ML21288A540

Attachment 17: HI-STORM FW Amendment 7 Certificate of Compliance, Appendix B Reorganization Evaluation Form

ML21288A540
Person / Time
Site:	07201032
Issue date:	10/15/2021
From:	Holtec
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML21288A521	List: ML21288A522 ML21288A524 ML21288A525 ML21288A526 ML21288A528 ML21288A534 ML21288A535 ML21288A536 ML21288A537 ML21288A538 ML21288A539 ML21288A540 ML21288A542
References
5018091, CAC 001028, CoC No. 1032, EPID L2021-LLA-0053
Download: ML21288A540 (85)

Text

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 1 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes A2 Yes A3 Yes Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes The fuel specification requirements in the tables referenced in this TS are key to safe storage.

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes The fuel specification requirements in the tables referenced in this TS are key to safe storage.

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes The fuel specification requirements in the tables referenced in this TS are key to safe storage.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 2 of 85 Evaluation Summary Move to Appendix B Section 2. Applies generically to all three criteria (A1, A2, A3).

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 3 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls Yes Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes Placing the fuel in a safe condition is key to safe storage The possibility of a new or different kind of accident being created compared Yes Placing the fuel in a safe condition is key to safe storage

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 4 of 85 to those previously evaluated in the FSAR?

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes Placing the fuel in a safe condition is key to safe storage Evaluation Summary Move to Appendix B Section 4 as these are procedural and record keeping administrative controls. 2.2.1 specifies what must be done if the Fuel Specifications or Loading Conditions of 2.1 are violated. 2.2.2 and 2.2.3 give the administrative notification requirements to the NRC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 5 of 85 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 2.1-5 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 Yes The information in these figures is referenced in the Fuel Assembly Limits table to inform the reader of where damaged fuel assemblies or fuel debris stored in DFCs may be loaded in the MPC basket. The permitted locations of damaged and failed fuel assemblies inside MPCs are key features required to provide reasonable assurance that the cask safety functions of decay heat removal and shielding will be maintained.

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this A significant increase in the probability or consequences of an Yes

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 6 of 85 requirement from the CoC/TS result in accident previously evaluated in the cask FSAR?

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes Evaluation Summary Retain in Appendix B Section 2 as these figures 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.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 7 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes - The following items in Table 2.1-1 are required per Criterion A1 and shall be retained:

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 allowed per MPC (condition of spent fuel)

Neutron source assemblies and burnable poison rod assemblies (type of fuel)

A2 No A3 Yes (see evaluation summary below)

Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

A1 Items - Yes Other Items - No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 8 of 85 The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

A1 Items - Yes Other Items - No A Significant reduction in the margin of safety for ISFSI or cask operation?

A1 Items - Yes Other Items - No 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.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 9 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes - The following items in Table 2.1-2 are required per Criterion A1 and shall be retained:

Number of fuel rod locations (Type of spent fuel)

Number of guide and/or instrument tubes (Type of spent fuel)

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

A1 Items - Yes Other Items - No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

A1 Items - Yes Other Items - No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 10 of 85 A Significant reduction in the margin of safety for ISFSI or cask operation?

A1 Items - Yes Other Items - No 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.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 11 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes - The following items in Table 2.1-3 are required per Criterion A1 and shall be retained:

Maximum planar-average initial enrichment Number of fuel rod locations (Type of spent fuel)

Number of water rods (Type of spent fuel)

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

A1 Items - Yes Other Items - No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

A1 Items - Yes Other Items - No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 12 of 85 A Significant reduction in the margin of safety for ISFSI or cask operation?

A1 Items - Yes Other Items - No 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.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 13 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes This section provides information on maximum heat designed to be dissipated (10CFR72.236(a)).

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this A significant increase in the probability or consequences of an No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 14 of 85 requirement from the CoC/TS result in accident previously evaluated in the cask FSAR?

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes 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. 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)

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 15 of 85 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 and MPC-37P 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes These Tables provide information on maximum heat designed to be dissipated (10CFR72.236(a)).

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 16 of 85 to those previously evaluated in the FSAR?

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes 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. 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)

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 17 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 Yes A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes 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. In addition, the use of

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 18 of 85 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.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 19 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes These Tables provide information on maximum heat designed to be dissipated (10CFR72.236(a)).

