ML22028A381
| ML22028A381 | |
| Person / Time | |
|---|---|
| Site: | Holtec |
| Issue date: | 01/28/2022 |
| From: | Holtec |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML22028A371 | List: |
| References | |
| 5014939 | |
| Download: ML22028A381 (101) | |
Text
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-2.1_______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Section 2.1: Fuel Specifications and Loading Conditions 2.1.1: Fuel to be Stored In The HI-STORM 100 SFSC System 2.1.2: Uniform Fuel Loading 2.1.3: Regionalized Fuel Loading CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection A2 Yes Criteria) A3 Yes Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in Yes the probability or The fuel specification requirements in the tables consequences of an referenced in this TS are key to safe storage.
accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or Yes requirement different kind of accident The fuel specification requirements in the tables from the CoC/TS being created compared referenced in this TS are key to safe storage.
result in to those previously evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for The fuel specification requirements in the tables ISFSI or cask operation? referenced in this TS are key to safe storage.
Page 1 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Evaluation Summary Keep in Appendix B Section 2. Applies generically to all three criteria (A1, A2, A3).
Page 2 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: __B-2.2________
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Section 2.2: Violations If any Fuel Specifications or Loading Conditions of 2.1 are violated, the following actions shall be completed:
2.2.1 The affected fuel assemblies shall be placed in a safe condition.
2.2.2 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, notify the NRC Operations Center.
2.2.3 Within 30 days, submit a special report which describes the cause of the violation, and actions taken to restore compliance and prevent recurrence.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative Yes Controls A significant increase in Yes the probability or Placing the fuel in a safe condition is key to safe Risk Insight**:
consequences of an storage Will removing accident previously this evaluated in the cask requirement FSAR?
from the CoC/TS The possibility of a new or Yes result in different kind of accident Placing the fuel in a safe condition is key to safe being created compared storage Page 3 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B to those previously evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for Placing the fuel in a safe condition is key to safe ISFSI or cask operation? 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.
Page 4 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Fig. 2.1-1 through 2.1-4_______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Figures 2.1-1 through 2.1-4 illustrate the fuel loading regions for the applicable MPCs CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 Yes Criteria) 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 Appendix B.
provide reasonable assurance that the cask safety Technical functions of decay heat removal and shielding will be Specifications maintained.
A3 No Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in Yes the probability or Risk Insight**:
consequences of an Will removing accident previously this evaluated in the cask requirement FSAR?
from the CoC/TS The possibility of a new or Yes result in different kind of accident being created compared Page 5 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B to those previously evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for ISFSI or cask operation?
Evaluation Summary Keep in Appendix B Section 2 as these tables illustrate fuel loading information necessary to understand the information in other tables in this section. (Criterion A2) Specifically, discussions in other parts of the CoC (i.e. Table 2.1-1) refer to these figures when identifying permitted locations for storing DFCs. The permitted locations of damaged and failed fuel assemblies inside DFCs are key features required to provide reasonable assurance that the cask safety functions of decay heat removal and shielding will be maintained. The figures are also referred to in order to illustrate heat loading regions through the MPC.
Page 6 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: __B-Table 2.1-1________
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Table 2.1-1: Fuel Assembly Limits CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes - The following items in Table 2.1-1 are required Contents (Selection per Criterion A1 and shall be retained:
Criteria)
- Fuel (Type of spent fuel)
- Cladding type (Type of spent fuel)
- Enrichment
- Cooling time
- Burn-up
- Decay heat (heat designed to be dissipated)
- Damaged fuel assemblies or fuel debris Appendix B. allowed per MPC (condition of spent fuel)
Technical
- Neutron source assemblies and burnable Specifications poison rod assemblies (type of fuel)
A2 No A3 Yes (see evaluation summary below)
Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Risk Insight**: A significant increase in A1 Items - Yes Will removing the probability or Other Items - No this consequences of an requirement accident previously from the CoC/TS evaluated in the cask result in FSAR?
Page 7 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B The possibility of a new or A1 Items - Yes different kind of accident Other Items - No being created compared to those previously evaluated in the FSAR?
A Significant reduction in A1 Items - Yes the margin of safety for Other Items - No ISFSI or cask operation?
Evaluation Summary Keep 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 2.1.17 through 2.1.24)
- Fuel assembly length
- Fuel assembly width (Tables 2.1.3 and 2.1.4)
- Fuel cladding inner and outer diameters
- Fuel pellet diameter
- Fuel rod pitch
- Active fuel length If the Licensee has fuel that does not meet these characteristics that already exist in the FSAR, acceptability will be determined per 10 CFR 72.48.
Fuel assembly weight is a characteristic that would also not meet the Criteria A1 and A2 above. However, other CoC reorganization efforts have resulted in this characteristic being retained in the final approved CoC. Therefore, this characteristic could be said to meet Criterion A3 and will be retained in CoC Appendix B Section 2 with the rest of the retained information in this Table.
Page 8 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.1-2_______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Table 2.1-2: PWR Fuel Assembly Characteristics CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes - The following items in Table 2.1-2 are required Contents (Selection per Criterion A1 and shall be retained:
Criteria)
- Design Initial U (Type of spent fuel)
- Cladding type (Type of spent fuel)
- Enrichment
- Number of fuel rod locations (Type of spent fuel)
Appendix B.
