ML21126A296
| ML21126A296 | |
| Person / Time | |
|---|---|
| Site: | 07201032 |
| Issue date: | 05/06/2021 |
| From: | Holtec |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML21126A266 | List: |
| References | |
| 5018083 | |
| Download: ML21126A296 (58) | |
Text
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 Section 2.1: Fuel Specifications and Loading Conditions 2.1.1: Fuel to be Stored in the HI-STORM FW Storage System 2.1.2: 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 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Evaluation Summary Retain in Appendix B Section 2. Applies generically to all three criteria (A1, A2, A3).
Page 2 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: __B-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 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 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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 4 as these are procedural and record keeping administrative controls.
Page 4 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Fig. 2.1-1 through 2.1-5_______
- 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 Figures 2.1-1 through 2.1-4 illustrate the fuel loading regions and cell identifications for the applicable MPCs:
Figure 2.1-1: MPC-37 Region-Cell Identification Figure 2.1-2: MPC-89 Region-Cell Identification Figure 2.1-3: MPC-32ML Cell Identification Figure 2.1-4: MPC-37P Cell Identification Figure 2.1-5: MPC-44 Cell Identification 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 Yes 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 Yes from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 5 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A Significant reduction in Yes the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B Section 2 as these tables illustrate fuel loading information necessary to understand the information in other tables in this section. (Criterion A2) Specifically, discussions in other parts of the CoC (i.e. Table 2.1-1) refer to these figures when identifying permitted locations for storing DFCs. The permitted locations of damaged and failed fuel assemblies inside DFCs are key features required to provide reasonable assurance that the cask safety functions of decay heat removal and shielding will be maintained. The figures are also referred to in order to illustrate heat loading regions through the MPC.
Page 6 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: __B-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 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 - The following items in Table 2.1-1 are required Contents (Selection per Criterion A1 and shall be retained:
Criteria)
- Fuel (Type of spent fuel)
- Cladding type (Type of spent fuel)
- Enrichment
- Cooling time
- Burn-up
- Decay heat (heat designed to be dissipated)
- Damaged fuel assemblies or fuel debris Appendix B. allowed per MPC (condition of spent fuel)
Technical
- Neutron source assemblies and burnable Specifications poison rod assemblies (type of fuel)
A2 No A3 Yes (see evaluation summary below)
Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Risk Insight**: A significant increase in A1 Items - Yes Will removing the probability or Other Items - No this consequences of an requirement accident previously from the CoC/TS evaluated in the cask result in FSAR?
Page 7 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B The possibility of a new or A1 Items - Yes different kind of accident Other Items - No being created compared to those previously evaluated in the FSAR?
A Significant reduction in A1 Items - Yes the margin of safety for Other Items - No ISFSI or cask operation?
Evaluation Summary Retain A1 items identified above in CoC Appendix B Section 2.
The following characteristics will be eliminated from this table in the CoC and already exist in the FSAR (Tables 2.1.1a and 2.1.1b):
- Fuel assembly length
- Fuel assembly width If the Licensee has fuel that does not meet these characteristics that already exist in the FSAR, acceptability will be determined per 10 CFR 72.48.
Fuel assembly weight is a characteristic that would also not meet the Criteria A1 and A2 above. However, other CoC reorganization efforts have resulted in this characteristic being retained in the final approved CoC. Therefore, this characteristic could be said to meet Criterion A3 and will be retained in CoC Appendix B Section 2 with the rest of the retained information in this Table.
Page 8 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 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 - The following items in Table 2.1-2 are required Contents (Selection per Criterion A1 and shall be retained:
Criteria)
- Number of fuel rod locations (Type of spent fuel)
- Number of guide and/or instrument tubes (Type of spent fuel)
Appendix B.
A2 No Technical A3 No Specifications 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 A1 Items - Yes the probability or Other Items - No consequences of an Risk Insight**:
accident previously Will removing evaluated in the cask this FSAR?
requirement The possibility of a new or A1 Items - Yes from the CoC/TS different kind of accident Other Items - No result in being created compared to those previously evaluated in the FSAR?
Page 9 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A Significant reduction in A1 Items - Yes the margin of safety for Other Items - No ISFSI or cask operation?
