ML23146A140

Attachment 1 - HI-STORM 100 Amendment 18 Responses to Requests for Additional Information

ML23146A140
Person / Time
Site:	Holtec
Issue date:	05/26/2023
From:	Holtec
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML23146A138	List: ML23146A139 ML23146A140 ML23146A141 ML23146A142
References
5014962
Download: ML23146A140 (1)

Text

Attachment 1 to Holtec Letter 5014962 HI-STORM 100 Amendment 18 Responses to Requests for Additional Information

RAI 4-1: Clarify in section 1.0.3.1 of the updatedfinal safety analysis report (UFSAR):

a. In step 2 the meaningof Site / Holtec.

b. In steps 2a and 2c that the second and third bullets, respectively, end the process for that fuel loading pattern. Also, in step 2d that the first sub-bullet ends the process for that fuel loading pattern. (see alsoobservation Th-3, Agencywide Documents Access and Management System (ADAMS) Accession No. ML22122A200)

c. In step 2a in the second bullet andin step 2d in the first sub-bullet that an application must be approved by the NRC.

d. The purpose of comparing the peak cladding temperature (PCT) instep 2b to the PCT in step 2c.

e. Whether there will be an additional step that includes all the 72.48 changes within the Invariant model, in addition to the new fuel loading pattern. (see also request for supplemental information (RSI) 4-2 and observations Th-2, and Th-4 (ML22122A200))

f. As referenced in step 3, provide an example of the sites qualification report, and also describe what is meant by, as appropriate; in addition, the staff notes that configuration-controlled qualification reports will be referenced inthe inspectable 72.212 report. Confirm that the Holtec Report No. HI-2200343-A Topical Report (TR)

(ML21302A147) evaluated loadingpattern is completely documentedin the sites configuration-controlled qualification report.

Regarding item a.above, it is not clear whether, Site / Holtec, means: 1) the site licensee and Holtec, 2) the site licensee or Holtec, or 3) the site licensee and/or Holtec. Additional clarification may be needed in figure 1.0.1, which states that the site (not site / Holtec) develops the candidate heat loadpattern. It is not clear whether the site andHoltec will work together because Holtec has the invariant thermal model referencedinthe Holtec Report No. HI-2200343-A TR safety evaluation (ML21216A181), the staff assumes Holtec would not provide the invariant thermal model to the site.

Regarding item b. above, it is not clear that the second and third bullets in steps 2aand 2c, respectively, and the first sub-bullet in step 2d ends the process for that fuel loading pattern.

The NRC staff notes that it is described in figure 1.0.1 step 2a that if the description in step 2a is not met, the process stops. (see also observation Th-3)

Regarding item c. above, it is not clear that the applicationmust be approved by the NRC, not only submitted to the NRC.

Regarding item d. above, the purposeof comparing the PCT in steps 2b and 2c is not clear; it is also not clear why the PCT is the only component temperaturebeing compared, why the PCT has to be higher in step 2c than instep 2b, and why the pressure isnt also compared.

See also item e., which could make the PCT, or any other comparison unnecessary.

Regarding item e. above, it is not clear whether there will be a step after step 2c, where all the 10 CFR 72.48 changes, including those made for any prior fuel loading patterns using the thermal TR, as well as the 10 CFR 72.48 changes associated with the new proposed fuel loading patternbeing evaluatedusing the thermal TR, will be included within the invariant model andthen evaluated usingthe thermal TR with the new proposed fuel loadingpattern.

This may have an impact on all subsequent steps (e.g., steps 2d and 3) in section 1.0.3.1 of the UFSAR. All of the 10 CFR 72.48 changes have to be incorporated in the invariant model along with the new proposed fuel loadingpattern to provide accuratetemperature and pressure results that are then evaluated usingthe thermal TR. (see also RSI 4-2 and observations Th-2, and Th-4)

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Regarding item f. above, an example of the qualification report has not been provided; however, this is important to safety considering that a configuration-controlled qualification report will have the heat load patternthat has been determinedto meet the acceptance criteria in the TR, which will then be used for loading operations, and is referenced in the 10 CFR72.212 report. The sites loadingpattern should be completely describedin the sites configuration-controlled qualification report that is referenced andinspectable through the 10 CFR 72.212 report.

This information is needed to determinecompliance with10 CFR 72.236(f).