- Number of guide and/or instrument tubes Technical (Type of spent fuel)
Specifications A2 No A3 No Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in A1 Items - Yes the probability or Other Items - No Risk Insight**:
consequences of an Will removing accident previously this evaluated in the cask requirement FSAR?
from the CoC/TS The possibility of a new or A1 Items - Yes result in different kind of accident Other Items - No being created compared Page 9 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B to those previously evaluated in the FSAR?
A Significant reduction in A1 Items - Yes the margin of safety for Other Items - No ISFSI or cask operation?
Evaluation Summary Keep 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 2.1.3 and 2.1.4):
- 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.
Table notes connected only to the removed characteristics were also removed (notes 1, 2, 6, and 8)
Page 10 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.1-3_______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Table 2.1-3: BWR Fuel Assembly Characteristics CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes - The following items in Table 2.1-2 are required Contents (Selection per Criterion A1 and shall be retained:
Criteria)
- Design Initial U (Type of spent fuel)
- Cladding type (Type of spent fuel)
- Enrichment (Planar-average and Rod)
- Number of fuel rod locations (Type of spent fuel)
Appendix B.
- Number of water rods (Type of spent fuel)
Technical Specifications A2 No A3 No Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in A1 Items - Yes the probability or Other Items - No consequences of an Risk Insight**:
accident previously Will removing evaluated in the cask this FSAR?
requirement The possibility of a new or A1 Items - Yes from the CoC/TS different kind of accident Other Items - No result in being created compared to those previously evaluated in the FSAR?
Page 11 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A Significant reduction in A1 Items - Yes the margin of safety for Other Items - No ISFSI or cask operation?
Evaluation Summary Keep 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.
Table notes connected only to the removed characteristics were also removed (notes 1 and 2)
Page 12 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.1-8 _______
- 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 Table 2.1-8: Non-Fuel Hardware Cooling and Average Burnup CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This Table provides information on maximum heat Criteria) designed to be dissipated (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**: FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible Page 13 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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 Keep in Appendix B Section 2 as this Table provides cooling time and burnup for approved content.
(Criterion A2)
Page 14 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: __B-Table 2.1-9_ _______
- 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 Table 2.1-9: Restrictions for Partial Gadolinium Credit in MPC-68M CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 Yes Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask FSAR?
Risk Insight**:
The possibility of a new or No Will removing different kind of accident this being created compared requirement to those previously from the CoC/TS evaluated in the FSAR?
result in A Significant reduction in Yes the margin of safety for ISFSI or cask operation? The margin to criticality during an accident could be impacted if neither the minimum burnup requirements nor the soluble boron limits from LCO 3.3.1 are met.
Page 15 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Evaluation Summary Keep in Appendix B Section 2 as this Table provides cooling time and burnup for approved content.
(Criterion A2)
Page 16 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 Section 2.4: Decay Heat Limits for ZR-Clad Fuel This section provides the limits on ZR-clad fuel assembly decay heat, burnup, and cooling time for storage in the HI-STORM 100 System. The method to calculate the limits and verify compliance, including examples, is provided in Chapter 12 of the HI-STORM 100 FSAR.
2.4.1: Uniform Fuel Loading Decay Heat Limits for ZR-clad fuel for VENTILATED OVERPACK Table 2.4-1 provides the maximum allowable decay heat per fuel storage location for ZR-clad fuel in uniform fuel loading for each MPC model.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This section provides information on maximum heat Criteria) designed to be dissipated (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Risk Insight**: A significant increase in No Will removing the probability or this consequences of an requirement accident previously Page 17 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B from the CoC/TS evaluated in the cask result in FSAR?
The possibility of a new or No different kind of accident being created compared to those previously evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify. In addition, the use of MPC/Overpack models with a limited heat load is necessary to limit the occupational dose.
Evaluation Summary Keep in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)). (Criterion A1)
Page 18 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___ B-Table 2.4-1_______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Table 2.4-1: Maximum Allowable Decay Heat per Fuel Storage Location (Uniform Loading, ZR-Clad)
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This Table provides information on maximum heat Criteria) designed to be dissipated (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**:
FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident Page 19 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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 Keep in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)). (Criterion A1)
Page 20 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: __B-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 Section 2.4.2 Regionalized Fuel Loading Decay Heat Limits for ZR-Clad Fuel for VENTILATED OVERPACK The maximum allowable decay heat per fuel storage location for intact or undamaged fuel assemblies in regionalized loading is determined using the following equations:
Q(X) = 2 x Q0 / (1 + Xy) y = 0.23 / X0.1 q2 = Q(X) / (n1 x X +n2) q1 = q2 x X Where:
Q0 = Maximum uniform storage MPC decay heat (34 kW)
X = Inner region to outer region assembly decay heat ratio (0.5 X 3) n1 = Number of storage locations in inner region from Table 2.4-2.
n2 = Number of storage locations in outer region from Table 2.4-2.
Allowable heat loads for Damaged Fuel and Fuel Debris in regionalized loading are shown in Table 2.4-5.
Optional loading patterns for MPC-68M are shown in Figures 2.4-1 through 2.4-4.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No Appendix B. and Application Technical Section 2 Approved A1 Yes Specifications Contents (Selection This provides information on maximum heat Criteria) designed to be dissipated (10CFR72.236(a)).
