ML18124A168
| ML18124A168 | |
| Person / Time | |
|---|---|
| Site: | 07201004 |
| Issue date: | 04/26/2018 |
| From: | TN Americas LLC |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| E-51306 | |
| Download: ML18124A168 (44) | |
Text
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 1 of 44 CoC Condition/TS Identifier: TS-5.1 (Form #55) Revision 3 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.1: Procedures (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)* and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls Yes, for the first paragraph, although the bulleted items are not necessary, per the Evaluation Summary at the end of this form.
Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 2 of 44 Requirement TS 5.1: Procedures (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary Procedures are required by § 72.150, Instructions, procedures, and drawings, as follows:
§ 72.150 Instructions, procedures, and drawings.
The licensee, applicant for a license, certificate holder, and applicant for a CoC shall prescribe activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall require that these instructions, procedures, and drawings be followed. The instructions, procedures, and drawings must include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
The first paragraph provides an overarching requirement that procedures of the nature described shall be generated. This paragraph will remain and will be in TS Section 4 Administrative Controls.
The bullet items listed in this TS are mostly specifically required to be part of the Subpart G Quality Assurance Program, or are required by other regulations, or are required by other TS.
Therefore these bullets serve no safety purpose, are redundant to other more direct requirements, and therefore they should be removed from TS and not relocated to anywhere.
The two paragraphs following the bullets, regarding the fuel removal procedure, are covered in generally the same language and details in the Operating Systems chapters of the UFSAR for each respective DSC. However, to ensure clarity, the language from these paragraphs which is not currently in the UFSAR is being added to each operating procedure chapter.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 3 of 44 CoC Condition/TS Identifier: TS-5.1.1 (Form #56) Revision 0 (no NRC questions - no changes made)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.1.1: DSC Loading, Unloading and Preparation Program (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 4 of 44 Requirement TS 5.1.1: DSC Loading, Unloading and Preparation Program (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary All of these provisions are covered by other TS or by regulation.
The program described in the first paragraph is generally required by § 72.150, Instructions, procedures, and drawings. The first paragraph refers to several TS and the UFSAR commitments.
The UFSAR operations chapters call out the TS related to operational steps. The TS themselves must be accounted for in procedures and complied with. Therefore this TS paragraph does not serve any safety purpose and can be removed from the licensing basis.
The second paragraph is redundant to TS 3.1.1.
The clear intent of TS 3.1.1 is to limit the oxidation of the fuel. The UFSAR operations chapters call out TS 3.1.1 for any water removal from the DSCs. Therefore this TS paragraph does not serve any safety purpose and can be removed from the licensing basis.
The activities that would be covered by the third paragraph are LCOs, which have as standard format the ACTIONS and COMPLETION TIMES.
Therefore this TS paragraph does not serve any safety purpose and can be removed from the licensing basis.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 5 of 44 CoC Condition/TS Identifier: TS-5.1.2 (Form #57) Revision 3 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.1.2: ISFSI Operations Program (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls Yes for TS 5.1.2 #2 Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 6 of 44 Requirement TS 5.1.2: ISFSI Operations Program (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary Item 1 is not really related to UFSAR ISFSI operations, but rather is a verification that TS 4.3.1 is met. TS 4.3.1 will be verified as an item in the Appendix A inspections, tests, and evaluations, and therefore TS 5.1.2 Item 1 serves no purpose and can be removed entirely from the licensing basis.
Item 2 is a verification that that the concrete storage pad parameters are consistent with the UFSAR analysis. This verification will be joined with the current TS 5.3.1 TC/DSC lifting and handling requirements in the new TS Section 4 Administrative Controls.
