ML21068A395
| ML21068A395 | |
| Person / Time | |
|---|---|
| Site: | Holtec |
| Issue date: | 03/09/2021 |
| From: | Holtec |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML21068A360 | List: |
| References | |
| 5014917, CoC No. 1014 | |
| Download: ML21068A395 (48) | |
Text
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-2.1_______
- 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 Appendix B-100U Section 2.1: Fuel Specifications and Loading Conditions 2.1.1: Fuel to be Stored In The HI-STORM SFSC System Model 100U 2.1.2: Uniform Fuel Loading 2.1.3: Regionalized Fuel Loading CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection A2 Yes Criteria) A3 Yes Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Page 1 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U Evaluation Summary Retain in Appendix B-100U Section 2. Applies generically to all three criteria (A1, A2, A3).
Page 2 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: __BU-2.2________
- 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 Appendix B-100U Section 2.2: Violations If any Fuel Specifications or Loading Conditions of 2.1 are violated, the following actions shall be completed:
2.2.1 The affected fuel assemblies shall be placed in a safe condition.
2.2.2 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, notify the NRC Operations Center.
2.2.3 Within 30 days, submit a special report which describes the cause of the violation, and actions taken to restore compliance and prevent recurrence.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative Yes Controls A significant increase in N/A the probability or Risk Insight**:
consequences of an Will removing accident previously this evaluated in the cask requirement FSAR?
from the CoC/TS The possibility of a new or N/A result in different kind of accident being created compared Page 3 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 4 as these are procedural and record keeping administrative controls.
Page 4 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-Fig. 2.1-1 through 2.1-4_______
- 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 Appendix B-100U Figures 2.1-1 through 2.1-4 illustrate the fuel loading regions for the applicable MPCs CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 Yes Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 2 as these tables illustrate fuel loading information necessary to Page 5 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U understand the information in other tables in this section. (Criterion A2)
Page 6 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: __BU-Table 2.1-1________
- 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 Appendix B-100U Table 2.1-1: Fuel Assembly Limits CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 2 as this Table provides information such as enrichment, cooling time, and assembly condition (72.236(a)). (Criterion A1)
Page 7 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-Table 2.1-2_______
- 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 Appendix B-100U Table 2.1-2: PWR Fuel Assembly Characteristics CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 2 as this Table provides information such as enrichment (72.236(a)).
(Criterion A1)
Page 8 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-Table 2.1-3_______
- 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 Appendix B-100U Table 2.1-3: BWR Fuel Assembly Characteristics CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 2 as this Table provides information such as enrichment (72.236(a)).
(Criterion A1)
Page 9 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-Table 2.1-4 _______
- 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 Appendix BU-100U Table 2.1-4: Non-Fuel Hardware Cooling and Average Burnup CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 Yes Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 2 as this Table provides cooling time and burnup for non-fuel hardware that may be loaded into MPCs with fuel assemblies to ensure subcriticality. (Criterion A2)
Page 10 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-2.4.1 _______
- 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 Appendix B-100U Section 2.4: Decay Heat, Burnup, and Cooling Time Limits for ZR-Clad Fuel This section provides the limits on ZR-clad fuel assembly decay heat, burnup, and cooling time for storage in the HI-STORM 100 System Model 100U.
The method to calculate the limits and verify compliance, including examples, is provided in Chapter 12 of the HI-STORM 100 FSAR.
2.4.1 Uniform Fuel Loading Decay Heat Limits for ZR-clad fuel Table 2.4-1 provides the maximum allowable decay heat per fuel storage location for ZR-clad fuel in uniform fuel loading for each MPC model.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Risk Insight**: A significant increase in N/A Will removing the probability or this consequences of an requirement accident previously Page 11 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U from the CoC/TS evaluated in the cask result in FSAR?
The possibility of a new or N/A different kind of accident being created compared to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 2 as this Section provides information on decay heat limits (72.236(a)).