Evaluation Summary Retain A1 items identified above in CoC Appendix B Section 2.
The following characteristics will be eliminated from this table in the CoC and already exist in the FSAR (Table 2.1.2):
- Fuel cladding inner and outer diameters
- Fuel pellet diameter
- Fuel rod pitch
- Active fuel length
- Guide and/or instrument tube thickness If the Licensee has fuel that does not meet these characteristics that already exist in the FSAR, acceptability will be determined per 10 CFR 72.48.
Page 10 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 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 - The following items in Table 2.1-3 are required Contents (Selection per Criterion A1 and shall be retained:
Criteria)
- Maximum planar-average initial enrichment
- Number of fuel rod locations (Type of spent fuel)
- Number of water rods (Type of spent fuel)
Appendix B.
A2 No Technical A3 No Specifications 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 A1 Items - Yes the probability or Other Items - No consequences of an Risk Insight**:
accident previously Will removing evaluated in the cask this FSAR?
requirement The possibility of a new or A1 Items - Yes from the CoC/TS different kind of accident Other Items - No result in being created compared to those previously evaluated in the FSAR?
Page 11 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A Significant reduction in A1 Items - Yes the margin of safety for Other Items - No ISFSI or cask operation?
Evaluation Summary Retain A1 items identified above in CoC Appendix B Section 2.
The following characteristics will be eliminated from this table in the CoC and already exist in the FSAR (Table 2.1.3):
- Fuel cladding inner and outer diameters
- Fuel pellet diameter
- Fuel rod pitch
- Active fuel length
- Water rod thickness
- Channel thickness If the Licensee has fuel that does not meet these characteristics that already exist in the FSAR, acceptability will be determined per 10 CFR 72.48.
Page 12 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-2.3 _______
- 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 Section 2.3: Decay Heat Limits 2.3.1: Fuel Loading Decay Heat Limits for VENTILATED OVERPACK 2.3.2: Fuel Loading Decay Heat Limits for UNVENTILATED OVERPACK 2.3.3: Variable Fuel Height for MPC-37, MPC-37P, and MPC-44 2.3.4: Variable Fuel Height for MPC-89 2.3.5: 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 This section provides information on maximum heat Criteria) designed to be dissipated (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Risk Insight**: A significant increase in No Will removing the probability or this consequences of an Page 13 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B requirement accident previously from the CoC/TS evaluated in the cask result in FSAR?
The possibility of a new or No different kind of accident being created compared to those previously evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify. In addition, the use of MPC/Overpack models with a limited heat load is necessary to limit the occupational dose.
Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on decay heat limits (72.236(a)).
(Criterion A1)
Page 14 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___ B-Tables 2.3-1 through 2.3-5_______
- 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:
Table 2.3-1A: MPC-37 Heat Load Data Table 2.3-1B: MPC-37 Heat Load Data Table 2.3-1C: MPC-37 Heat Load Data Table 2.3-2A: MPC-89 Heat Load Data Table 2.3-2B: MPC-89 Heat Load Data Table 2.3-3: MPC-37 Heat Load Data Table 2.3-4: MPC-89 Heat Load Data Table 2.3-5: MPC-32ML Heat Load Data 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 These Tables provide information on maximum heat Criteria) designed to be dissipated (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No 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 No result in different kind of accident being created compared Page 15 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B to those previously evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify. In addition, the use of MPC/Overpack models with a limited heat load is necessary to limit the occupational dose.
Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on decay heat limits (72.236(a)).
(Criterion A1)
Page 16 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.3-6 _______
- 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 Table 2.3-6: PWR Fuel Length Categories 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 No the probability or consequences of an accident previously evaluated in the cask FSAR?
Risk Insight**: The possibility of a new or No Will removing different kind of accident this being created compared requirement to those previously from the CoC/TS evaluated in the FSAR?
result in A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify. In addition, the use of Page 17 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B MPC/Overpack models with a limited heat load is necessary to limit the occupational dose.
The information in this fuel length category table is not directly a set of heat load limits or other parameter that falls under A1 in this evaluation.
However, the fuel length category informs which set of heat load limits apply to loading of a specific MPC.