A2 No A3 No L1 No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 20 of 85 Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes 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. 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)

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 21 of 85 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

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 22 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes These Figures provide information on maximum heat designed to be dissipated (10CFR72.236(a)).

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 23 of 85 Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes 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. 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)

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 24 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes This section provides information on burnup (10CFR72.236(a)).

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 25 of 85 Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes The margin to criticality during an accident could be 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)

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 26 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes This section provides information on burnup (10CFR72.236(a)).

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes The margin to criticality during an accident could be 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.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 27 of 85 Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on burnup and cooling time limits (72.236(a)). (Criterion A1)

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 28 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes This section provides information on burnup (10CFR72.236(a)).

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes The margin to criticality during an accident could be 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.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 29 of 85 Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on fuel assembly burnup (72.236(a)). (Criterion A1)

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 30 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

N/A The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

N/A A Significant reduction in the margin of safety for ISFSI or cask operation?

N/A 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)

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 31 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes This section provides information on the relationship between burnup and cooling time (maximum heat designed to be dissipated) for authorized fuel (10CFR72.236(a)).

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 32 of 85 Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes If the minimum cooling times are not met, the 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)

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 33 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes This section provides information on the relationship between burnup and cooling time (maximum heat designed to be dissipated) for authorized fuel (10CFR72.236(a)).

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes If the minimum cooling times are not met, the maximum heat value for a given MPC could be

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 34 of 85 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)

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 35 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes This section provides information on the relationship between burnup and cooling time (maximum heat designed to be dissipated) for authorized fuel (10CFR72.236(a)).

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 36 of 85 A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes If the minimum cooling times are not met, the 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)

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 37 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes This section provides information on the relationship between burnup and cooling time (maximum heat designed to be dissipated) for authorized fuel (10CFR72.236(a)).

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 38 of 85 A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes If the minimum cooling times are not met, the 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)

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 39 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 40 of 85 A Significant reduction in the margin of safety for ISFSI or cask operation?

No 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.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 41 of 85 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 Certified Design Section I. Technology No 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 of the reorganized format as they are important to acceptance testing related to criticality control.

Appendix A - Inspections, Tests, and Evaluations Yes Acceptance Testing for neutron absorber material is necessary for the cask to operate in conformance

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 42 of 85 with the certified design and fulfill its required safety functions.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

N/A The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

N/A A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes The margin of safety would be reduced or eliminated if the Metamic HT B-10 weight % and total Metamic radially surrounding the fuel assemblies is less than the requirements used in the criticality analysis.

Evaluation Summary Move to Appendix A - 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.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 43 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Items 1 Yes 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.

Item 4 - No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No L1 No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 44 of 85 Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

Items 1 Yes The margin of safety would be reduced if these 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.

Item 4 - No Evaluation Summary Move items 1-3 to 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.

Delete item 4 as this statement merely refers to NRC acceptance of the Holtec QA program manual under docket 71-0784. The Holtec QA program satisfies the requirements of 10 CFR 72 Subpart G. This statement can be removed from the CoC as compliance with the QA provisions in 10 CFR 72 Subpart G is a regulatory requirement that must be met.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 45 of 85 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 Certified Design Section I. Technology No Section II. Design Features Yes Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this A significant increase in the probability or consequences of an Second sentence - No Removal of this statement does not change any requirements for Holtec systems.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 46 of 85 requirement from the CoC/TS result in accident previously evaluated in the cask FSAR?

Rest of section - Yes If the ITS MPCs/Casks are not built in accordance with the ASME Code requirements, then the consequences of an accident might be significantly increased.

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Second sentence - No Removal of this statement does not change any requirements for Holtec systems.

A Significant reduction in the margin of safety for ISFSI or cask operation?

Second sentence - No Removal of this statement does not change any 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.

Move the rest of the section text to CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 47 of 85 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 Certified Design Section I. Technology No Section II. Design Features Yes Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 48 of 85 Evaluation Summary Retain in CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 49 of 85 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 Certified Design Section I. Technology No Section II. Design Features Yes Appendix A - Inspections, Tests, and Evaluations Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 50 of 85 Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

N/A The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

N/A A Significant reduction in the margin of safety for ISFSI or cask operation?

N/A Evaluation Summary Retain in CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 51 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes (see evaluation summary below)

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

N/A The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

N/A A Significant reduction in the margin of safety for ISFSI or cask operation?

