Letter Sequence Other |
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CAC:001028, (Approved, Closed) EPID:L-2022-LLA-0028, Independent Spent Fuel Storage Installation - Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section Le and 10 CFR 73.55(r) Annual Physical Requalification Requirement (Approved, Closed) |
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, ... further results|Request]]
- Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance
- Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement
Administration
- Withholding Request Acceptance
- Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting
Results
- Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, ... further results|Approval]]
Other: L-23-005, Independent Spent Fuel Storage Installation License Renewal Application, Revision 1 (Cac/Epid No. 001028/L-2022-RNW-0007), ML19276D398, ML20014E677, ML20049A082, ML20065N277, ML20065N278, ML20065N280, ML20065N281, ML20065N285, ML20071F156, ML20076D696, ML20094G482, ML20099A180, ML20104C015, ML20104C016, ML20104C018, ML20104C019, ML20105A135, ML20105A136, ML20105A137, ML20105A138, ML20105A139, ML20105A173, ML20111A240, ML20115E377, ML20121A272, ML20136A049, ML20136A050, ML20136A051, ML20150A300, ML20150A335, ML20150A421, ML20155K741, ML20155K742, ML20155K743, ML20155K744, ML20160A040, ML20161A088, ML20163A702, ML20163A703, ML20163A704, ML20181A211, ML20181A212, ML20192A328, ML20192A329, ML20212L768, ML20212L769, ML20212L878, ML20223A036, ML20224A287... further results
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MONTHYEARML19276D3982019-10-0303 October 2019 Exemption Request to Load and Store Spent Fuel in HI-STORM FW Spent Fuel Casks Utilizing Amendment 1, Revision 1 to CoC No. 1032 Project stage: Other ML20115E3782019-10-0303 October 2019 Independent Spent Fuel Storage Installation Exemption Safety Evaluation Report Project stage: Approval ML20014E6772020-01-0909 January 2020 Fws List of Threatened and Endangered Species That May Occur with Respect to the McGuire Exemption Request Project stage: Other ML20015A3142020-01-14014 January 2020 Package: Exemption Request McGuire Nuclear Facility Project stage: Request ML20049A0812020-01-31031 January 2020 Holtec International - HI-STORM 100 Storage CoC Renewal Application Project stage: Request ML20049A0822020-01-31031 January 2020 Holtec International - HI-STORM 100 Storage CoC Renewal Application Project stage: Other ML20055F3372020-02-20020 February 2020 Conversation Record - Clarification Call (02/20/2020) on RAI 1 for CoC 1040 Umax Amendment 4 Project stage: RAI ML20064F6162020-02-29029 February 2020 January 15, 2020, Summary of Meeting with Holtec International, Inc., to Discuss the Upcoming Submittal of the Application for Renewal of the Storage Certificate of Compliance No. 1014 for the HI-Storm 100 Cask System Project stage: Meeting ML20063M0152020-03-0303 March 2020 HI-STORM 100 Renewal Presubmittal Meeting (Holtec Slides, 1-15-20) Project stage: Meeting ML20064E6222020-03-0303 March 2020 U.S. Nuclear Regulatory Commission Approval of NAC International Request for Withholding Information from Public Disclosure for Coc 1025 Renewal (CAC No. 001028) Project stage: Withholding Request Acceptance ML20071J0552020-03-0505 March 2020 Notice of Cancelled Meeting with the U.S. Department of Energy, Idaho Operations Office to Discuss the Upcoming Submittal of the Application for Renewal of the Idaho Spent Fuel Facility License (SNM-2512) Project stage: Meeting ML20065K2162020-03-0505 March 2020 Notice of Meeting with U.S. Department of Energy, Idaho Operations Office to Discuss the Upcoming Submittal of the Application for Renewal of the Idaho Spent Fuel Facility License (SNM-2512) Project stage: Meeting ML20071F1562020-03-0505 March 2020 Interim Storage Partners, LLC - Affidavit Project stage: Other ML20071F1532020-03-0505 March 2020 Interim Storage Partners, LLC - Supplemental Information in Support of Nrc'S Environmental Review Project stage: Supplement ML20065J4272020-03-0505 March 2020 Submittal of Renewal Application for the TN-32 Dry Storage Cask - CoC 1021 Project stage: Request ML20066K5782020-03-0606 March 2020 Acceptance Review of Request for Amendment No. 7 to Certificate of Compliance No. 1032 for the HI-STORM Flood/Wind Multipurpose Canister Storage System Project stage: Acceptance Review ML20065L3442020-03-0606 March 2020 Amendment No. 15 to Certificate of Compliance No. 1014 for the Hi-Storm 100 Multipurpose Canister Storage System - Request for Additional Information Project stage: RAI ML20065N2852020-03-0909 March 2020 ISFSI Renewed Technical Specifications Project stage: Other ML20065N2772020-03-0909 March 2020 ISFSI Renewal Cover Letter Project stage: Other ML20065N2812020-03-0909 March 2020 ISFSI Preamble-License Renewal Order Project stage: Other ML20071D9942020-03-11011 March 2020 Submittal of HI-STAR 100 Updated FSAR, Revision 4 Project stage: Request ML20076D6962020-03-11011 March 2020 Interim Storage Partners, LLC - Submittal of Clarifications to Support Nrc'S Continued Review of the Safety Case for the WCS CISF Project stage: Other ML20065N2782020-03-11011 March 2020 ISFSI FRN Notice of Issuance for License Renewal Project stage: Other ML20104C0152020-03-30030 March 2020 International - Amendment No. 4 to the HI-STORM