Evaluation Summary Retain in Appendix B Section 2 as these tables illustrate fuel loading information necessary to understand the information in other tables in this section. (Criterion A2) Specifically, the information in this table informs the heat load limit loading patterns captured in Figures 2.3-1 through 2.3-9. The fuel length categories are necessary to understand the differences between the Figures and the heat load limits they contain.
Page 18 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Tables 2.3-7 through 2.3-13 _______
- 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:
Table 2.3-7A: MPC-37P Heat Load Data for Ventilated Overpack Table 2.3-7B: MPC-37P Heat Load Data for Ventilated Overpack Table 2.3-8A: MPC-44 Heat Load Data for Ventilated Overpack Table 2.3-8B: MPC-44 Heat Load Data for Ventilated Overpack Table 2.3-9A: MPC-37 Heat Load Data for Unventilated Overpack Table 2.3-9B: MPC-37 Requirements on Developing Regionalized Heat Load Patterns for Unventilated Overpack Table 2.3-10A: MPC-89 Heat Load Data for Unventilated Overpack Table 2.3-10B: MPC-89 Requirements on Developing Regionalized Heat Load Patterns for Unventilated Overpack Table 2.3-11: Section Heat Load Calculations for MPC-37 Table 2.3-12: Section Heat Load Calculations for MPC-89 Table 2.3-13: MPC-44 Heat Load Data for Unventilated Overpack 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 Appendix B.
Contents (Selection These Tables provide information on maximum heat Technical Criteria) designed to be dissipated (10CFR72.236(a)).
Specifications A2 No A3 No L1 No Page 19 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Section 3 Limiting L2 No Conditions for L3 No Operation (LCOs)*
and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask FSAR?
The possibility of a new or No Risk Insight**: different kind of accident Will removing being created compared this to those previously requirement evaluated in the FSAR?
from the CoC/TS A Significant reduction in Yes result in the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify. In addition, the use of MPC/Overpack models with a limited heat load is necessary to limit the occupational dose.
Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on decay heat limits (72.236(a)).
(Criterion A1)
Page 20 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: __B-Fig. 2.3-1 through 2.3-15_ _______
- 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:
Figure 2.3-1: Loading Pattern 37C1 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Short Fuel per Cell Heat Load Limits Figure 2.3-2: Loading Pattern 37C2 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, Short Fuel per Cell Heat Load Limits Figure 2.3-3: Loading Pattern 37C3 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Short Fuel per Cell Heat Load Limits Figure 2.3-4: Loading Pattern 37D1 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Standard Fuel per Cell Heat Load Figure 2.3-5: Loading Pattern 37D2 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, Standard Fuel per Cell Heat Load Limits Figure 2.3-6: Loading Pattern 37D3 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Standard Fuel per Cell Heat Load Limits Figure 2.3-7: Loading Pattern 37E1 for MPC-37 Loading Pattern for MPCs Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Long Fuel per Cell Heat Load Limits Figure 2.3-8: Loading Pattern 37E2 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, Long Fuel per Cell Heat Load Limits Page 21 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Figure 2.3-9: Loading Pattern 37E3 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Long Fuel per Cell Heat Load Limits Figure 2.3-10: Loading Pattern 89A1 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per Cell Heat Load Limits Figure 2.3-11: Loading Pattern 89A2 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per Cell Heat Load Limits Figure 2.3-12: Loading Pattern 89B1 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per cell Heat Load Limits Figure 2.3-13: Loading Pattern 89B2 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per Cell Heat Load Limits Figure 2.3-14: Loading Pattern 1 for MPC-37P Figure 2.3-15: Loading Pattern 2 for MPC-37P 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 These Figures provide information on maximum Criteria) heat designed to be dissipated (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Page 22 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A significant increase in No the probability or consequences of an accident previously evaluated in the cask FSAR?
The possibility of a new or No Risk Insight**: different kind of accident Will removing being created compared this to those previously requirement evaluated in the FSAR?
from the CoC/TS A Significant reduction in Yes result in the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify. In addition, the use of MPC/Overpack models with a limited heat load is necessary to limit the occupational dose.
Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)).