N/A Evaluation Summary While this Table could potentially be removed without any risk impact, the removal could increase the need for cumbersome alternative code use

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 52 of 85 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.

Alternatively, it could be 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.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 53 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No. Removal of this Table does not change any requirements for Holtec systems.

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No. Removal of this Table does not change any requirements for Holtec systems.

A Significant reduction in the margin of safety for ISFSI or cask operation?

No. Removal of this Table does not change any requirements for Holtec systems.

Evaluation Summary Remove from CoC and Appendices. While the table is useful to more easily identify where a user must look

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 54 of 85 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.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 55 of 85 CoC Condition/TS Identifier: ___B-3.4(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 Section 3.4: Site Specific Parameters and Analyses that will require verification by the system user are, as a minimum, as follows:

1. The temperature of 80°F is the maximum average yearly temperature for the VENTILATED OVERPACK. The temperature of 70°F is the maximum average yearly temperature for the UNVENTILATED OVERPACK. A Sites yearly average ambient temperature may be used for site-specific analysis.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes This site-specific parameter of maximum ambient temperature will need to be validated against the key design criteria used and evaluated in the CoC cask design in the decay heat removal related FSAR sections.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement A significant increase in the probability or consequences of an accident previously No The consequences of the accident event would likely be greater but not significantly greater.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 56 of 85 from the CoC/TS result in evaluated in the cask FSAR?

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Move to Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation. A 72.212 evaluation by the General Licensee will perform written evaluations confirming that the site meets the terms, conditions, and specifications of the approved cask CoC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 57 of 85 CoC Condition/TS Identifier: ___B-3.4(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 Section 3.4: Site Specific Parameters and Analyses that will require verification by the system user are, as a minimum, as follows:

2. The allowed temperature extremes, averaged over a 3-day period, shall be greater than

-40o F and less than 125o F.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes This site-specific parameter of maximum extreme ambient temperature used for accident analyses will need to be validated against the key design criteria used and evaluated in the CoC cask design in the decay heat removal related FSAR sections.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The consequences of the accident event would likely be greater but not significantly greater.

The possibility of a new or different kind of accident No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 58 of 85 being created compared to those previously evaluated in the FSAR?

A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Move to Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation. A 72.212 evaluation by the General Licensee will perform written evaluations confirming that the site meets the terms, conditions, and specifications of the approved cask CoC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 59 of 85 CoC Condition/TS Identifier: ___B-3.4(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 Section 3.4: Site Specific Parameters and Analyses that will require verification by the system user are, as a minimum, as follows:

3.

a. For storage in a free-standing OVERPACK, the resultant horizontal acceleration (vectorial sum of two horizontal Zero Period Accelerations (ZPAs) at a three-dimensional seismic site), aH, and vertical ZPA, aV, on the top surface of the ISFSI pad, expressed as fractions of a, shall satisfy the following inequalities:

aH f (1 - aV); and aH r (1 - aV) / h where f is the Coulomb friction coefficient for the cask/ISFSI pad interface, r is the radius of the cask, and h is the height of the cask center-of-gravity above the ISFSI pad surface. Unless demonstrated by appropriate testing that a higher coefficient of friction value is appropriate for a specific ISFSI, the value used shall be 0.53. If acceleration time-histories on the ISFSI pad surface are available, aH and aV may be the coincident values of the instantaneous net horizontal and vertical accelerations. If instantaneous accelerations are used, the inequalities shall be evaluated at each time step in the acceleration time history over the total duration of the seismic event.

If this static equilibrium based inequality cannot be met, a dynamic analysis of the cask/ISFSI pad assemblage with appropriate recognition of soil/structure interaction effects shall be performed to ensure that the casks will not tip over or undergo

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 60 of 85 excessive sliding under the sites Design Basis Earthquake.

b. For a free-standing OVERPACK under environmental conditions that may degrade the pad/cask interface friction (such as due to icing) the response of the casks under the sites Design Basis Earthquake shall be established using the best estimate of the friction coefficient in an appropriate analysis model. The analysis should demonstrate that the earthquake will not result in cask tipover or cause excessive sliding such that impact between casks could occur. Any impact between casks should be considered an accident for which the maximum total deflection, d, in the active fuel region of the basket panels shall be limited by the following inequality: d 0.005 l, where I is the basket cell inside dimension.

