMPs, the applicant placed the storm center at the centroid of the entire watershed, which is comprised of five subbasins contributing to potential 2

flooding events at the proposed CISF site. The U.S. Army Corps of Engineers users manual for the HMR52 software [USACE, 1987] suggested that the center of the storm, in additional to storm size and orientation, be adjusted to assure the precipitation as calculated by the software is the PMP. Additionally, determination of the controlling PMP should be based on the probable maximum flood (PMF) water level. The applicant should clearly identify the model parameters and hydraulic modeling results in its justification for the selection of the controlling PMP. The applicant should also provide the hydrologic and hydraulic model input files, for verification of the controlling PMP by the staff.

This information is necessary to determine compliance with 10 CFR 72.90(b) through (c), 10 CFR 72.92(a) through (b), 72.98(a), and 72.122(b)(2)(i)(A) through (B).

RAI 2-16-S-4: Provide additional technical basis to justify that the Clark Unit Hydrograph method results in the highest probable maximum flood (PMF) water level.

The applicant examined three rainfall to surface runoff transformation methods, namely the Clark Unit Hydrograph (CUH), the Soil Conservation Service (SCS) Hydrograph, and the U. S.

Bureau of Reclamation Flood Hydrology Manual Method [GEI Consultants, 2021]. The applicant reported that the CUH produced the highest peak of flow [Figure 12, GEI Consultants, 2021]. It is important to note that PMF water level is a more important indicator of flood impact to onsite structure, system, and components (SSC) important to safety than flow rate. In particular, Figure 12 suggests that the SCS method resulted in later peak arrival but higher total water volume among the three hydrographs tested. The applicant should provide additional information, e.g., comparison of PMF water levels at various SSC locations using the three unit hydrographs, including the parameters used for calculating the flow rates and water levels.

This information is necessary to determine compliance with 10 CFR 72.90(a), 72.90(b), and 72.92(c).

RAI 2-18-S-1: Provide additional technical basis to justify the use of the initial and constant loss method in determining rainfall excess.

In the hydrologic models of the CISF, the applicant selected, among others, the initial and constant loss method to determine rainfall loss and thus rainfall excess that was subsequently transformed to surface runoff. However, the applicant provided little justification as to why the method is applicable, for example, to the antecedent soil moisture content, to the depth of soil profiles that may accommodate a constant loss rate, and to restrictive layer of soil or formation beneath land surface. The applicant cited the New Mexico Office of State Engineer [NMOSE, 2008] and selected constant loss rates referenced in the publication for various soil groups. The applicant should provide additional information to justify the selection of the median constant loss rates without determining the sensitivity of model results to this particular model parameter.

The applicant should also justify model assumptions, its selection of model parameters, and subsequently compare model calculated rainfall excess against standard engineering practices, for example, the 2008 NMOSE hydrologic modeling guidelines.

This information is necessary to determine compliance with 10 CFR 72.90(a), 72.90(b), and 72.92(c).

RAI 2-18-S-2: Provide technical basis to justify the outflow structure parameters and outflow curve at the three large playas, Lagunas Gatuna, Plata, and Tonto, used in the hydrologic models.

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The applicant used a broad-crested dam as the outflow structure for Lagunas Gatuna and Tonto, and an outflow curve for Laguna Plata in the hydrologic model. The applicant indicated that the selection of these model inputs was based on digital elevation models obtained from the United States Geological Survey. However, no information can be found in the SAR or the GEI report indicating the outflow area geometry and the relevant parameters used to obtain the outflow curve for Laguna Plata. The applicant should provide additional information to justify the use of these input values.

This information is necessary to determine compliance with 10 CFR 72.90(a), 72.90(b), and 72.92(c).

RAI 2-18-S-3: Add probable maximum seiche wave height to PMF water level.

Surge and seiche affect sites adjacent to large water bodies or the oceans. The CISF site is adjacent to the large Laguna Gatuna playa. The applicants hydrologic and hydraulic calculations indicated that the western boundary of Laguna Gatuna reaches the CISF under the 72-hour PMP condition. The applicant should calculate the seiche wave height under this condition and add the result to the PMF water level.