Page 21 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A2 No A3 No Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask FSAR?
The possibility of a new or No Risk Insight**: different kind of accident Will removing being created compared this to those previously requirement evaluated in the FSAR?
from the CoC/TS A Significant reduction in Yes result in the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify. In addition, the use of MPC/Overpack models with a limited heat load is necessary to limit the occupational dose.
Evaluation Summary Keep in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)). (Criterion A1)
Page 22 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.4-2 _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Table 2.4-2: Fuel Storage Regions per MPC CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 Yes Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask FSAR?
Risk Insight**: The possibility of a new or No Will removing different kind of accident this being created compared requirement to those previously from the CoC/TS evaluated in the FSAR?
result in A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify. In addition, the use of Page 23 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B MPC/Overpack models with a limited heat load is necessary to limit the occupational dose.
Evaluation Summary Keep in Appendix B Section 2 as this table provides information on acceptable loading patterns for an MPC. (Criterion A2)
Page 24 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.4-5 _______
- 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 Table 2.4-5: Allowable Heat Load for Damaged Fuel Assemblies and Fuel Debris under Regionalized Loading CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 Yes Criteria) This provides information on maximum heat designed to be dissipated (10CFR72.236(a)).
Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**:
FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident Page 25 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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 Keep in Appendix B Section 2 as this table provides information on acceptable loading patterns for an MPC. (Criterion A2)
Page 26 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 Section 2.4.3: Burnup Limits as a Function of Cooling Time for ZR-Clad Fuel for Ventilated Overpack The maximum allowable ZR-clad fuel assembly average burnup varies with the minimum required fuel assembly cooling time. Tables 2.4-3 and 2.4-4 provide for each MPC the allowable maximum burnup based on the assemblys particular cooling time.
2.4.3.1 Linear interpolation of burnups between cooling times is permitted. For example, the allowable burnup for a cooling time of 4.5 years may be interpolated between those burnups calculated for 4 year and 5 years.
2.4.3.2 Calculated burnup limits shall be rounded down to the nearest integer.
2.4.3.3 Calculated burnup limits greater than 68,200 MWD/MTU for PWR fuel and 65,000 MWD/MTU for BWR must be reduced to be equal to these values.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This section provides information on burnup Criteria) (10CFR72.236(a)).
Appendix B. A2 No Technical A3 No Specifications Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Page 27 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**: FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for The margin to criticality during an accident could be ISFSI or cask operation? impacted if neither the minimum burnup requirements nor the soluble boron limits from LCO 3.3.1 are met.
Evaluation Summary Keep in Appendix B Section 2 as this Section provides information on fuel assembly burnup and cooling time limits (72.236(a)). (Criterion A1)
Page 28 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: __B-2.4.4_ _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Section 2.4.4: When complying with the maximum fuel storage location decay heat limits, users must account for the decay heat from both the fuel assembly and any NON-FUEL HARDWARE, as applicable for the particular fuel storage location, to ensure the decay heat emitted by all contents in a storage location does not exceed the limit.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This provides information on maximum heat Criteria) designed to be dissipated (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or Risk Insight**:
consequences of an Will removing accident previously this evaluated in the cask requirement FSAR?
from the CoC/TS The possibility of a new or No result in different kind of accident being created compared Page 29 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B to those previously evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify. In addition, the use of MPC/Overpack models with a limited heat load is necessary to limit the occupational dose.
Evaluation Summary Keep in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)). (Criterion A1)
Page 30 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: __B-2.4.5_ _______
- 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 2.4.5: Fuel Loading Decay Heat Limits for Unventilated Overpack Tables 2.4-6a and 2.4-6b provide the maximum allowable decay heat per fuel storage location for MPC-68M in HI-STORM 100 Version UVH.
A minor deviation from the prescribed loading pattern in an MPCs permissible contents to allow one slightly thermally-discrepant fuel assembly per quadrant to be loaded as long as the peak cladding temperature for the MPC remains below the ISG-11 Rev 3 requirements is permitted for essential dry storage campaigns to support decommissioning.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This provides information on maximum heat Criteria) designed to be dissipated (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Risk Insight**: A significant increase in No Will removing the probability or this consequences of an Page 31 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B requirement accident previously from the CoC/TS evaluated in the cask result in FSAR?
The possibility of a new or No different kind of accident being created compared to those previously evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify. In addition, the use of MPC/Overpack models with a limited heat load is necessary to limit the occupational dose.
Evaluation Summary Keep in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)). (Criterion A1)
Page 32 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: __B-2.4.6_ _______
- 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 2.4.6: Burnup and Cooling Time Qualifications for the MPC-68M for Unventilated Overpack The burnup and cooling time for every fuel loaded into the MPC-68M must satisfy the following equation:
= 3 + 2 + +
where, Ct = Minimum cooling time (years),
Bu = Assembly-average burnup (MWd/mtU),
A, B, C, D = Polynomial coefficients listed in Table 2.4-9 CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This section provides information on the relationship Criteria) between burnup and cooling time (maximum heat designed to be dissipated) for authorized fuel (10CFR72.236(a)).
Appendix B. A2 No Technical A3 No Specifications Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Risk Insight**: A significant increase in No Will removing the probability or this consequences of an Page 33 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B requirement accident previously from the CoC/TS evaluated in the cask result in FSAR?