(Criterion A1)
Page 23 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-2.4 _______
- 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 Section 2.4: Burnup Credit Criticality control during loading of the MPC-37 is achieved through either meeting the soluble boron limits in LCO 3.3.1 OR verifying that the assemblies meet the minimum burnup requirements in Table 2.4-1.
For those spent fuel assemblies that need to meet the burnup requirements specified in Table 2.4-1, a burnup verification shall be performed in accordance with either Method A OR Method B described below.
Method A: Burnup Verification Through Quantitative Burnup Measurement Method B: Burnup Verification Through an Administrative Procedure and Qualitative Measurements 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 This section provides information on burnup Criteria) (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Page 24 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**: FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for The margin to criticality during an accident could be ISFSI or cask operation? impacted if neither the minimum burnup requirements specified in Table 2.4-1 nor the soluble boron limits from LCO 3.3.1 are met.
Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on burnup (72.236(a)).
(Criterion A1)
Page 25 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 Table 2.4-1: Polynomial Functions for the Minimum Burnup as a Function of Initial Enrichment 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 This section provides information on burnup Criteria) (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No 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 accident previously evaluated in the cask Risk Insight**: FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for The margin to criticality during an accident could be ISFSI or cask operation? impacted if neither the minimum burnup requirements specified in Table 2.4-1 nor the soluble boron limits from LCO 3.3.1 are met.
Page 26 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on burnup and cooling time limits (72.236(a)). (Criterion A1)
Page 27 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 Table 2.4-2: Burnup Credit Configurations 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 This section provides information on burnup Criteria) (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No 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 accident previously evaluated in the cask Risk Insight**: FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for The margin to criticality during an accident could be ISFSI or cask operation? impacted if neither the minimum burnup requirements specified in Table 2.4-1 nor the soluble boron limits from LCO 3.3.1 are met.
Page 28 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on fuel assembly burnup (72.236(a)). (Criterion A1)
Page 29 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 Table 2.4-3: In-Core Operating Requirements 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 Section 2 as this Table provides information such as fuel temperature during operation which is related to condition of the spent fuel at the time of storage (72.236(a)). (Criterion A1)
Page 30 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-2.5 _______
- 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 Section 2.5: Burnup and Cooling Time Qualification Requirements 2.5.1: Burnup and cooling time limits for fuel assemblies authorized for loading into the MPC-32ML are provided in Table 2.5-1. Burnup and cooling time limits for fuel assemblies authorized for loading according to only the alternative loading patterns shown in Figures 2.3-1 through 2.3-9 (MPC-37) and Figures 2.3-10 through 2.3-13 (MPC-89) are provided in Table 2.5-2 2.5.2: Burnup and cooling time limits for fuel assemblies authorized for loading into the MPC-37P and MPC-44 are provided in Table 2.5-3 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 This section provides information on the relationship Criteria) between burnup and cooling time (maximum heat designed to be dissipated) for authorized fuel (10CFR72.236(a)).
Appendix B. A2 No Technical A3 No Specifications Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Page 31 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A significant increase in No the probability or consequences of an accident previously evaluated in the cask FSAR?
The possibility of a new or No Risk Insight**: different kind of accident Will removing being created compared this to those previously requirement evaluated in the FSAR?
from the CoC/TS A Significant reduction in Yes result in the margin of safety for If the minimum cooling times are not met, the ISFSI or cask operation? maximum heat value for a given MPC could be exceeded. If the maximum heat value for a given MPC is higher than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify.
Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on burnup and cooling time limits (72.236(a)). (Criterion A1)
Page 32 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.5-1 _______
- 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 Table 2.5-1: Burnup and Cooling Time Fuel Qualification Requirements for MPC-32ML 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 This section provides information on the relationship Criteria) between burnup and cooling time (maximum heat designed to be dissipated) for authorized fuel (10CFR72.236(a)).
Appendix B. A2 No Technical A3 No Specifications 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 No the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or No 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 Yes the margin of safety for If the minimum cooling times are not met, the ISFSI or cask operation? maximum heat value for a given MPC could be Page 33 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B exceeded. If the maximum heat value for a given MPC is higher than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify.
Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on burnup and cooling time limits (72.236(a)). (Criterion A1)
Page 34 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.5-2 _______
- 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 Table 2.5-2: Burnup and Cooling Time Fuel Qualification Requirements for MPC-37 and MPC-89 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 This section provides information on the relationship Criteria) between burnup and cooling time (maximum heat designed to be dissipated) for authorized fuel (10CFR72.236(a)).
Appendix B. A2 No Technical A3 No Specifications 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 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 35 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A Significant reduction in Yes the margin of safety for If the minimum cooling times are not met, the ISFSI or cask operation? maximum heat value for a given MPC could be exceeded. If the maximum heat value for a given MPC is higher than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify.
Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on burnup and cooling time limits (72.236(a)). (Criterion A1)
Page 36 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.5-3 _______
- 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 Table 2.5-3: Burnup and Cooling Time Fuel Qualification Requirements for MPC-37P and MPC-44 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 This section provides information on the relationship Criteria) between burnup and cooling time (maximum heat designed to be dissipated) for authorized fuel (10CFR72.236(a)).
Appendix B. A2 No Technical A3 No Specifications 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 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 37 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A Significant reduction in Yes the margin of safety for If the minimum cooling times are not met, the ISFSI or cask operation? maximum heat value for a given MPC could be exceeded. If the maximum heat value for a given MPC is higher than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify.
Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on burnup and cooling time limits (72.236(a)). (Criterion A1)
Page 38 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 Section 3.1: Site 3.1.1: Site Location The HI-STORM FW 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 39 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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 40 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 Section 3.2: Design Features Important for Criticality Control 3.2.1 MPC-37
- 1. Minimum basket cell ID: 8.92 in. (nominal)
- 2. Minimum basket cell wall thickness: 0.57 in.
(nominal)
- 3. B4C in the Metamic-HT: 10.0 wt % (min.)
3.2.2 MPC-89
- 1. Minimum basket cell ID: 5.99 in. (nominal)
- 2. Minimum basket cell wall thickness: 0.38 in.
(nominal)
- 3. B4C in the Metamic-HT: 10.0 wt % (min.)
(3.2.3 is covered in next table) 3.2.4 MPC-32ML
- 1. Minimum basket cell ID: 9.53 (nominal)
- 2. Minimum basket cell wall thickness: 0.57 in (nominal)
- 3. B4C in the Metamic-HT: 10.0 wt % (min.)
3.2.5 MPC-37P
- 1. Minimum basket cell ID: 8.70 (nominal)
- 2. Minimum basket cell wall thickness: 0.77 in (nominal)
- 3. B4C in the Metamic-HT: 10.0 wt % (min.)
3.2.6 MPC-44
- 1. Minimum basket cell ID: 8.00 (nominal)
- 2. Minimum basket cell wall thickness: 0.49 in (nominal)
- 3. B4C in the Metamic-HT: 10.0 wt % (min.)
CoC Body Section I. Technology No Certified Design Section II. Design Features No These features are not general enough to incorporate into the CoC main body. They are only included in Appendix A as they are important to acceptance testing related to criticality control.
Appendix A - Inspections, Tests, and Yes Evaluations Acceptance Testing for neutron absorber material is necessary for the cask to operate in conformance Page 41 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B with the certified design and fulfill its required safety functions.
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 Retain in Appendix A - design features important to acceptance testing for neutron absorber material.
Page 42 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-3.2.3 _______
- 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 Section 3.2.3: Neutron Absorber Tests
- 1. The weight percentage of the boron carbide must be confirmed to be greater than or equal to 10% in each lot of Al/B4C powder.
- 2. The areal density of the B-10 isotope corresponding to the 10% min. weight density in the manufactured Metamic HT panels shall be independently confirmed by the neutron attenuation test method by testing at least one coupon from a randomly selected panel in each lot.
- 3. If the B-10 areal density criterion in the tested panels fails to meet the specific minimum, then the manufacturer has the option to reject the entire lot or to test a statistically significant number of panels and perform statistical analysis for acceptance.
- 4. All test procedures used in demonstrating compliance with the above requirements shall conform to the cask designers QA program which has been approved by the USNRC under docket number 71-0784.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Acceptance Testing for neutron absorber material is necessary for the cask to operate in conformance with the certified design and fulfill its required safety functions.
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 Page 43 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask FSAR?