(Criterion A1)
Page 12 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___ BU-Table 2.4-1_______
- 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 Appendix B-100U Table 2.4-1: Maximum Allowable Decay Heat per Fuel Storage Location (Uniform Loading, ZR-Clad)
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 2 as this Section provides information on decay heat limits (72.236(a)).
(Criterion A1)
Page 13 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: __BU-2.4.2_ _______
- 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 Appendix B-100U Section 2.4.2 Regionalized Fuel Loading Decay Heat Limits for ZR-Clad Fuel The maximum allowable decay heat per fuel storage location for intact or undamaged fuel assemblies in regionalized loading is determined using the following equations:
Q(X) = 2 x Q0 / (1 + Xy) y = 0.23 / X0.1 q2 = Q(X) / (n1 x X +n2) q1 = q2 x X Where:
Q0 = Maximum uniform storage MPC decay heat (34 kW)
X = Inner region to outer region assembly decay heat ratio (0.5 X 3) n1 = Number of storage locations in inner region from Table 2.4-2.
n2 = Number of storage locations in outer region from Table 2.4-2.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection A2 No Appendix B. Criteria) A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Page 14 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 2 as this Section provides information on decay heat limits (72.236(a)).
(Criterion A1)
Page 15 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-Table 2.4-2 _______
- 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 Appendix B-100U Table 2.4-2: Fuel Storage Regions per MPC CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 Yes Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B Section 2 as this table provides information on acceptable loading patterns for an MPC. (Criterion A2)
Page 16 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-2.4.3 _______
- 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 Appendix B-100U Section 2.4.3: Burnup Limits as a Function of Cooling Time for ZR-Clad Fuel The maximum allowable ZR-clad fuel assembly average burnup varies with the minimum required fuel assembly cooling time. Tables 2.4-3 and 2.4-4 provide for each MPC the allowable maximum burnup based on the assemblys particular cooling time.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an Risk Insight**:
accident previously Will removing evaluated in the cask this FSAR?
requirement The possibility of a new or N/A from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 17 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 2 as this Section provides information on decay heat limits (72.236(a)).
(Criterion A1)
Page 18 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: __BU-2.4.4_ _______
- 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 Appendix B-100U Section 2.4.4: When complying with the maximum fuel storage location decay heat limits, users must account for the decay heat from both the fuel assembly and any NON-FUEL HARDWARE, as applicable for the particular fuel storage location, to ensure the decay heat emitted by all contents in a storage location does not exceed the limit.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an Risk Insight**:
accident previously Will removing evaluated in the cask this FSAR?
requirement The possibility of a new or N/A from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 19 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 2 as this Section provides information on decay heat limits (72.236(a)).
(Criterion A1)
Page 20 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-Table 2.4-3 _______
- 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 Appendix B-100U Table 2.4-3: PWR Fuel Assembly Burnup and Cooling Time Limits (ZR Clad Fuel)
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 2 as this Section provides information on fuel assembly cooling time (72.236(a)). (Criterion A1)
Page 21 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-Table 2.4-4 _______
- 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 Appendix B-100U Table 2.4-4: BWR Fuel Assembly Burnup and Cooling Time Limits (ZR Clad Fuel)
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Page 22 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U Evaluation Summary Retain in Appendix B-100U Section 2 as this Section provides information on fuel assembly cooling time (72.236(a)). (Criterion A1)
Page 23 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-3.1 _______
- 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 Appendix BU-100U Section 3.1: Site 3.1.1: Site Location The HI-STORM 100 Cask System is authorized for general use by 10 CFR Part 50 license holders at various site locations under the provisions of 10 CFR 72, Subpart K.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an Risk Insight**:
accident previously Will removing evaluated in the cask this FSAR?
requirement The possibility of a new or No from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 24 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U A Significant reduction in No the margin of safety for ISFSI or cask operation?