Holtec Response:

a. Clarified that this was intended to be the general licensee and Holtec working together, since comparison to the proprietary model requires information from the general licensee on the as used configuration as well as Holtec proprietary information.

b. Added clarifications to each of those bullets that the topical report methodology cannot be used further.

c. Added clarification to steps 2a and steps 2d that the application must be approved by the NRC prior to use.

d. The PCT is used as an additional metric for comparison. The topical report clearly indicates the acceptance criteria for the loading patterns, which are temperatures and pressures. As an additional assurance for changes to the invariant model, the PCT of the heat load pattern in a model with 72.48 changes is compared to the PCT from the same heat load pattern in the invariant model to demonstrate that the invariant model is bounding.

e. Step 2b is intended to be this check, it has been clarified to indicate that the 72.48 model is intended to be the model of the canisters to be loaded with the candidate heat load pattern. This model includes all applicable 72.48 modifications along with the candidate heat load pattern.

f. Step 3 already includes the instruction for the general licensee to reference the qualification report in their 10CFR72.212 report, a suggestion was added to follow the example section of the topical report to write the qual ification report.

RAI 4-2: Explain and clarify the HI-STORM 100 technical specifications (TS) appendix A, SR 3.1.2 language, such that it is consistent with the language in sections 3.1.2, and 3.2.4.9 of the Holtec Report No. HI-2200343-A TR (ML21302A147).

The HI-STORM 100 TS appendix A, SR 3.1.2 states, For OVERPACKS with installed temperature monitoring equipment, verify that the difference between the average OVERPACK air outlet temperature and independent spent fuel storage installation (ISFSI) ambient temperature is < 155 °F for OVERPACKS containing pressurized water reactor (PWR) multipurpose canisters (MPCs), < 137 °F for OVERPACKS containing boiling water reactor (BWR) MPCs (except MPC-68M) and 164 °F for OVERPACKS containing MPC-68M. For sites that have loadedin accordance with the TR HI-2200343-A, verify that the difference between the averageOVERPACK air outlet temperature and ISFSI ambient temperature is less than or equal to the value computed using the topical report methodology.

Section 3.1.2 of the TR, item iii. (for the MPC-68M) states, For overpacks installed with temperature monitoring equipment, verify that the difference between the average overpack air outlet temperature and ISFSI ambient temperature is < 168 °F. The staff assumes 168

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°F was calculated basedon the difference betweenthe value of the averageair outlet temperature (248 °F) and the ISFSI ambient temperature (80 °F) from the example 1, table 3.1 of the TR. Similarly, section 3.2.4.9 of the TR, item iii. states, For overpacks installed with temperature monitoring equipment, verify that the difference between the average overpack air outlet temperature and ISFSI ambient temperature is < 191 °F. The staff also assumes 191 °F was calculated based on the difference betweenthe value of the average air outlet temperature (271 °F) and the ISFSI ambient temperature (80 °F) from the example 2, table 3.3 of the TR.

It is not clear based on the language in section 3.1.2of the TR, item iii. in combination with the language in the TS appendix A, SR 3.1.2, whether the calculated 168 °F replaces 164 °F for the MPC-68M in the TS appendix A, SR 3.1.2for that heat loadingpattern in example 1 of the TR because an MPC-68M was used in that example. This would then be recalculated for every fuel loading patternand the appropriatenumerical value in TS appendix A, SR 3.1.2 would be replaced based on the type of canister (PWR, BWR, or MPC-68M). Alternatively, because this is an example, andthere is no explicit part of the chapter 2 TR methodology that describes this calculation; therefore, the difference between the measured air outlet temperature and the ISFSI ambient temperature should be less than 164°F, as described for the MPC-68M in the TS appendix A SR 3.1.2. The staff notes that example 2 in the TR is also for an MPC-68M. There were no examples in the TR for PWR MPCs or BWR MPCs, excluding the MPC-68M.

This information is needed to d eterminecompliance with10 CFR 72.236(f).

Holtec Response:

As outlined in the examples in the topical report (for example, see Section 5.1.2, item iii), the intent was to follow the process in the topical report to calculate the appropriate temperature difference for the system based on the candidate heat load pattern. Accordingly, SR 3.1.2 has been updated to refer to the specific term used in the topical report (T), which is the difference between the average outlet air temperature and ambient air temperature. This parameter will be recalculated for every fuel loading pattern and the appropriate numerical value in the TS Appendix A, SR 3.1.2 would be replaced based on the type of canister.

RAI 4-3: Provide whether and how the 100 percent duct blockage of the HI-STORM 100 inlet vents temperature monitoring limit, as described in section 1.0.3.1, step 5 of the UFSAR, is calculated based onthe methodology in section 2.3.12 of the TR.