Item 3 is also not really related to UFSAR ISFSI operations, but rather is a verification that the maximum lifting heights for the cask system meet Technical Specification 5.3.1 requirements. TS 5.3.1 will be verified as an item in CoC Appendix A inspections, tests, and evaluations, and therefore TS 5.1.2 Item 3 serves no purpose and can be removed entirely from the licensing basis.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 7 of 44 CoC Condition/TS Identifier: TS-5.2 Programs -Introduction (Form #58) Revision 0 (no NRC questions - no changes made)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.2 Programs - Introduction Each user of the NUHOMS System will implement the following programs:
- 10 CFR 72.48 Evaluation Program
- Training Program
- Radiological Environmental Monitoring Program
- Radiation Protection Program
- HSM Thermal Monitoring Program CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)* and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls Yes, since it introduces the programs Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 8 of 44 Requirement TS 5.2 Programs - Introduction Each user of the NUHOMS System will implement the following programs:
- 10 CFR 72.48 Evaluation Program
- Training Program
- Radiological Environmental Monitoring Program
- Radiation Protection Program
- HSM Thermal Monitoring Program A Significant reduction in the margin of safety for ISFSI or cask operation?
No Evaluation Summary This introductory section will be retained in TS and will list the programs which remain in this section.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 9 of 44 CoC Condition/TS Identifier: TS-5.2.1 (Form #59) Revision 0 (no NRC questions - no changes made)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.2.1: 10 CFR 72.48 Evaluation Program (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 10 of 44 Requirement TS 5.2.1: 10 CFR 72.48 Evaluation Program (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary The provisions of this TS are entirely redundant to 10 CFR 72.48 and having them reiterated in the TS is not necessary to assure safe cask or ISFSI operation.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 11 of 44 CoC Condition/TS Identifier: TS-5.2.2 (Form #60) Revision 1 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.2.2: Training Program (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 12 of 44 Requirement TS 5.2.2: Training Program (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary As the TS states, training is required by Part 72.
The UFSAR has sections addressing training. The details of the specific training required represent the aspects for which licensees must develop procedures and therefore must train on. That detail more appropriately should be included in the UFSAR. No purpose is served by having that detail in the TS. Therefore, this TS can be removed.
UFSAR Section 9.3, Training Program, should be revised to incorporate applicable information from this TS.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 13 of 44 CoC Condition/TS Identifier: TS-5.2.3 (Form #61) Revision 3 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.2.3: Radiological Environmental Monitoring Program (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls Yes Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 14 of 44 Requirement TS 5.2.3: Radiological Environmental Monitoring Program (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary This TS establishes a program essentially the same as that required by 72.44(d)(2) for specific licenses. This TS shall be retained and moved to TS Section 4 Administrative Controls.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 15 of 44 CoC Condition/TS Identifier: TS-5.2.4 (introductory paragraph)
(Form #62) Revision 0 (no NRC questions - no changes made)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.2.4: Radiation Protection Program (introductory paragraph)
The Radiation Protection Program shall establish administrative controls to limit personnel exposure to As Low As Reasonably Achievable (ALARA) levels in accordance with 10 CFR Part 20 and Part 72.
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)* and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 16 of 44 Requirement TS 5.2.4: Radiation Protection Program (introductory paragraph)
The Radiation Protection Program shall establish administrative controls to limit personnel exposure to As Low As Reasonably Achievable (ALARA) levels in accordance with 10 CFR Part 20 and Part 72.
A Significant reduction in the margin of safety for ISFSI or cask operation?
No Evaluation Summary The introductory paragraph is totally redundant to Part 20 and Part 72, both of which define ALARA and require ALARA. Therefore this TS sentence is not needed and can be removed.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 17 of 44 CoC Condition/TS Identifier: TS-5.2.4.a (Form #63) Revision 0 (no NRC questions - no changes made)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.2.4 Item a): Radiation Protection Program -
topics dealing with remote handling devices, situations involving the OS197L transfer cask model, and liquid neutron shield draining.
(as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)* and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls Yes Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 18 of 44 Requirement TS 5.2.4 Item a): Radiation Protection Program -
topics dealing with remote handling devices, situations involving the OS197L transfer cask model, and liquid neutron shield draining.
(as currently listed in Proposed Amendment 15 TS)
A Significant reduction in the margin of safety for ISFSI or cask operation?
Yes, based on the importance of radiation safety and the unique nature of the OS197L design, if the requirements in this TS were not met a significant reduction in margin would potentially occur.