The possibility of a new or No different kind of accident being created compared to those previously evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the minimum cooling times are not met, the ISFSI or cask operation? maximum heat value for a given MPC could be exceeded. If the maximum heat value for a given MPC is higher than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible cladding rupture - would occur sooner than the limits currently specify.
Evaluation Summary Keep in Appendix B Section 2 as this Section provides information on burnup and cooling time (72.236(a)).
(Criterion A1)
Page 34 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.4-3 _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Table 2.4-3: PWR Fuel Assembly Burnup and Cooling Time Limits for Ventilated Overpack CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This section provides information on burnup Criteria) (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**: FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for The margin to criticality during an accident could be ISFSI or cask operation? impacted if neither the maximum burnup requirements nor the soluble boron limits from LCO 3.3.1 are met.
Page 35 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Evaluation Summary Keep in Appendix B Section 2 as this Section provides information on fuel assembly burnup and cooling time limits (72.236(a)). (Criterion A1)
Page 36 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.4-4 _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Table 2.4-4: BWR Fuel Assembly Burnup and Cooling Time Limits for Ventilated Overpack CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This section provides information on burnup Criteria) (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**: FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for The margin to criticality during an accident could be ISFSI or cask operation? impacted if neither the minimum burnup requirements nor the soluble boron limits from LCO 3.3.1 are met.
Page 37 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Evaluation Summary Keep in Appendix B Section 2 as this Section provides information on fuel assembly burnup and cooling time limits (72.236(a)). (Criterion A1)
Page 38 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.4-6a _______
- 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 2.4-6a: MPC-68M Heat Load Data for Unventilated Overpack CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This provides information on maximum heat Criteria) designed to be dissipated (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**: FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible Page 39 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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 Keep in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)). (Criterion A1)
Page 40 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.4-6b _______
- 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 2.4-6b: MPC-68M Requirements on Developing Regionalized Heat Load Patterns for Unventilated Overpack CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This provides information on maximum heat Criteria) designed to be dissipated (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**:
FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident Page 41 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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 Keep in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)). (Criterion A1)
Page 42 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.4-7 _______
- 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 Table 2.4-7: Section Heat Load Calculations for MPC-68M for Unventilated Overpack CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This provides information on maximum heat Criteria) designed to be dissipated (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**: FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident consequences - thermal overheating and possible Page 43 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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 Keep in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)). (Criterion A1)
Page 44 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.4-8 _______
- 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 Table 2.4-8: DFC and DFI Storage Locations with Heat Load penalties for MPC-68M for Unventilated Overpack CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This provides information on maximum heat Criteria) designed to be dissipated (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**:
FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident Page 45 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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 Keep in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)). (Criterion A1)
Page 46 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 2.4-9 _______
- 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 Table 2.4-9: Burnup and Cooling Time Fuel Qualification Requirements for MPC-68M for Unventilated Overpack CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This table provides information on burnup Criteria) (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or No requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for The margin to criticality during an accident could be ISFSI or cask operation? impacted if neither the minimum burnup Page 47 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B requirements nor the soluble boron limits from LCO 3.3.1 are met.
Evaluation Summary Keep in Appendix B Section 2 as this Section provides information on burnup and cooling time limits (72.236(a)). (Criterion A1)
Page 48 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: __B-Fig. 2.4-1 through 2.4-4_ _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Figures 2.4-1 through 2.4-4: QSHL through QSHL-4 Patterns Per Cell Allowable Heat Loads (kW) - MP68M.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 Yes Contents (Selection This provides information on maximum heat Criteria) designed to be dissipated (10CFR72.236(a)).
A2 No Appendix B. A3 No Technical Section 3 Limiting L1 No Specifications Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**:
FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat value for a given MPC is higher ISFSI or cask operation? than that analyzed in the design bases, then if a blockage of the vents were to occur, the accident Page 49 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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 Keep in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)). (Criterion A1)
Page 50 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-3.1 _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Section 3.1: Site 3.1.1: Site Location The HI-STORM 100 Cask System is authorized for general use by 10 CFR Part 50 license holders at various site locations under the provisions of 10 CFR 72, Subpart K.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an Risk Insight**:
accident previously Will removing evaluated in the cask this FSAR?
requirement The possibility of a new or No from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 51 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A Significant reduction in No the margin of safety for ISFSI or cask operation?
Evaluation Summary Eliminate from CoC - not required as compliance with the QA provisions in 10 CFR 72 Subpart K is a regulatory requirement that must be met.
Page 52 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-3.2 _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Section 3.2: Design Features Important for Criticality Control 3.2.1 MPC-24
- 1. Flux trap size: 1.09 in.
- 2. 10B loading in the neutron absorbers:
0.0267 g/cm2 (Boral) and 0.0223 g/cm2 (METAMIC) 3.2.2 MPC-68 and MPC-68FF
- 1. Fuel cell pitch: 6.43 in.
- 2. 10B loading in the neutron absorbers:
0.0372 g/cm2 (Boral) and 0.0310 g/cm2 (METAMIC) 3.2.3 MPC-68F
- 1. Fuel cell pitch: 6.43 in.