Section 1.0.3.1, step 5 of the UFSAR describes that the site ensures loading procedures have the accurate restrictions for duct blockage allowable clearance time or temperature monitoring limit and is further referred to the HI-2200343-A section 2.3.12. Part four of the response to RSI 4-4 (ML22122A200) addresses how the duct blockage clearance times are calculated in section 2.3.12 of the TR. However, section 2.3.12 of the TR does not address recalculation of the temperature monitoring limits.

Section 2.3.12 of the TR further states, A threshold heat load is defined for all MPCs in Section 4.6 of the HI-STORM 100 UFSAR [2] at or below which fuel and component temperatures remain below the UFSARprescribed temperature limits under a 30- day accident. The TR does not intend to modify these threshold total decay heats already established in the UFSAR and CoC. Therefore, 30-day 100% vent blockage accident is not included in the TR. The

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staff notes that section 11.2.13.4 of the UFSAR states, For an accident event that completely blocks the inlet or outlet air ducts of a cask with heat loads greater than the threshold heat load (Table 4.6.8a) at the time of occurrence for greater than the analyzed duration, a site-specific evaluation or analysis may be performed to demonstrate adequateheat removal for the duration of the event. See also, the RAI 8-1 that describes how the temperature limits from the UFSAR that are part of the TR acceptance criteria are not clear.

This information is needed to determinecompliance with10 CFR 72.236(f).

Holtec Response Holtec does not intend to modify the already established threshold heat loads for 30- day 100%

duct blockage accident event using the topical report methodology. The heat load patterns approved in HI-STORM 100 CoC for this event remains unchanged. This is also explained in Section 2.3.12 of the Thermal topical report and Note 1 of Table 2.1 in the TR.

RAI 4-4: Clarify in section 1.0.3.1 of the UFSAR how content changes that do anddo not appear in the CoC or TS, but do explicitly affect the thermal model would warrant a thermal review.

Section 1.0.3.1 of the UFSARdoes not address the issue of content changes that do appear in the TS, and/or the CoC, would result inan amendment request and a thermal review with justification, which would be provided by the applicant to demonstrate that the TR included in section 1.0.3.1 is valid for the content changes. Content changes that do not appear in the TS or CoC could alsonecessitate a thermal review. For example, changes inthe fuel assembly effective thermal conductivity, density, or specific heat for an existing approved content could affect the thermal model beyond changing the heat load pattern, and it is not clear from section of the UFSAR whether that content change wouldbe thermally reviewed inan amendment request. Therefore, specifying in broadterms within the implementation described in section 1.0.3.1 of the UFSAR how content changes would lead to a thermal review, would provide reasonableassurance that the implementationdescribed in section 1.0.3.1 is not obviating the needfor a thermal review.

This information is needed to determinecompliance with10 CFR 72.236(f).

Holtec Response

All proposed modifications to a system certified under 10 CFR Part 72 are subject to the provisions of 10 CFR 72.48. Therefore, any changes to any aspect of the CoC (including content) would need to go through the NRC review and approval process, prior to loading, with or without the topical report. Any changes to the FSAR related information (including content) would be reviewed under the 10CFR72.48 process as outlined in Section 1.0.3.1. For clarity, Section 1.0.3.1 has been updated to state that the process is for the system AND its contents.

RAI 4-5: Clarify the following in section 1.0.3.1 of the UFSAR:

a. How errors and uncertainties are accounted for in the TR change control process.

b. If current bounding temperature results inthe UFSAR are exceeded basedon the design changes or applicant-developedheat load patterns, that the UFSAR will be updated to reflect those results and the corresponding model description.

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Regarding item a. above, possible errors and uncertainties inthe thermal model should be considered inthe incorporation of design changes; examples of errors and uncertainties in computational fluid dynamics (CFD) simulations are provided in NUREG-2152, Computational Fluid Dynamics Best Practice Guidelines for Dry Cask Applications. This can be especially important when temperatures are close to the maximum allowablelimits.

Regarding item b. above, it is not clear in section 1.0.3.1 of the application if the bounding temperature results found inthe current UFSAR are exceeded that the temperature results and corresponding model description will be updated in the UFSAR.

This information is needed to determinecompliance with10 CFR 72.236(f).