c. For those ISFSI sites with design basis seismic acceleration values that may overturn or cause excessive sliding of free-standing casks, the anchored OVERPACK shall be utilized. Each OVERPACK shall be anchored with studs and compatible nuts of material suitable for the expected ISFSI environment. The embedment design shall comply with Appendix B of ACI-349-97. A later edition of this Code may be used, provided a written reconciliation is performed.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes The general licensee must perform an assessment to confirm that the site-specific seismic accelerations meet the cask seismic criteria applicable.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for L1 No L2 No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 61 of 85 Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes If the site-specific seismic parameters (ZPA levels) are greater than those analyzed for the cask design and no anchoring is used, this could result in a cask tip-over or sliding, which would be a significant increase in the consequences of a seismic accident.

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Move to Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation. A 72.212 evaluation by the General Licensee will perform written evaluations confirming that the site meets the terms, conditions, and specifications of the approved cask CoC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 62 of 85 CoC Condition/TS Identifier: ___B-3.4(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 Section 3.4: Site Specific Parameters and Analyses that will require verification by the system user are, as a minimum, as follows:

4. The maximum permitted depth of submergence under water shall not exceed 125 feet.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes It must be verified that the site-specific conditions are bounded by the enveloping design basis flood condition of 125 feet water height.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 63 of 85 A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Move to Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation. A 72.212 evaluation by the General Licensee will perform written evaluations confirming that the site meets the terms, conditions, and specifications of the approved cask CoC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 64 of 85 CoC Condition/TS Identifier: ___B-3.4(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 3.4: Site Specific Parameters and Analyses that will require verification by the system user are, as a minimum, as follows:

5. The maximum permissible velocity of floodwater, V, for a flood of height, h, shall be the lesser of V1 or V2, where:

V1 = (1.876 W*)1/2 / h V2 = (1.876 f W*/ D h)1/2 and W* is the apparent (buoyant weight) of the loaded overpack (in pounds force), D is the diameter of the overpack (in feet), and f is the interface coefficient of friction between the ISFSI pad and the overpack, as used in step 3.a above. Use the height of the overpack, H, if h>H.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes It must be verified that the site-specific flood water velocities meet the cask flood water design criteria considered in the FSAR.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this A significant increase in the probability or consequences of an No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 65 of 85 requirement from the CoC/TS result in accident previously evaluated in the cask FSAR?

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Move to Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation. A 72.212 evaluation by the General Licensee will perform written evaluations confirming that the site meets the terms, conditions, and specifications of the approved cask CoC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 66 of 85 CoC Condition/TS Identifier: ___B-3.4(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 Section 3.4: Site Specific Parameters and Analyses that will require verification by the system user are, as a minimum, as follows:

6. The potential for fire and explosion while handling a loaded OVERPACK or TRANSFER CASK shall be addressed, based on site-specific considerations. The user shall demonstrate that the site-specific potential for fire is bounded by the fire conditions analyzed by the Certificate Holder, or an analysis of the site-specific fire considerations shall be performed.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes It must be verified that the site-specific loadings resulting from potential fires and explosions meet the loadings resulting from potential fires and explosions considered in the FSAR.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement A significant increase in the probability or consequences of an accident previously No The consequences of the accident event would likely be greater but not significantly greater. 10 CFR 72 Subpart K requires Licensees to confirm that no

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 67 of 85 from the CoC/TS result in evaluated in the cask FSAR?

conditions exist near the ISFSI that would result in pressures due to off-site explosions which would exceed those postulated in the FSAR for tornadic missiles or wind effects.

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Move to Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation. A 72.212 evaluation by the General Licensee will perform written evaluations confirming that the site meets the terms, conditions, and specifications of the approved cask CoC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 68 of 85 CoC Condition/TS Identifier: ___B-3.4(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 Section 3.4: Site Specific Parameters and Analyses that will require verification by the system user are, as a minimum, as follows:

7.

a. For storage in a free-standing OVERPACK, the user shall demonstrate that the ISFSI pad parameters used in the non-mechanistic tipover analysis are bounding for the site or a site specific non-mechanistic tipover analysis shall be performed using the dynamic model described in FSAR Section 3.4. The maximum total deflection, d, in the active fuel region of the basket panels shall be limited by the following inequality: d 0.005 l, where l is basket cell inside dimension.

b. For storage in an anchored OVERPACK, a tipover event is not credible. However, the ISFSI pad shall be designed to meet the embedment requirements of the anchored design.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes The general licensee must perform an assessment to confirm that the site-specific ISFSI pad parameters meet the parameters considered for the ISFSI pad design in the FSAR.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

L1 No L2 No L3 No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 69 of 85 and Surveillance Requirements (SRs)

(Selection Criteria)

Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes If the site-specific parameters are not bound by those analyzed for the ISFSI design, this could result in a cask tip-over.

