ML19255E960
| ML19255E960 | |
| Person / Time | |
|---|---|
| Site: | 07201004 |
| Issue date: | 09/03/2019 |
| From: | Orano USA |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML19255E934 | List: |
| References | |
| E-54825 | |
| Download: ML19255E960 (12) | |
Text
E-54825 Enclosure 7 Evaluation Forms for CoC 1004 TS Section 3 Items Page 1 of 12 CoC Condition/TS Identifier: TS-3.0 (Form #21) 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 3.0 LCO and SR applicability 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 Yes L2 Yes L3 Yes 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 These LCO and SR applicability requirements are necessary to ensure that safety functions are maintained as described in the individual LCOs and SRs.
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 These LCO and SR applicability requirements are necessary to ensure that safety functions are maintained as described in the individual LCOs and SRs.
E-54825 Enclosure 7 Evaluation Forms for CoC 1004 TS Section 3 Items Page 2 of 12 Requirement TS 3.0 LCO and SR applicability Evaluation Summary These applicability items are standard information in TS LCO and SR sections. They therefore should remain. All three criteria (L1, L2, L3) are given a Yes response since this TS applies generically to all LCOs/SRs.
E-54825 Enclosure 7 Evaluation Forms for CoC 1004 TS Section 3 Items Page 3 of 12 CoC Condition/TS Identifier: TS-3.1.1 (Form #22) 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 3.1.1: DSC Bulkwater Removal Medium and Vacuum Drying Pressure 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?
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 This LCO ensures the integrity of the fission product barrier. Its removal would reduce the margin of safety for confinement.
E-54825 Enclosure 7 Evaluation Forms for CoC 1004 TS Section 3 Items Page 4 of 12 Requirement TS 3.1.1: DSC Bulkwater Removal Medium and Vacuum Drying Pressure Evaluation Summary This LCO ensures that oxidation of the fuel cladding does not occur, preserving the fuel cladding fission product barrier. Therefore this TS meets criterion L2 and should remain.
E-54825 Enclosure 7 Evaluation Forms for CoC 1004 TS Section 3 Items Page 5 of 12 CoC Condition/TS Identifier: TS-3.1.2 (Form #23) 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 3.1.2: DSC Helium Backfill Pressure 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?
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 This LCO ensures the integrity of the cladding fission product barrier. Its removal would reduce the margin of safety for confinement.
E-54825 Enclosure 7 Evaluation Forms for CoC 1004 TS Section 3 Items Page 6 of 12 Requirement TS 3.1.2: DSC Helium Backfill Pressure Evaluation Summary This LCO ensures an inert atmosphere around the fuel cladding, preserving the integrity of the fuel cladding fission product barrier. Therefore this TS meets criterion L2 and should remain.
E-54825 Enclosure 7 Evaluation Forms for CoC 1004 TS Section 3 Items Page 7 of 12 CoC Condition/TS Identifier: TS-3.1.3 (Form #24) 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 3.1.3: Time Limit for Completion of DSC Transfer (24PTH, 61BTH Type 2, 32PTH1, 69BTH, or 37PTH DSC only).
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?
No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No
E-54825 Enclosure 7 Evaluation Forms for CoC 1004 TS Section 3 Items Page 8 of 12 Requirement TS 3.1.3: Time Limit for Completion of DSC Transfer (24PTH, 61BTH Type 2, 32PTH1, 69BTH, or 37PTH DSC only).
A Significant reduction in the margin of safety for ISFSI or cask operation?
Yes This LCO ensures the integrity of the cladding fission product barrier. Its removal would reduce the margin of safety for confinement.
Evaluation Summary This LCO ensures fuel cladding temperatures remain below the 752°F limit for normal storage operations provided in NUREG-1536, Rev. 1, preserving the integrity of the fuel cladding fission product barrier. Therefore this TS meets criterion L2 and should remain.
E-54825 Enclosure 7 Evaluation Forms for CoC 1004 TS Section 3 Items Page 9 of 12 CoC Condition/TS Identifier: TS-3.1.4 (Form #25) 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 3.1.4: HSM Maximum Air Exit Temperature with a Loaded DSC 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 A Significant reduction in the margin of safety for ISFSI or cask operation?
Yes This LCO ensures the integrity of the cladding fission product barrier. Its removal would reduce the margin of safety for confinement.
E-54825 Enclosure 7 Evaluation Forms for CoC 1004 TS Section 3 Items Page 10 of 12 Requirement TS 3.1.4: HSM Maximum Air Exit Temperature with a Loaded DSC Evaluation Summary This LCO ensures that fuel cladding temperatures remain below the 752°F limit, preserving the integrity of the fuel cladding fission product barrier. This LCO also ensures that HSM concrete temperatures do not exceed limits, preserving the shielding, thermal, and structural functions.
Therefore this TS should remain. However, based on the one-time nature of this item, it best fits in the CoC Appendix A ITE requirements.
E-54825 Enclosure 7 Evaluation Forms for CoC 1004 TS Section 3 Items Page 11 of 12 CoC Condition/TS Identifier: TS-3.2.1 (Form #26) 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 3.2/3.2.1: Cask Criticality Control 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 criticality accident is significantly increased.
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 Loss of criticality control would cause a significant reduction in the margin of safety.
E-54825 Enclosure 7 Evaluation Forms for CoC 1004 TS Section 3 Items Page 12 of 12 Requirement TS 3.2/3.2.1: Cask Criticality Control Evaluation Summary This LCO ensures that a subcritical configuration is maintained. Therefore this TS meets criterion L2 and should remain.