- 2. 10B loading in the Boral neutron absorbers:
0.01 g/cm2 3.2.4 MPC-24E and MPC-24EF
- 1. Flux trap size:
- i. Cells 3, 6, 19, and 22: 0.776 inch ii. All Other Cells: 1.076 inches
- 2. 10B loading in the neutron absorbers:
0.0372 g/cm2 (Boral) and 0.0310 g/cm2 (METAMIC) 3.2.5 MPC-32 and MPC-32F
- 1. Fuel cell pitch: 9.158 inches
- 2. 10B loading in the neutron absorbers:
0.0372 g/cm2 (Boral) and 0.0310 g/cm2 (METAMIC) 3.2.6 MPC-68M
- 1. Basket Cell wall thickness 0.4 in. (nom.)
- 2. B4C content in METAMIC-HT shall be 10 wt.
3.2.7 Fuel spacers shall be sized to ensure that the active fuel region of intact or undamaged fuel assemblies remains within the neutron poison region of the MPC basket with water in the MPC.
3.2.8 The B4C content in METAMIC shall be 33.0 wt.%.
Page 53 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Acceptance Testing for neutron absorber material is necessary for the cask to operate in conformance with the certified design and fulfill its required safety functions.
Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**: FSAR?
Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for The margin of safety would be reduced or eliminated ISFSI or cask operation? 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.
Page 54 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-3.2.9 _______
- 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 3.2.9: Neutron Absorber Tests Boral and Metamic Classic Section 9.1.5.3 of the HI-STORM 100 FSAR is hereby incorporated by reference into the HI-STORM 100 CoC. For each MPC model specified in Sections 3.2.1 through 3.2.5 above, the neutron absorber shall meet the minimum requirements for 10B areal density or B4C content, as applicable.
Metamic-HT (Section 3.2.6 above)
- 1. The weight percentage of the boron carbide must be confirmed to be greater than or equal to 10% in each lot of Al/B4C powder.
- 2. The areal density of the B-10 isotope corresponding to the 10% min. weight density in the manufactured Metamic-HT panels shall be independently confirmed by the neutron attenuation test method by testing at least one coupon from a randomly selected panel in each lot.
- 3. If the B-10 areal density criterion in the tested panels fails to meet the specific minimum, then the manufacturer has the option to reject the entire lot or to test a statistically significant number of panels and perform statistical analysis for acceptance.
- 4. All test procedures used in demonstrating compliance with the above requirements shall conform to the cask designers QA program which has been approved by the USNRC under docket number 71-0784.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Items 1 Yes Evaluations Acceptance Testing for neutron absorber material is necessary for the cask to operate in conformance with the certified design and fulfill its required safety functions.
Page 55 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Item 4 - No Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask FSAR?
The possibility of a new or No Risk Insight**:
different kind of accident Will removing being created compared this to those previously requirement evaluated in the FSAR?
from the CoC/TS A Significant reduction in Items 1 Yes result in the margin of safety for The margin of safety would be reduced if these ISFSI or cask operation? neutron poison acceptance tests were not met. The results of the criticality analyses would be subject to question since assumptions underlying the analysis may no longer be valid.
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.
Page 56 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-3.3 _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Section 3.3: Codes and Standards The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 1995 Edition with Addenda through 1997, is the governing Code for the HI-STORM 100 System MPCs, OVERPACKs, and TRANSFER CASKs, as clarified in Specification 3.3.1 below, except for Code Sections V and IX. The latest effective editions of ASME Code Sections V and IX, including addenda, may be used for activities governed by those sections, provided a written reconciliation of the later edition against the 1995 Edition, including addenda, is performed by the certificate holder. American Concrete Institute (ACI) 349-85 is the governing Code for plain concrete as clarified in Appendix 1.D of the Final Safety Analysis Report for the HI-STORM 100 Cask System.
CoC Body Section I. Technology No Certified Design Section II. Design Features Yes Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Risk Insight**: A significant increase in Yes - If the Dry Cask Storage System ITS SSCs are not Will removing the probability or built in accordance with these codes and standards, this consequences of an Page 57 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B requirement accident previously then the consequences of an accident might be from the CoC/TS evaluated in the cask significant increased.
result in FSAR?
The possibility of a new or No different kind of accident being created compared to those previously evaluated in the FSAR?
A Significant reduction in Yes - These codes and standards provide guidance on the margin of safety for establishing acceptable margins of safety for the Dry ISFSI or cask operation? Storge System SCCs.
Evaluation Summary Move to CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs.
Page 58 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-3.3.1 _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Section: Alternatives to Codes, Standards, and Criteria Table 3-1 lists approved alternatives to the ASME Code for the design of the MPCs, OVERPACKs, and TRANSFER CASKs of the HI-STORM 100 Cask System CoC Body Section I. Technology No Certified Design Section II. Design Features Yes Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or No requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
Page 59 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Evaluation Summary Move to CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs.
Page 60 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-3.3.2 _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Section 3.3.2: Construction/Fabrication Alternatives to Codes, Standards, and Criteria Proposed alternatives to the ASME Code, Sections II and III, 1995 Edition with Addenda through 1997 including modifications to the alternatives allowed by Specification 3.3.1 may be used on a case-specific basis when authorized by the Director of the Office of Nuclear Material Safety and Safeguards or designee.