Holtec Response

a. The errors and uncertainties are accounted for by adopting a mesh converged solution. A mesh sensitivity study was performed following the guidance in ASME V&V 20-2009 for the most bounding configuration i.e., MPC placed in the HI-TRAC. The grid convergence index (or GCI) was also calculated to evaluate the spatial discretization error. Converged mesh was adopted for all licensing basis calculations. The calculations and results are documented in Appendix N of Holtec Report 2043317. Further, Section 4.2 of NRCs SER on HI-STORM 100 CoC Amendment 9 provides a summary of this mesh sensitivity study.

b. As mentioned in Section 1.0.3.1 of the HI-STORM 100 FSAR, a site qualification report is prepared that documents candidate heat load pattern and associated thermal evaluations.

This report is then appropriately referenced in the general licensees 72.212 report.

RAI 4-6: Clarify in the HI-STORM 100 TS, appendix A, table 3-2a, for the MPC-68M, item iii, whether the helium backfill pressure limit will be calculated for the MPC-68M with a proposed heat load greater than 42.8 kW and up to 50 kW.

It is not clear from the HI-STORM 100 TS, appendix A, table 3-2a, for the MPC-68M, item iii whether the helium backfill pressure limit is calculated for the proposed heat loadlimit that is greater than 42.8 kW.

This information is needed to determinecompliance with10 CFR 72.236(f).

Holtec Response Initial helium backfill limits will be calculated for new heat load patterns developed in accordance with the Thermal Topical Report. This is irrespective of whether the total heat load of the new patterns is greater than 42.8kW or not. Section B 3.1.1 of Chapter 12 of HI-STORM 100 FSAR is revised to provide further clarity.

RAI 4-7: Address whether the friction factor used inthe TRs multiple thermal models is bounding for all applicable MPCs / fuel contents. Also clarify whether the concept of cyclic drying during vacuum drying was incorporatedin all of the TRs multiple thermal models.

In HI-STORM 100 Amendment No. 2 the concept of a friction factor not being bounding (see ML041250495) was raised after many MPC and fuel contents were approved. Because the TR uses invariant thermal models, it is not clear whether the friction factor concept seen in

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Amendment No. 2, and the concept of cyclic drying were alsoapplied to all of the thermal models.

This information is needed to determinecompliance with10 CFR 72.236(f).

Holtec Response Table 2.3 of the Thermal Topical Report (TR) provides the friction factors or axial flow resistance for both PWR and BWR fuel assemblies. These values are consistent with those adopted in thermal evaluations documented in the latest approved revisions of both HI-STORM 100 and HI-STORM FW FSARs. The 3D MPC thermal model adopted for the evaluations of cyclic drying operation is the same as that adopted for all other thermal evaluations. The same friction factors summarized in Table 2.3 of the TR are also adopted during cyclic drying.

RAI 4-8: Clarify how site elevation is addressed and its effects on fuel and component temperatures when using the TR.Section 4.4.4.3, Effects of Elevation, of the UFSAR describes the effects of elevation on PCT (that the reduced pressure also reduces the ventilation air flow, but the site ambient temperature also decreases, resulting in a net increasein PCT). It is not clear in the applicationhow elevation is addressed when using the TR.

This information is needed to determinecompliance with10 CFR 72.236(f).

Holtec Response Section 3.4.2 of the thermal topical report SE presents discussions related to screening criteria that have been developed to determine when additional calculations are needed. If the screening criteria defined in the TR are met when performing the long-term storage evaluation, then no other storage conditions, including the effect of site elevation, need to be considered.

However, even if one of the screening criteria is not met, all evaluations including effect of site elevation shall be performed.

Secti on 4.4.4.3 of HI-STORM 100 FSAR is revised to provide the above clarification.

Errors/Typos/Suggestions:

In section 1.0.3.1, step 2., change typical to topical.

In section 1.0.3.1, change system to HI-STORM 100 system (multiple occurrences).

In section 1.0.3.1, be specific regarding the TR that you are referring to for three occurrences (i.e., HI-2200343-A [1.0.7]) (e.g., in the sentence prior to the list of steps, in steps 2., 2a., and 2c.).

In figure 1.0.1, step 2., change invariant to invariant thermal model.

In section 1.0.3.1, step 4., and figure 1.0.1, step 4., change CoC restrictions to CoC requirements.

In figure 1.0.1, step 2c., if the intent is to be consistent with section 1.0.3.1, step 2c., add language to specify the, invariant thermal model.

In figure 1.0.1, step 2c., similar to step 2a., note that if the description in step 2c. is not met, the process stops. (see also RAI 4-1b. (ML22122A200))

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In figure 1.0.1, step 2d., similar to step 2a., note that if the description in step 2d. is not met, the process stops. (see also RAI 4-1b. (ML22122A200))

Page B 3.1.1-9, change, quantity of helium to helium backfill pressure limit to be consistent with the meaning in table 3-2 of appendix A of the TS, section 1.0.3.1, step 5, and section 2.3.6 of the TR.