Evaluation Summary Based on risk insights, these TS requirements should remain in the CoC Appendix B TS Section 4 Administrative Controls under the Radiation Protection Program.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 19 of 44 CoC Condition/TS Identifier: TS-5.2.4.b (Form #64) Revision 4 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.2.4 Item b): Radiation Protection Program -
DSC Closure Weld NDE (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
Yes, potentially. This TS is only a verification of the confinement boundary multi-layered welds, but if the confinement boundary, which is a fission product barrier, is not ensured, consequences of a drop accident could potentially increase.
The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 20 of 44 Requirement TS 5.2.4 Item b): Radiation Protection Program -
DSC Closure Weld NDE (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary This item, regarding DSC closure weld NDE, is related to the confinement design function.
If these steps are not performed, the worst possible consequences would be that all of the multiple welds were flawed, the flaws line up to create a leak path, and therefore the multiple accidents involving the confinement boundary would involve a potential breach and a potential release of radionuclides, which would result in contamination and increased dose rates.
Based on the direct relationship of this TS to the confinement design function, which is a fission product barrier, this one-time verification TS item should remain, but is better suited to become an ITE.
Language regarding dye penetrant test and liquid penetrant test has been made consistent in the ITE to say liquid penetrant test.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 21 of 44 CoC Condition/TS Identifier: TS-5.2.4.c (Form #65) Revision 4 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.2.4 Item c): Radiation Protection Program -
Leak Test of DSC Inner Seal Weld (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)* and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
Yes, potentially. This TS is only a verification of the confinement boundary multi-layered welds, but if the confinement boundary, which is a fission product barrier, is not ensured, consequences of a drop accident could potentially increase.
The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 22 of 44 Requirement TS 5.2.4 Item c): Radiation Protection Program -
Leak Test of DSC Inner Seal Weld (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary This item, regarding leak testing of the DSC inner seal weld, is related to the confinement design function.
If this leak test is not performed, the worst possible consequences would be that all of the multiple welds were flawed, the flaws line up to create a leak path, the NDE of the welds was somehow not performed, and therefore the multiple accidents involving the confinement boundary would involve a potential breach and a potential release of radionuclides, which would result in contamination and increased dose rates.
Regardless of the very low risk, based on the direct relationship of this TS to the confinement design function, which is a fission product barrier, this one-time TS item should remain, but is better suited to become an ITE.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 23 of 44 CoC Condition/TS Identifier: TS-5.2.4.d (Form #66) Revision 4 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.2.4 Item d): Radiation Protection Program -
TC/DSC Contamination (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 Yes; this item is related to ensuring that radioactive contamination does not exceed limits prior to DSC storage in the HSM.
Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No increase in the probability of any accident.
Slight Increase in consequences due to increased dose from contamination, but not a significant increase.
The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 24 of 44 Requirement TS 5.2.4 Item d): Radiation Protection Program -
TC/DSC Contamination (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary In order to ensure that radioactive contamination does not exceed limits prior to DSC storage in the HSM, this item will be moved to TS Section 3 as an LCO. The TS Bases in UFSAR Chapter 10 will be updated as well.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 25 of 44 CoC Condition/TS Identifier: TS-5.2.4.e (Form #67) Revision 4 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.2.4 Item e): Radiation Protection Program -
TC Dose Rate Measurements (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No increase in the probability of any accident.
Increase in consequences of all accidents, due to increased dose from the TC, only if there was an area with reduced shielding. This TS is a verification and not an overt action involving an SSC that provides shielding.
The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No There would be a slight reduction in the margin of safety for the shielding design function, but only if an area of reduced shielding exists.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 26 of 44 Requirement TS 5.2.4 Item e): Radiation Protection Program -
TC Dose Rate Measurements (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary Based on the importance of this dose rate information in assessing worker dose and potentially identifying a misload, this item should be retained and is best suited to become an ITE.
Language regarding the timing of this LCO is made consistent and clear.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 27 of 44 CoC Condition/TS Identifier: TS-5.2.5 (Form #68) Revision 4 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.2.5: HSM or HSM-H Thermal Monitoring Program (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)* and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 Yes L3 No Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
Yes The probability of a blocked vent event may go undetected if not detected by inspection of the HSM inlet and outlet vents or monitoring of the DSC/HSM temperatures.