Risk Insight**:
The possibility of a new or No Will removing different kind of accident this being created compared requirement to those previously from the CoC/TS evaluated in the FSAR?
result in A Significant reduction in Yes the margin of safety for The margin of safety would be reduced if these ISFSI or cask operation? neutron poison acceptance tests were not met. The results of the criticality analyses would be subject to question since assumptions underlying the analysis may no longer be valid.
Evaluation Summary Retain in Appendix A 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 44 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 Section 3.3: Codes and Standards The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 2007 Edition, is the governing Code for the HI-STORM FW System MPC as clarified in Specification 3.3.1 below, except for Code Sections V and IX. The ASME Code paragraphs applicable to the HI-STORM FW OVERPACK and TRANSFER CASK 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 2007 Edition, including any 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 Second sentence - No Will removing the probability or Removal of this statement does not change any this consequences of an requirements for Holtec systems.
Page 45 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B requirement accident previously Rest of section - Yes from the CoC/TS evaluated in the cask If the ITS MPCs/Casks are not built in accordance with result in FSAR? the ASME Code requirements, then the consequences of an accident might be significantly increased.
The possibility of a new or Second sentence - No different kind of accident Removal of this statement does not change any being created compared requirements for Holtec systems.
to those previously evaluated in the FSAR?
A Significant reduction in Second sentence - No the margin of safety for Removal of this statement does not change any ISFSI or cask operation? requirements for Holtec systems.
Rest of section - Yes The margin of safety could be reduced if these ITS MPCs are not built in accordance with the ASME Code requirements. Confinement safety function could be compromised.
Evaluation Summary Eliminate the second sentence The ASME Code paragraphs applicable to the HI-STORM FW OVERPACK and TRANSFER CASK are listed in Table 3-2 from the CoC. This information already exists in Table 1.2.6 of the FSAR.
Retain the rest of the section text in CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs.
Page 46 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 Section: Alternatives to Codes, Standards, and Criteria Table 3-1 lists approved alternatives to the ASME Code for the design of the MPCs of the HI-STORM FW 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 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 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Evaluation Summary Retain in CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs.
Page 48 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 Section 3.3.2: Construction/Fabrication Alternatives to Codes, Standards, and Criteria Proposed alternatives to the ASME Code,Section III, 2007 Edition, 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, 2007 Edition, 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 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 49 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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 50 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___ B-Table 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 Table 3-1: List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs)
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations (see evaluation summary below)
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 While this Table could potentially be removed without any risk impact, the removal could increase the need for cumbersome alternative code use Page 51 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B approval requests. Also, other CoC reorganization efforts have resulted in this table being retained in the final approved CoC. Therefore, this table will be retained in Appendix A.
It could be more appropriate to place this table in a separate Appendix. However, other Holtec CoCs contain more than two Appendices due to the complexity of these systems (see CoC-1014).
Therefore, to maintain consistent Appendix designations between various Holtec CoCs, this table will be retained in its own section at the end of CoC Appendix A.
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Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___ B-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 Table 3-2: Reference ASME Code Paragraphs for HI-STORM FW Overpack and HI-TRAC VW Transfer Cask, Primary Load Bearing Parts 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. Removal of this Table does not change any the probability or requirements for Holtec systems.
consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or No. Removal of this Table does not change any requirement different kind of accident requirements for Holtec systems.
from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in No. Removal of this Table does not change any the margin of safety for requirements for Holtec systems.
ISFSI or cask operation?
Evaluation Summary Remove from CoC and Appendices. While the table is useful to more easily identify where a user must look Page 53 of 58
Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B in the code to find the applicable paragraphs, it does not change which paragraphs/sections/requirements are applicable. This information already exists in Table 1.2.6 of the FSAR.
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Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 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?
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Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Evaluation Summary Retained in Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation.
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Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-3.5 _______
- 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 Section 3.5: 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 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 Yes the probability or Unnoticed buildup of combustible gas could increase consequences of an the probability of a fire.
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?
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Attachment 28 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A Significant reduction in No the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B Section 4, Administrative Controls, as these controls are necessary to assure that the operations involved in the storage of spent fuel and reactor-related GTCC waste in an ISFSI are performed in a safe manner.
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