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Move to Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation. A 72.212 evaluation by the General Licensee will perform written evaluations confirming that the site meets the terms, conditions, and specifications of the approved cask CoC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 70 of 85 CoC Condition/TS Identifier: ___B-3.4(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 Section 3.4: Site Specific Parameters and Analyses that will require verification by the system user are, as a minimum, as follows:

8. In cases where engineered features (i.e.,

berms and shield walls) are used to ensure that the requirements of 10CFR72.104(a) are met, such features are to be considered important-to-safety and must be evaluated to determine the applicable quality assurance category.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes If supplemental site-specific shielding or engineered features are required to keep doses to any real individual located beyond the controlled area below the dose requirements in 10 CFR 72.104(a), then these features are considered ITS and must be designed and controlled accordingly.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement A significant increase in the probability or consequences of an accident previously No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 71 of 85 from the CoC/TS result in evaluated in the cask FSAR?

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes Since the site dose for an ISFSI is highly site specific, each licensee must perform a dose analysis in accordance with 10 CFR 72.212. The analysis should consider existing plant conditions, the site-specific arrangement of the ISFSI, the characteristics of the spent fuel to be placed in dry storage, and relevant empirical data as appropriate. The on-site dose analysis should demonstrate compliance with the 10 CFR 72.104(a) limits for normal conditions and 10 CFR 72.106 for accident conditions.

Evaluation Summary Move to Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation. A 72.212 evaluation by the General Licensee will perform written evaluations confirming that the site meets the terms, conditions, and specifications of the approved cask CoC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 72 of 85 CoC Condition/TS Identifier: ___B-3.4(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 Section 3.4: Site Specific Parameters and Analyses that will require verification by the system user are, as a minimum, as follows:

9. LOADING OPERATIONS, TRANSPORT OPERATIONS, and UNLOADING OPERATIONS shall only be conducted with working area ambient temperatures 0o F.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes This site-specific parameter of minimum ambient temperature will need to be validated against the key design criteria used and evaluated in the FSAR for the cask design.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The consequences of the accident event would likely be greater but not significantly greater.

The possibility of a new or different kind of accident being created compared No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 73 of 85 to those previously evaluated in the FSAR?

A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Move to Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation. A 72.212 evaluation by the General Licensee will perform written evaluations confirming that the site meets the terms, conditions, and specifications of the approved cask CoC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 74 of 85 CoC Condition/TS Identifier: ___B-3.4(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 Section 3.4: Site Specific Parameters and Analyses that will require verification by the system user are, as a minimum, as follows:

10. For those users whose site-specific design basis includes an event or events (e.g., flood) that result in the blockage of any OVERPACK inlet or outlet air ducts for an extended period of time (i.e, longer than the total Completion Time of LCO 3.1.2), an analysis or evaluation may be performed to demonstrate adequate heat removal is available for the duration of the event.

Adequate heat removal is defined as fuel cladding temperatures remaining below the short term temperature limit. If the analysis or evaluation is not performed, or if fuel cladding temperature limits are unable to be demonstrated by analysis or evaluation to remain below the short term temperature limit for the duration of the event, provisions shall be established to provide alternate means of cooling to accomplish this objective.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes Possible site-specific events causing vent blockages for an extended period of time must be evaluated.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

L1 No L2 No L3 No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 75 of 85 and Surveillance Requirements (SRs)

(Selection Criteria)

Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes The consequences of the accident event could be significantly increased if site-specific analysis is not performed for events that may result in blocked vents for an extended period of time and alternative means of cooling is not provided where necessary based on these evaluations.