The consequences of a blocked undetected vent could cause the cladding temperatures in the DSC to exceed the 752 degrees F temperature limit (loss of confinement safety function) or cause degradation of the structural properties of the concrete HSM.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 28 of 44 Requirement TS 5.2.5: HSM or HSM-H Thermal Monitoring Program (as currently listed in Proposed Amendment 15 TS)
The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No Evaluation Summary The safety purpose of this program is to provide the licensee with a positive means to identify conditions which threaten to approach temperature criteria for proper HSM or HSM-H operation and allow for the correction of off-normal thermal conditions that could lead to exceeding the concrete and fuel clad temperature criteria.
The details of this TS include surveillances, requirements, conditions, and actions, and therefore it is better suited as an LCO.
The LCO CONDITIONS and REQUIRED ACTIONS are written to ensure that the system is returned to normal operating conditions.
The following aspects of the existing TS can be moved to the TS Bases chapter of the UFSAR:
This program shall monitor the thermal performance of each HSM daily, either by direct visual inspection or remote temperature measurement.
The program shall be of sufficient scope to provide the licensee with a positive means to identify conditions which threaten to approach temperature criteria for proper HSM or HSM-H operation and allow for the correction of off-normal thermal conditions that could lead to exceeding the concrete and fuel clad temperature criteria.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 29 of 44 CoC Condition/TS Identifier: TS-5.2.6 (Form #69) Revision 4 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.2.6: Hydrogen Gas Monitoring for 24P, 52B, 24PHB, 61BT, 32PT, 24PTH, 61BTH, 32PTH1, 69BTH, and 37PTH DSCs (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls Yes Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
Yes A hydrogen explosion could result from a hydrogen concentration exceeding the flammability limit -
an accident threatening occupational workers as well as possible loss of confinement.
A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 30 of 44 Requirement TS 5.2.6: Hydrogen Gas Monitoring for 24P, 52B, 24PHB, 61BT, 32PT, 24PTH, 61BTH, 32PTH1, 69BTH, and 37PTH DSCs (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary This TS prevents a potential hydrogen explosion during establishment of the confinement boundary or purposeful breaching of the confinement boundary. The explosion could affect the shielding function and is a personnel safety item. This TS should be retained and located in CoC Appendix B TS Section 4 Administrative Controls.
This TS is applicable to all DSC models so there is no reason to specify models.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 31 of 44 CoC Condition/TS Identifier: TS-5.3.1 (Form #70) Revision 4 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.3.1: TC/DSC Lifting/Handling Height Limits (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls Yes Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
Yes A significant reduction in the margin of safety for confinement is possible if there were no limit on the cask lifting and handling height (currently analyzed to 80 inches).
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 32 of 44 Requirement TS 5.3.1: TC/DSC Lifting/Handling Height Limits (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary This TS is associated with ensuring the confinement function. The TS contains evaluations of temperatures with resultant restrictions (impacting the ductility/brittleness of the cask materials) necessary to provide reasonable assurance that the cask safety function of confinement will be performed.
Therefore, this TS should be retained in (Section 4 of revised TS) Administrative Controls.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 33 of 44 CoC Condition/TS Identifier: TS-5.3.2 (Form #71) Revision 0 (no NRC questions - no changes made)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.3.2: Cask Drop (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 34 of 44 Requirement TS 5.3.2: Cask Drop (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary This TS requires an inspection of the cask/DSC after a drop height of greater than 15 inches. As explained in the details of this TS, the probability of a confinement breach due to a drop is essentially zero.
Based on the quality assurance program and its required corrective action program, a drop of an SSC as massive as the TS/DSC would without doubt receive a thorough investigation and inspection for damage.