Evaluation Summary Eliminate from CoC - not required as compliance with the QA provisions in 10 CFR 72 Subpart K is a regulatory requirement that must be met.
Page 25 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-3.2.1 through 3.2.7 _______
- 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 Appendix B-100 Section 3.2: Design Features Important for Criticality Control 3.2.1 MPC-24
- 1. Flux trap size: 1.09 in.
- 2. 10B loading in the neutron absorbers:
0.0267 g/cm2 (Boral) and 0.0223 g/cm2 (METAMIC) 3.2.2 MPC-68
- 1. Fuel cell pitch: 6.43 in.
- 2. 10B loading in the neutron absorbers:
0.0372 g/cm2 (Boral) and 0.0310 g/cm2 (METAMIC) 3.2.3 MPC-24E Flux trap size:
- i. Cells 3, 6, 19, and 22: 0.776 inch ii. All Other Cells: 1.076 inches 10B loading in the neutron absorbers:
0.0372 g/cm2 (Boral) and 0.0310 g/cm2 (METAMIC) 3.2.4 MPC-32
- 1. Fuel cell pitch: 9.158 inches
- 2. 10B loading in the neutron absorbers:
0.0372 g/cm2 (Boral) and 0.0310 g/cm2 (METAMIC) 3.2.5 Not Used DESIGN FEATURES 3.2 Design features Important for Criticality Control (contd) 3.2.6 Fuel spacers shall be sized to ensure that the active fuel region of intact fuel assemblies remains within the neutron poison region of the MPC basket with water in the MPC.
3.2.7 The B4C content in METAMIC shall be 33.0 wt.%.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Section 1 Definitions, Use No Appendix B.
and Application Technical A1 No Specifications A2 No Page 26 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U Section 2 Approved A3 No Contents (Selection Criteria)
Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix A-100U - important to criticality control Page 27 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-3.2.8 _______
- 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 Appendix B-100U Section 3.2.8: Neutron Absorber Tests Section 9.1.5.3 of the HI-STORM 100 FSAR is hereby incorporated by reference into the HI-STORM 100 CoC. The minimum 10B for the neutron absorber shall meet the minimum requirements for each MPC model specified in Sections 3.2.1 through 3.2.4 above.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an Risk Insight**:
accident previously Will removing evaluated in the cask this FSAR?
requirement The possibility of a new or N/A from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 28 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix A-100 as the described tests ensure the MPC has been manufactured and will operate in conformance with the certified design, and that the safety functions of confinement, sub-criticality and shielding will be performed.
Page 29 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-3.3 _______
- 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 Appendix B-100U Section 3.3: Codes and Standards The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 1995 Edition with Addenda through 1997, is the governing Code for the HI-STORM 100 System MPCs, OVERPACKs, and TRANSFER CASKs, as clarified in Specification 3.3.1 below, except for Code Sections V and IX. The ASME Code paragraphs applicable to the 100U VVM are listed in Table 3-2. The latest effective editions of ASME Code Sections V and IX, including addenda, may be used for activities governed by those sections, provided a written reconciliation of the later edition against the 1995 Edition, including addenda, is performed by the certificate holder. American Concrete Institute (ACI) 349-85 is the governing Code for plain concrete as clarified in Appendix 1.D of the Final Safety Analysis Report for the HI-STORM 100 Cask System.
CoC Body Section I. Technology No Certified Design Section II. Design Features Yes Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Risk Insight**: A significant increase in N/A Will removing the probability or Page 30 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U this consequences of an requirement accident previously from the CoC/TS evaluated in the cask result in FSAR?
The possibility of a new or N/A different kind of accident being created compared to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs.
Page 31 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-3.3.1 _______
- 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 Appendix B-100U Section: Alternatives to Codes, Standards, and Criteria Table 3-1 of Appendix B to CoC-1014 lists approved alternatives to the ASME Code for the design of the MPCs and TRANSFER CASKs of the HI-STORM 100U System.