In page B 3.1.2-4 of the UFSAR, HI-2200343 is still there. (see RSI typos / errors (ML22122A200))

In table 3-2a of appendix A of the TS, note 2 continues to refer to table 3-1; however, table 3-1 refers to all MPCs with no reference to the TR HI-2200343-A, Revision 2 methodology; whereas table 3-1a of appendix A of the TS refers to ventilated MPCs and includes a reference to the TR HI-2200343-A, Revision 2 methodology. (see RSI typos / errors (ML22122A200))

NRC staff suggests that Holtec provide the entire HI-STORM 100 Amendment No. 18 TS, not only page changes, for the staff to be in the best position to evaluate the proposed changes based on the staffs RSIs (ML22122A200) and RAIs.

Holtec Response

The edits have been made in accordance with the above suggestions. The full amendment 18 technical specifications are attached to the letter submitting these RAI responses.

RAI 6-1: Provide information to evaluatethe shieldingimplications of documented alternate decay heat load patterns and submit details for thoseupdated patterns or provide a generic shielding methodology for evaluation of any developed alternate decay heat loading patterns.

The NRCs staff reviewedthe information provided by the applicant and evaluated the changes requested in the application. The applicationconsisted of incorporation of the thermal methodology for developing and evaluating alternate decay heat load patterns for the HI-STORM 100 MPCs as described in TR HI-2200343-A.

The applicant confirmed in their response to RSIs (ML22245A103) that the decay heat limits and burn-up, enrichment andcooling time (BECT) limits are completely independent of each other, so no BECTs are derived from decay heat limits developed using the TR. Since there is no general provision for allowing for implementationof an alternate decay heat load pattern without prior NRC review andapproval of a shielding methodology, and that the applicant didnt provide supporting information to (a) evaluate shielding implications of any alternate decay heat load pattern or (b) provide a generic shielding methodology in this submittal to allow for development of alternatedecay heat loadpatterns without prior NRC review and approval, the NRC cannot make a regulatory determination.

The staff needs this information to determine the system shielding design compliance with 10 CFR72.236(d).

Holtec Response:

In terms of shielding analyses, and specifically the selection of BECT (Burnups, enrichments and cooling times) for the dose analysis, this Amendment 18 is predicated on the approach introduced in Amendment 16 of this CoC with no further changes proposed here. Approval of Amendment 16 is therefore a prerequisite of the approval of this Amendment 18 that introduces the Thermal TR. The reason, and the consequence of this, is explained further in the following

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paragraphs.

Initial connection between heat load limits and BECT limits.

Initially, the HI-STORM 100 FSAR included a close (numerical) connection between the heat load limits and the BECT limits for a given cell in the MPC -24, MPC -32 and MPC-68 (and their equivalent derivatives: MPC-24E/24EF, MPC -32F, M PC-68F/68FF). This was implemented through a polynomial function to calculate the burnup limit for the assembly in a given cell as a function of the heat load limit of that cell, and the enrichment of the assembly to be loaded into that cell. The coefficients for the polynomials were provided in a large set of tables, by assembly type and by cooling time (see for example FSAR Rev. 2, Table 2.1.28 and Table 2.1.29). When the MPC-68M was first introduced, this basket was treated the same as the MPC-68. This approach created a significant overhead when qualifying fuel assemblies for storage.

Additionally, the link between heat load limit and burnup limit is not considered necessary since both burnup and heat load of an assembly must be separately verified against the limits. The BECTs derived from the thermal loading patterns defined in the FSAR were then utilized to calculate the dose rates around casks, including those values reported in Chapter 5. Hence this links the BECTs closely to the heat load patterns in the FSAR, and therefore does not support any option to establish heat load patterns outside of the FSAR, such as those that can be generated using the thermal TR.