Therefore, this TS can be removed and relocated to the UFSAR. The requirement for inspection if a drop occurs should become an operational step in the UFSAR operations chapters and the remainder of this TS should be included in the Confinement chapters if the information is not already included in those chapters.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 35 of 44 CoC Condition/TS Identifier: TS-5.3.3 (Form #72) Revision 1 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.3.3: TC Alignment with HSM or HSM-H (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 36 of 44 Requirement TS 5.3.3: TC Alignment with HSM or HSM-H (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary This TS provides the alignment tolerances for the transfer cask with respect to the horizontal storage module and is applicable during the insertion and retrieval operations. Those operations are detailed in UFSAR operations chapters (e.g., Chapter 5, Chapter K.8, Chapter M.8). This TS should be moved to those chapters of the UFSAR, including the actions to ensure proper alignment.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 37 of 44 CoC Condition/TS Identifier: TS-5.3.4 (Form #73) Revision 3 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.3.4: Trailer Shielding Drop onto OS197L TC The DSC and the OS197L TC and the trailer shielding shall be inspected for damage and evaluated for further use after the accident drop of the trailer shielding onto the OS197L TC.
The lifting of outer top trailer shielding is restricted such that the bottommost part of the body of the outer top trailer shielding is less than 4 inches above the inner top trailer shielding.
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls Yes Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 38 of 44 Requirement TS 5.3.4: Trailer Shielding Drop onto OS197L TC The DSC and the OS197L TC and the trailer shielding shall be inspected for damage and evaluated for further use after the accident drop of the trailer shielding onto the OS197L TC.
The lifting of outer top trailer shielding is restricted such that the bottommost part of the body of the outer top trailer shielding is less than 4 inches above the inner top trailer shielding.
The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
Yes A drop of the outer top trailer shielding could damage the TC. In addition, for radiation shielding purposes, to maintain dose to the occupational workers within acceptable levels, the top trailer shielding should be maintained just above the inner top trailer shielding.
Evaluation Summary These requirements are necessary for radiation protection and should remain in TS as Administrative Controls.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 39 of 44 CoC Condition/TS Identifier: TS-5.4 (Form #74) Revision 1 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.4: HSM or HSM-H Dose Rate Evaluation Program (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 40 of 44 Requirement TS 5.4: HSM or HSM-H Dose Rate Evaluation Program (as currently listed in Proposed Amendment 15 TS)
A Significant reduction in the margin of safety for ISFSI or cask operation?
Yes Failure of this SSC to provide adequate shielding could result in a significant reduction in the margin of safety for radiation shielding effectiveness and impact on worker and public dose.
Evaluation Summary This TS is a one-time measurement taken at locations on the exterior of the HSM or HSM-H that contributes to ensuring that the shielding design function has been established correctly.
Failure of the HSM to provide shielding could have a significant impact on worker and public health and safety.
Therefore, this TS should be retained. However, based on its one-time evaluation nature, it belongs in the CoC Appendix A ITE section.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 41 of 44 CoC Condition/TS Identifier: TS-5.5 (Form #75) Revision 0 (no NRC questions - no changes made)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.5: Concrete Testing for HSM-H (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes, performed by the CoC holder Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)* and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
Yes The consequences of the Blockage of Air Inlet and Outlet Openings could be significantly increased if the concrete fails at elevated temperatures.
The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 42 of 44 Requirement TS 5.5: Concrete Testing for HSM-H (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary This TS requires tests that are necessary to provide reasonable assurance that HSMs have been manufactured and will operate in conformance with the certified design and that the safety function of shielding will be performed.
This TS should remain but should be relocated to CoC Appendix A, Inspections, Tests, and Evaluations, to be performed by the CoC holder during fabrication.
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 43 of 44 CoC Condition/TS Identifier: TS-5.6 (Form #76) Revision 4 (changes made and tracked)
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),
and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?
Requirement TS 5.6: HSM-H Configuration Changes (as currently listed in Proposed Amendment 15 TS)
CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.
Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)
A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
L1 No L2 No L3 No Section 4 Administrative Controls Yes Risk Insight**:
Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No A Significant reduction in the margin of safety for ISFSI or cask operation?
No
E-51306 Enclosure 6 Evaluation Forms for CoC 1004 TS Section 5 Items Page 44 of 44 Requirement TS 5.6: HSM-H Configuration Changes (as currently listed in Proposed Amendment 15 TS)
Evaluation Summary The 8% limitation in TS 5.6 for configuration changes was a condition for acceptance of the analysis in a prior amendment. Therefore it must remain in the TS. It will be moved to new TS Section 4 for Administrative Controls.