This information is necessary to determine compliance with 10 CFR 72.90(a), 72.90(b), and 72.92(c).

RAI 2-18-S-4: Justify the exclusion of ice flooding given the large playa Laguna Gatuna is adjacent to the site boundary.

Winter precipitation has been recorded in the area surrounding the site. For example, the applicant reported that the maximum recorded snow accumulation for Hobbs, NM, is 12.2 inches. It is also likely that freezing of the water retained in nearby Laguna Gatuna can occur in the winter. The applicant should provide additional information to justify that ice flooding would not impact the onsite structure, system, and component important to safety.

This information is necessary to determine compliance with 10 CFR 72.122(b)(2)(i)(A) and (B).

References:

1. Colorado Division of Water Resources, Department of Natural Resources, 2018.

Colorado - New Mexico Regional Extreme Precipitation Study, Summary Report, Volume II. Deterministic Regional Probable Maximum Precipitation Estimation.

November, 2018.

2. GEI Consultants, 2021. Report CIS-RP 003-02, Probable Maximum Flood Analysis, HI-STORE CISF, Lea County, New Mexico. July 2021.

3. National Oceanic and Atmospheric Administration (NOAA), 1982. Application of Probable Maximum Precipitation Estimates - United States East of the 105th Meridian, Hydrometeorological Report Number 52 (HMR-52), National Oceanic and Atmospheric Administration, August, 1982.

4. NOAA, 1980. Probable Maximum Precipitation Estimates - United States East of the 105th Meridian, Hydrometeorological Report Number 51 (HMR-51), National Oceanic and Atmospheric Administration, August, 1980.

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5. New Mexico Office of the State Engineer (NMOSE), 2008. Hydrologic Analysis for Dams, August 15, 2008.

6. United States Army Corps of Engineers, 1987. HMR 52, Probable Maximum Storm (Eastern United States), Users Manual, Revised April 1987.

RAI 2-33-S: Provide the material properties of each stratigraphic layer of the subgrade used in estimating the immediate and long-term (consolidation) settlement of the storage pads and the Canister Transfer Facility (CTF) in HI-2188143, Revision 2, HI-STORE Bearing Capacity and Settlement Calculations. Provide details of the approach used in determining the required properties if not directly measured in the field or in the laboratory.

This information is necessary to determine compliance with 10 CFR 72.24(a), 72.103, and 72.122.

RAI 2-42-S-1: Justify the following assumptions regarding Report No. HI-2188143, Revision 1, HI-STORE Bearing Capacity and Settlement Calculations:

1) Justify whether a two-layer or a three-layer subsurface would be appropriate for estimating the bearing capacity and settlement (both immediate and long-term) of the storage pads and the Canister Transfer Facility (CTF). Update Table 5.3 of document HI-2188143 accordingly.

2) Provide details of the methods used to estimate the bearing capacity and the immediate and long-term settlements of the storage pads and the CTF.

3) Describe the approach selected to demonstrate that the maximum long-term settlement of the storage pads at the proposed HI-STORE facility would be bounded by the limiting maximum long-term settlement of the UMAX FSAR.

4) The HI-STORM UMAX FSAR considers a 5 x 5 array of vertical ventilated modules (VVMs) to determine the design long-term settlement (0.2 inch) of the storage pad; however, in the proposed CISF, each storage pad will have a 25 x 10 array of VVMs instead. Provide the rationale for whether the comparison should be at a 5 x 5 array of VVMs (proposed CISF represented by an equivalent 5 x 5 array) or the UMAX FSAR 5 x 5 VVMs array converted to an equivalent 25 x 10 VVMs array.

This information is necessary to determine compliance with 10 CFR 72.24, 72.103, and 72.122.

Safety Analysis Report (SAR), Chapter 5, Structural and Installation Evaluation RAI 5-27: Verify and describe in Section 1.0, Purpose, of Holtec Report No. HI-2210576, Rev.

0, Structural Analysis of HI-STORE Cask Transfer Building, if the CTB roof design considered wet load of concrete for the composite roof during construction.

If the corrugated steel is used as a form work, the wet concrete will deflect during pouring of the concrete while rebars are not bonded. The staff needs this information to confirm the roof slab will not fail during construction.