The request for such alternative should demonstrate that:
- 1. The proposed alternatives would provide an acceptable level of quality and safety, or
- 2. Compliance with the specified requirements of the ASME Code,Section III, 1995 Edition with Addenda through 1997, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Requests for alternatives shall be submitted in accordance with 10 CFR 72.4.
CoC Body Section I. Technology No Certified Design Section II. Design Features Yes Appendix A - Inspections, Tests, and Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Appendix B. Contents (Selection A2 No Technical Criteria) A3 No Specifications Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Page 61 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or No requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
Evaluation Summary Move to CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs. Delete the following statement as it is not required because compliance with 10 CFR 72.4 is a regulatory requirement that must be met: Requests for alternatives shall be submitted in accordance with 10 CFR 72.4.
Page 62 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___ B-Table 3-1_______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Table 3-1: List of ASME Code Alternatives for HI-STORM 100 Cask System CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations (see evaluation summary below)
Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary While this Table could potentially be removed without any risk impact, the removal could increase the need for cumbersome alternative code use Page 63 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B approval requests. Therefore, this table will be moved to Appendix A.
Page 64 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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(1): Site Specific Parameters and Analyses:
- 1. The temperature of 80º 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.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations 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.
Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Risk Insight**: A significant increase in No Will removing the probability or The consequences of the accident event would likely this consequences of an be greater but not significantly greater.
requirement accident previously from the CoC/TS evaluated in the cask result in FSAR?
Page 65 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B The possibility of a new or No different kind of accident being created compared to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
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.
Page 66 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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(2): Site Specific Parameters and Analyses:
- 2. The allowed temperature extremes, averaged over a 3-day period, shall be greater than -
40º F and less than 125º F.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations 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.
Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or The consequences of the accident event would likely Risk Insight**:
consequences of an be greater but not significantly greater.
Will removing accident previously this evaluated in the cask requirement FSAR?
from the CoC/TS The possibility of a new or No result in different kind of accident being created compared Page 67 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
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.
Page 68 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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(3): Site Specific Parameters and Analyses:
3.
- a. For storage in freestanding OVERPACKs, the resultant horizontal acceleration (vectorial sum of two horizontal Zero Period Accelerations (ZPAs) at a three-dimensional seismic site), GH, and vertical ZPA, GV, on the top surface of the ISFSI pad, expressed as fractions of g, shall satisfy the following inequality:
GH + µGV µ where µ is either the Coulomb friction coefficient for the cask/ISFSI pad interface or the ratio r/h, where r is the radius of the cask and h is the height of the cask center-of-gravity above the ISFSI pad surface.
The above inequality must be met for both definitions of µ, but only applies to ISFSIs where the casks are deployed in a freestanding configuration. 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, GH and GV may be the coincident values of the instantaneous net horizontal and vertical accelerations. If instantaneous accelerations are used, the inequality 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 Page 69 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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 excessive sliding under the sites Design Basis Earthquake.
- b. For free-standing casks, 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 a cask to fall off the pad. In addition, impact between casks should be precluded, or should be considered an accident for which the maximum g-load experienced by the stored fuel shall be limited to 45 gs.
- c. For those ISFSI sites with design basis seismic acceleration values that may overturn or cause excessive sliding of free-standing casks, the OVERPACKs shall be anchored to the ISFSI pad. The site seismic characteristics and the anchorage system shall meet the following requirements:
- i. The site acceleration response spectra at the top of the ISFSI pad shall have ZPAs that meet the following inequalities:
GH 2.12 AND GV 1.5 Where:
GH is the vectorial sum of the two horizontal ZPAs at a three-dimensional seismic site (or the horizontal ZPA at a two-dimensional site) and GV is the vertical ZPA.
ii. Each HI-STORM 100 dry storage cask shall be anchored with twenty-eight Page 70 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B (28), 2-inch diameter studs and compatible nuts of material suitable for the expected ISFSI environment.
The studs shall meet the following requirements:
Yield Strength at Ambient Temperature: 80 ksi Ultimate Strength at Ambient Temperature: 125 ksi Initial Tensile Pre-Stress: 55 ksi AND 65 ksi NOTE: The above anchorage specifications are required for the seismic spectra defined in item 3.4.3.c.i.
Users may use fewer studs or those of different diameter to account for site-specific seismic spectra less severe than those specified above. 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.
iii. Embedment Concrete Compressive Strength: 4,000 psi at 28 days CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations The general licensee must perform an assessment to confirm that the site-specific seismic accelerations meet the cask seismic criteria applicable.
Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Risk Insight**: A significant increase in No Will removing the probability or Page 71 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B this consequences of an If the site-specific seismic parameters (ZPA levels) are requirement accident previously greater than those analyzed for the cask design and from the CoC/TS evaluated in the cask no anchoring is used, this could result in a cask tip-result in FSAR? over or sliding, which would be a significant increase in the consequences of a seismic accident.
The possibility of a new or No different kind of accident being created compared to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
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.
Page 72 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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(4): Site Specific Parameters and Analyses:
- 4. The analyzed flood condition of 15 fps water velocity and a height of 125 feet of water (full submergence of the loaded cask) are not exceeded.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations It must be verified that the site-specific conditions are bounded by the enveloping design basis flood condition of 15 fps water velocity and 125 feet water height.
Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or Risk Insight**:
consequences of an Will removing accident previously this evaluated in the cask requirement FSAR?
from the CoC/TS The possibility of a new or No result in different kind of accident being created compared Page 73 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
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.
Page 74 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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(5): Site Specific Parameters and Analyses:
- 5. 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations 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.
Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No Risk Insight**:
the probability or The consequences of the accident event would likely Will removing consequences of an be greater but not significantly greater. 10 CFR 72 this accident previously Subpart K requires Licensees to confirm that no requirement conditions exist near the ISFSI that would result in Page 75 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B from the CoC/TS evaluated in the cask pressures due to off-site explosions which would result in FSAR? exceed those postulated in the FSAR for tornadic missiles or wind effects.
The possibility of a new or No different kind of accident being created compared to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
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.
Page 76 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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(6): Site Specific Parameters and Analyses:
6.
- a. For freestanding casks, the ISFSI pad shall be verified by analysis to limit cask deceleration during design basis drop and non-mechanistic tip-over events to 45 gs at the top of the MPC fuel basket.
Analyses shall be performed using methodologies consistent with those described in the HI-STORM 100 FSAR. A restriction on the lift and/or drop height is not required if the cask is lifted with a device designed in accordance with applicable stress limits from ANSI N14.6, and/or NUREG-0612, and has redundant drop protection features.
- b. For anchored casks, the ISFSI pad shall be designed to meet the embedment requirements of the anchorage design. A cask tip-over event for an anchored cask is not credible. The ISFSI pad shall be verified by analysis to limit cask deceleration during a design basis drop event to 45 gs at the top of the MPC fuel basket, except as provided for in this paragraph below. Analyses shall be performed using methodologies consistent with those described in the HI-STORM 100 FSAR. A restriction on the lift and/or drop height is not required to be established if the cask is lifted with a device designed in accordance with applicable stress limits from ANSI N14.6, and/or NUREG-0612, and has redundant drop protection features.
Section I. Technology No Page 77 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Body Section II. Design Features No Certified Design Appendix A - Inspections, Tests, and Yes Evaluations 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.
Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or If the site-specific parameters are not bound by those consequences of an analyzed for the ISFSI design, this could result in a accident previously cask tip-over.
Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or No requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
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.
Page 78 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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(7): Site Specific Parameters and Analyses:
- 7. 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations 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.
Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls Risk Insight**: A significant increase in No Will removing the probability or this consequences of an requirement accident previously Page 79 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B from the CoC/TS evaluated in the cask result in FSAR?
The possibility of a new or No different kind of accident being created compared to those previously evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for Since the site dose for an ISFSI is highly site specific, ISFSI or cask operation? 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.
Page 80 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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(8): Site Specific Parameters and Analyses:
- 8. LOADING OPERATIONS, OVERPACK TRANSPORT OPERATIONS, and UNLOADING OPERATIONS shall only be conducted with working area ambient temperatures 0ºF for all MPC heat loads, and
- a. 90ºF (averaged over a 3-day period) for operations subjected to direct solar heating
- b. 110ºF (averaged over a 3-day period) for operations not subjected to direct solar heating for all MPC heat loads.
If the reference ambient temperature exceeds the corresponding Threshold Temperature then a site specific analysis shall be performed using the actual heat load and reference ambient temperature equal to the three day average to demonstrate that the steady state peak fuel cladding temperature will remain below the 400°C limit.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations This site-specific parameter of ambient temperature will need to be validated against the key design criteria used and evaluated in the FSAR for the cask design.
Section 1 Definitions, Use No Appendix B. and Application Technical Section 2 Approved A1 No Specifications Contents (Selection A2 No Criteria) A3 No Page 81 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or The consequences of the accident event would likely consequences of an be greater but not significantly greater.
accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or No requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
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.
Page 82 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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(9): Site Specific Parameters and Analyses:
- 9. 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Possible site-specific events causing vent blockages for an extended period of time must be evaluated.
Section 1 Definitions, Use No and Application Section 2 Approved A1 No Appendix B. Contents (Selection A2 No Technical Criteria) A3 No Specifications Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Page 83 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in Yes the probability or The consequences of the accident event could be consequences of an significantly increased if site-specific analysis is not accident previously performed for events that may result in blocked evaluated in the cask vents for an extended period of time and alternative Risk Insight**:
FSAR? means of cooling is not provided where necessary Will removing based on these evaluations.
this The possibility of a new or No requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
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.
Page 84 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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(10): Site Specific Parameters and Analyses:
- 10. 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an Risk Insight**:
accident previously Will removing evaluated in the cask this FSAR?
requirement The possibility of a new or No from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 85 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A Significant reduction in No the margin of safety for ISFSI or cask operation?
Evaluation Summary 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.
Page 86 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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(11): Site Specific Parameters and Analyses:
- 11. Site ambient temperature under HI-TRAC TRANSPORT OPERATIONS shall be evaluated in accordance with Section 3.9 requirements.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations 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.
Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or The consequences of the accident event would likely consequences of an be greater but not significantly greater.
Risk Insight**:
accident previously Will removing evaluated in the cask this FSAR?
requirement The possibility of a new or No from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 87 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B A Significant reduction in No the margin of safety for ISFSI or cask operation?
Evaluation Summary 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.