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Move to Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation. A 72.212 evaluation by the General Licensee will perform written evaluations confirming that the site meets the terms, conditions, and specifications of the approved cask CoC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 76 of 85 CoC Condition/TS Identifier: ___B-3.4(11) _______

• 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 are, as a minimum, as follows:

11. Users shall establish procedural and/or mechanical barriers to ensure that during LOADING OPERATIONS and UNLOADING OPERATIONS, either the fuel cladding is covered by water, or the MPC is filled with an inert gas.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 77 of 85 to those previously evaluated in the FSAR?

A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Delete from CoC. The intent of this item is to limit possible oxidation of the fuel. It is mentioned elsewhere in the CoC (see LCO 3.1.1) that the dry MPC will be helium filled. Also, procedures in the FSAR already contain cautions that Inert gas must be used any time the fuel is not covered with water to prevent oxidation of the fuel cladding. The fuel cladding is not to be exposed to air at any time during loading operations. This caution applies to all sites and 10 CFR 72.150 requires that documented procedures be followed. Therefore, this item does not serve any safety purpose in the CoC and may be removed.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 78 of 85 CoC Condition/TS Identifier: ___B-3.4(12) _______

• 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 are, as a minimum, as follows:

12. The entire haul route shall be evaluated to ensure that the route can support the weight of the loaded system and its conveyance.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes The general licensee must perform an assessment to confirm that the site-specific haul route can support the equipment weights required for use of the HI-STORM System.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes If the haul route cannot be shown to adequately support the weights of the loading system and conveyance, there would be an increased probability of a drop or tipover of the cask.

The possibility of a new or different kind of accident being created compared No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 79 of 85 to those previously evaluated in the FSAR?

A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Move to Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation. A 72.212 evaluation by the General Licensee will perform written evaluations confirming that the site meets the terms, conditions, and specifications of the approved cask CoC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 80 of 85 CoC Condition/TS Identifier: ___B-3.4(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 Section 3.4: Site Specific Parameters and Analyses that will require verification by the system user are, as a minimum, as follows:

13. The loaded system and its conveyance shall be evaluated to ensure under the site specific Design Basis Earthquake the system does not tipover or slide off the haul route.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes The general licensee must perform an assessment to confirm that the site-specific seismic accelerations meet the seismic criteria applicable to the design of the casks and their conveyance.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes If the site-specific seismic parameters (ZPA levels) are greater than those analyzed for the cask and conveyance designs, this could result in a cask tip-over or sliding off the haul route, which would be a significant increase in the consequences of a seismic accident.

The possibility of a new or different kind of accident No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 81 of 85 being created compared to those previously evaluated in the FSAR?

A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Move to Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation. A 72.212 evaluation by the General Licensee will perform written evaluations confirming that the site meets the terms, conditions, and specifications of the approved cask CoC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 82 of 85 CoC Condition/TS Identifier: ___B-3.4(14) _______

• 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 are, as a minimum, as follows:

14. The HI-STORM FW/HI-TRAC VW stack which occurs during MPC TRANSFER shall be evaluated to ensure under the site specific Design Basis Earthquake the system does not tipover. A probabilistic risk assessment cannot be used to rule out the occurrence of the earthquake during MPC TRANSFER.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes The general licensee must perform an assessment to confirm that the site-specific seismic accelerations meet the seismic criteria applicable to the overpack/transfer cask stack-up configuration that occurs during transfer of the MPC.

Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement A significant increase in the probability or consequences of an accident previously Yes If the site-specific seismic parameters (ZPA levels) are greater than those analyzed for overpack/transfer cask stack-up configuration that occurs during transfer of the MPC, this could result in a cask tip-

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 83 of 85 from the CoC/TS result in evaluated in the cask FSAR?

over, which would be a significant increase in the consequences of a seismic accident.

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Move to Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation. A 72.212 evaluation by the General Licensee will perform written evaluations confirming that the site meets the terms, conditions, and specifications of the approved cask CoC.

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 84 of 85 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 Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls Yes Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes Unnoticed buildup of combustible gas could increase the probability or severity of a fire.

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes A combustible gas explosion could result. This would be an accident threatening occupational workers as well as possible loss of confinement.

A Significant reduction in the margin of safety for ISFSI or cask operation?

No

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 85 of 85 Evaluation Summary Move to 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. These controls prevent a potential explosion of combustible gas during establishment of the confinement boundary or purposeful breaching of the confinement boundary.

The explosion could affect confinement and shielding and functions and is a personnel safety item.