CoC Body Section I. Technology No Certified Design Section II. Design Features Yes Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Page 32 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U Evaluation Summary Retain in CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs.
Page 33 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-3.3.2 _______
- 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 Appendix B-100U Section 3.3.2:
Construction/Fabrication Alternatives to Codes, Standards, and Criteria Proposed alternatives to the ASME Code, Sections II and III, 1995 Edition with Addenda through 1997 including modifications to the alternatives allowed by Specification 3.3.1 may be used on a case-specific basis when authorized by the Director of the Office of Nuclear Material Safety and Safeguards or designee.
The request for such alternative should demonstrate that:
- 1. The proposed alternatives would provide an acceptable level of quality and safety, or
- 2. Compliance with the specified requirements of the ASME Code,Section III, 1995 Edition with Addenda through 1997, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Requests for alternatives shall be submitted in accordance with 10 CFR 72.4.
CoC Body Section I. Technology No Certified Design Section II. Design Features Yes Appendix A - Inspections, Tests, and Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Appendix B. Contents (Selection A2 No Technical Criteria) A3 No Specifications Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Page 34 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs.
Page 35 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-3.4 _______
- 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 Appendix B-100U Section 3.4: Site Specific Parameters and Analyses that will require verification by the system user CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retained in Appendix A-100U as this includes key generic design criteria used by the CoC holder in the Page 36 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U cask design, which require general licensee evaluation.
Page 37 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___ BU-Table 3-2_______
- 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 Appendix B-100U Table 3-2: Applicable Code Paragraphs for Underground VVMs CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retained in Appendix A-100U Page 38 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-3.6 _______
- 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 Appendix B-100U Section 3.6: Forced Helium Dehydration System 3.6.1: System Description 3.6.2: Design Criteria 3.6.3: Fuel Cladding Temperature 3.6.4: Pressure Monitoring During FHD Malfunction CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Page 39 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U Evaluation Summary Retained in Appendix A-100U as this includes design features for equipment that is only needed under specified circumstances, unlike the main equipment for the system described in CoC Sections I and II.
Page 40 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-Table 3-3 _______
- 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 Appendix B-100U Table 3-3: Load Combinations for the Top Surface Pad, VVM Interface Pad, Support Foundation Pad, and the Retaining Wall per ACI-318 (2005)
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retained in Appendix A-100U Page 41 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-Table 3-4 _______
- 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 Appendix B-100U Table 3-4: Values of Principle Design Parameters for the Underground ISFSI CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retained in Appendix A-100U Page 42 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-3.8 _______
- 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 Appendix B-100U Section 3.8: Combustible Gas Monitoring During MPC Lid Welding and Cutting During MPC lid-to-shell welding and cutting operations, combustible gas monitoring of the space under the MPC lid is required, to ensure that there is no combustible mixture present.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Page 43 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U Evaluation Summary Retained in Appendix A-100U as these are monitoring requirements Page 44 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-3.9 _______
- 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 Appendix B-100U Section 3.9: Corrosion Mitigation Measures The HI-STORM 100U VVM CEC Container Shell and Bottom Plate shall be protected from corrosion damage due to the corrosivity of the surrounding environment using the following means CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an Risk Insight**:
accident previously Will removing evaluated in the cask this FSAR?
requirement The possibility of a new or N/A from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 45 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retained in Appendix A-100U as this includes design features for equipment that is only needed under specified circumstances, unlike the main equipment for the system described in CoC Sections I and II.
Page 46 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U CoC Condition/TS Identifier: ___BU-3.10 _______
- 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 Appendix B-100U Section 3.10: Periodic Corrosion Inspections for Underground Systems Visual Inspection UT Inspection Inspection Criteria CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Page 47 of 48
Attachment 33 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B-100U Evaluation Summary Retained in Appendix A-100U as these are inspection requirements Page 48 of 48