Page 88 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-3.5 _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Section 3.5: Cask Transfer Facility (CTF) 3.5.1: Transfer Cask and MPC Lifters 3.5.2: CTF Structure Requirements 3.5.2.1: Cask Transfer Station and Stationary Lifting Devices 3.5.2.2: Mobile Lift Devices CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in Yes the probability or If the CTF and Lifting Devices cannot be shown to consequences of an adequately support the weights of the loading accident previously system, there would be an increased probability of a Risk Insight**: evaluated in the cask drop or a tipover.
Will removing FSAR?
this The possibility of a new or No requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
Page 89 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Evaluation Summary Move to Appendix A as this includes design features for equipment that is only needed under specified circumstances, unlike the main equipment for the system described in CoC Sections I and II.
Page 90 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 3-2 _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Table 3-2: Load Combinations and Service Condition Definitions for the CTF Structure CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in Yes the probability or If the CTF cannot be shown to adequately support the consequences of an weights of the loading system, there would be an accident previously increased probability of a drop or a tipover.
Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or No requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
Evaluation Summary Move to Appendix A as this includes design features for equipment that is only needed under specified circumstances, unlike the main equipment for the system described in CoC Sections I and II.
Page 91 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-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 Section 3.6: Forced Helium Dehydration System 3.6.1: System Description 3.6.2: Design Criteria 3.6.3: Fuel Cladding Temperature 3.6.4: Pressure Monitoring During FHD Malfunction CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or No requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in Yes the margin of safety for If the maximum heat or pressure values for a given ISFSI or cask operation? MPC are higher than analyzed in the design bases, Page 92 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B then if an event such as 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 Move to Appendix A as this includes design features for equipment that is only needed under specified circumstances, unlike the main equipment for the system described in CoC Sections I and II.
Page 93 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-3.7 _______
- 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 3.7: Supplemental Cooling System 3.7.1: System Description 3.7.2: Design Criteria CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No - Failure of the Supplemental Cooling System is the probability or evaluated as an accident in the FSAR and it is consequences of an concluded that the SCS failure does not affect the accident previously safe operation of the HI-STORM 100 System.
Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or No requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
Evaluation Summary Delete from CoC as this discussion is merely overly prescriptive information about a supplementary system that is fully discussed in the FSAR and this is Page 94 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B not required to be in the CoC for safety per the evaluation above. Also, the CoC main body already addresses the approved exemption allowing for the use of the SCS and LCO is established to ensure its functionality.
Page 95 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-Table 3-3 _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Table 3-3: Requirements for Supplemental Cooling System CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No - Failure of the Supplemental Cooling System is the probability or evaluated as an accident in the FSAR and it is consequences of an concluded that the SCS failure does not affect the accident previously safe operation of the HI-STORM 100 System.
Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or No requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
Evaluation Summary Delete from CoC as this discussion is merely overly prescriptive information about a supplementary system that is fully discussed in the FSAR and this is not required to be in the CoC for safety per the Page 96 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B evaluation above. Also, the CoC main body already addresses the approved exemption allowing for the use of the SCS and LCO is established to ensure its functionality.
Page 97 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-3.8 _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Section 3.8: Combustible Gas Monitoring During MPC Lid Welding and Cutting During MPC lid-to-shell welding and cutting operations, combustible gas monitoring of the space under the MPC lid is required, to ensure that there is no combustible mixture present.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative Yes Controls A significant increase in Yes the probability or Unnoticed buildup of combustible gas could increase consequences of an the probability or severity of a fire.
accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or Yes requirement different kind of accident A combustible gas explosion could result. This would from the CoC/TS being created compared be an accident threatening occupational workers as result in to those previously well as possible loss of confinement.
evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
Page 98 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B 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.
Page 99 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B CoC Condition/TS Identifier: ___B-3.9 _______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix B Section 3.9: Environmental Temperature Requirements TRANSPORT OPERATIONS involving the HI-TRAC transfer cask can be carried out if the reference ambient temperature (three day average around the cask) is above 0°F and below the Threshold Temperature of 110 deg. F ambient temperature, applicable during HI-TRAC transfer operations inside the 10 CFR Part 50 or 10 CFR Part 52 structural boundary and 90 deg. F outside of it. The determination of the Threshold Temperature compliance shall be made based on the best available thermal data for the site.
If the reference ambient temperature exceeds the corresponding Threshold Temperature then a site specific analysis shall be performed using the actual heat load and reference ambient temperature equal to the three day average to ensure that the steady state peak fuel cladding temperature will remain below the 400°C limit. If the peak fuel cladding temperature exceeds 400°C limit then the operation of a Supplemental Cooling System (SCS) in accordance with LCO 3.1.4 is mandatory.
SCS operation is mandatory if site data is not available or if a user elects to deploy Supplemental Cooling in lieu of site ambient temperature evaluation.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes Evaluations Site-specific ambient temperatures will need to be validated against the key design criteria used and evaluated in the FSAR for the cask design.
Appendix B. Section 1 Definitions, Use No Technical and Application Specifications A1 No Page 100 of 101
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Section 2 Approved A2 No Contents (Selection A3 No Criteria)
Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or The consequences of the accident event would likely consequences of an be greater but not significantly greater.
accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or No requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
Evaluation Summary Moved 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.
Page 101 of 101