Amendment 16 Amendment 16 replaces the polynomials with a simple set of BECTs, applicable regardless of the heat load limit (See Proposed FSAR Rev. 21 ML21068A372, Table 2.1.28 and Table 2.1.29). Dose rate values reported in Chapter 5 were correspondingly updated using uniform loading with fuel according to these BECT limits. Due to the use of a uniform distribution of these BECTs in the dose analyses, the BECTs are applicable to any cell in a basket regardless of the heat load or heat load limit. This resolves the issue of the overhead of the loading qualification, since burnup limits no longer have to be calculated based on other parameters. It also removes the link between heat loads and BECTs, since BECT limits no longer depend on heat load limits. This now allows to define heat load limits without the need to consider the BECTs and vice versa. Of course, for any cell, an assembly needs to satisfy both heat load and BECT limits. There may be situations where, for a given cell, an assembly meets heat load limits but not BECT limits, or BECT limits and not heat load limits. In such a case, an assembly would not be qualified for that cell. This is then being considered in developing the correct loading plans for the casks and cells, and is not a principal safety issue, since loading plans must be developed so all limits are met.

Amendment 18 For amendment 18, it was decided that no changes to the BECT approach for shielding were to be submitted. This introduces certain limitations to the content that would be permitted for loading under this Amendment. Specifically, the BECT limits may not allow assemblies up to the maximum heat load that could be qualified through the use of the topical report. However, it does allow a much larger flexibility in developing loading patterns, they are no longer limited to the two-region regionalized patterns that were the only option before the introduction of the thermal TR. In that sense, it is considered a valuable improvement, even though it does not allow the full flexibility that could be introduced by the thermal TR. The natural complement to the thermal TR will be the shielding TR, currently under NRC review, which allows to establish BECTs based on dose limits, separately from the FSAR/CoC, in a similar fashion that the thermal TR allows the establishment of heat loads limits based on temperature limits. The current Amendment 18 is therefore the first step in a two-step process, but it already provides benefits of additional flexibility for loading patterns and loading plans, and should not require

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review BECTs and shielding analyses since they are not changed. This supported the decision to submit Amendment 18 that way, and not wait for the shielding topical report to be approved first.

In summary, no new dose calculations are performed or provided, since the existing dose calculations are valid for the BECT distribution over the basket locations they are defined for, and are independent of the decay heat limits of those basket locations.

RAI 8-1: Provideadditional information to clarify the component temperature limits for the followingMPCs:

• MPCs - 24/24E/24EF

• MPCs - 32/32F

• MPCs - 68/68F/68FF/68M

The applicationuses Holtec TR HI-2200343-A (ML21302A147) for the methodology and acceptance criteria for developing heat load patterns for each canister. Holtec TR HI-2200343-A table 2.1 is consistent with and references HI-STORM 100 UFSAR table 2.II.2.9 which is applicable to the following MPCs:

• MPC-32M

• Version 1 of the MPC-32

• Version 1 of the MPC-68

Holtec TR HI-2200343-A does not reference HI-STORM 100 UFSAR table 2.2.3which provides maximum component temperatures for the followingMPCs:

• MPC - 24/24E/24EF

• MPC - 32/32F

• MPC - 68/68F/68FF/68M

The staff notes that the MPC component temperatures including the MPC shell, lid, baseplate, and closure ring are 200 °F to 400 °F lower in HI-STORM 100 UFSAR table 2.2.3 compared to the temperature limit for Alloy X (used for the MPC shell, lid, baseplate, and closure ring) listed in HI-STORM 100 UFSAR table 2.II.2.9. It is not clear to the staff whether the application is consistent with the principal acceptance criteria listed in Holtec TR HI-2200343-A, section 1.0, which states that the, PCT (Peak Cladding Temperature) and component temperatures shall remain below their respective limits under all conditions of storage. See also ML21099A262, comment no. 1 because it refers to the HI-STORM 100, table 2.1 of the Holtec TR HI-2200343-A, and table 2.2.3 of the UFSAR. The response to comment no. 1 states, Proposed temperature limits of all components except fuel cladding inTable 2.1 of the TR are consistent with those in Table 2.2.3 and 2.II.2.9 of HI-STORM 100 Amendment 15 LAR.

However, table 2.1 of the Holtec TR HI-2200343-A was not updated to refer to table 2.2.3 of the UFSAR.

This information is needed to determine compliancewith 10 CFR 72.236(b).

Holtec Response:

The application for HI-STORM 100 Amd 18 uses the Topical Report HI-2200343-A for the acceptance criteria for development of heat load patterns. This acceptance criteria includes the temperatures listed in HI-2200343-A, Table 2.1. The SER for the topical report approves those

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acceptance criteria for the set of canisters listed in the limitations section of the SER. This application does not request to modify the topical report or request to use any other temperatures as acceptance criteria. All heat load patterns must meet the topical report approved acceptance criteria. Reference to specific acceptance criteria tables has been added to Section 1.0.3.1 for clarity.

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