Umax Canister Storage System Project stage: Other ML20104C0162020-03-30030 March 2020 International - Proposed HI-STORM Umax CoC Amendment 4 Appendix a - Changed Pages Project stage: Other ML20104C0182020-03-30030 March 2020 International - HI-STORM Umax Amendment 4 FSAR - Changed Pages Project stage: Other ML20104C0192020-03-30030 March 2020 International - Affidavit for Kimberly Manzione Project stage: Other ML20104C0202020-03-30030 March 2020 International - HI-STORM Umax Amendment 4 Responses to Requests for Additional Information - Supplemental Information Project stage: Supplement ML20091L0642020-03-31031 March 2020 Enclosure 1 - Request for Additional Information - Non-Proprietary Project stage: RAI ML20065N2802020-03-31031 March 2020 ISFSI License Renewal SER Project stage: Other ML20101P3992020-03-31031 March 2020 Interim Storage Partners, LLC - Submittal of Draft Responses for Several Rals and Associated Document Markups from First Request for Additional Information, Parts 1, 2 and Clarifications Project stage: Draft Request ML20105A1352020-03-31031 March 2020 Enclosure 1 - Affidavits Project stage: Other ML20104C0482020-03-31031 March 2020 International - HI-STORM Umax Amendment 3 Responses to Requests for Additional Information Project stage: Response to RAI ML20091L0632020-03-31031 March 2020 Transmittal Letter - CoC 1042 Amendment Number 2 Request for Additional Information Project stage: RAI ML20099A1802020-04-0606 April 2020 Application for Renewal of the Certificate of Compliance No. 1014 for the Hi-Storm 100 Storage Cask System Accepted for Review (Cac/Epid Nos. 001028/L-2020-RNW-0007) Project stage: Other ML20105A1732020-04-0606 April 2020 Interim Storage Partners, LLC - Affidavits Project stage: Other ML20105A1362020-04-0707 April 2020 Enclosure 3 - RAIs and Responses Project stage: Other ML20105A1372020-04-0707 April 2020 Enclosure 5 - La Changed Pages Project stage: Other ML20105A1382020-04-0707 April 2020 Enclosure 7 - SAR Changed Pages Project stage: Other ML20105A1722020-04-0707 April 2020 Interim Storage Partners, LLC - Submittal of Supplemental Information in Support of RAI, Part 3 Project stage: Supplement ML20105A1392020-04-0707 April 2020 Enclosure 8 - Referenced Documents Project stage: Other ML20105A1342020-04-0707 April 2020 Submission of ISP Responses for RAIs and Associated Document Markups from First Request for Additional Information, Parts 2, 3, and 4 Project stage: Request ML20100F2952020-04-0909 April 2020 Tn Americas LLC - Submittal of Renewal Application for the TN-68 Dry Storage Cask - CoC 1027 Project stage: Request ML20104A0402020-04-10010 April 2020 Request for Additional Information for HI-STAR 100 CoC Renewal Application Project stage: RAI ML20111A2382020-04-13013 April 2020 International - HI-STORM Umax Amendment 4 Responses to Requests for Additional Information - Supplemental Information Project stage: Supplement ML20111A2392020-04-13013 April 2020 Attachment 1: HI-STORM Umax Amendment 4 RAI Supplemental Response (non-proprietary) Project stage: Supplement ML20111A2402020-04-13013 April 2020 Attachment 2: Proposed HI-STORM Umax CoC Amendment 4 Appendix a - Changed Pages (non-proprietary) Project stage: Other ML20094G4822020-04-15015 April 2020 GEH-Morris QAP Rev 4 Approval Project stage: Other ML20092L1732020-04-17017 April 2020 Safety Evaluation Report for the Pacific Gas and Electric Company Humboldt Bay Independent Spent Fuel Storage Installation Quality Assurance Plan HBI-L6 Revision 0 Project stage: Approval ML20120A2282020-04-29029 April 2020 Tn Americas LLC, Response to the Request for Additional Information to Application for Certificate of Compliance No. 1042, Amendment No. 2, to NUHOMS Eos System, (Docket No. 72-1042, CAC No. 001028 EPID: L-2019-LLA-0078)- Request for Extens Project stage: Request 2020-03-05
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Category:Response to Request for Additional Information (RAI)
MONTHYEARML23338A3062023-12-0404 December 2023 Attachment 1: HI-STORM 100 Amendment 18 RAI Responses (non-proprietary) ML23321A2192023-11-17017 November 2023 International, NRC Clarification Questions from EA-23-044 Holtec Pec Presentation ML23297A261 (Edited Excerpt from the Pec Transcript ML23307A107) ML23263B1242023-09-20020 September 2023 Attachment 1: HI-STORM 100 Amendment 16 Second Round RAI Response (non-proprietary) ML23251A2522023-09-0808 September 2023 Attachment 1: HI-STORM 100 Amendment 18 RAI Responses ML23146A1402023-05-26026 May 2023 Attachment 1 - HI-STORM 100 Amendment 18 Responses to Requests for Additional Information ML23076A2742023-03-17017 March 2023 Attachment 2: Holtec Response to Request for Additional Information (Batch 4) ML23069A2292023-03-10010 March 2023 HI-STORM 100 Multipurpose Canister Storage System Amendment 19 Rsi Responses ML23069A2302023-03-10010 March 2023 Attachment 1: HI-STORM 100 Amendment 19 Rsi Responses ML23032A4512023-02-0101 February 2023 Attachment 1: NRC Staff Clarifications Regarding Holtec'S Response to a Request for Additional Information (RAI) for: HI-2210161 Rev. 2, Topical Report on the Radiological Fuel Qualification Methodology for Dry Storage Systems ML23013A3402023-01-13013 January 2023 Attachment 2 - HI-STORM 100 Amendment 16 RAI Responses Batch 5 (Non-Proprietary) ML23005A2732023-01-0505 January 2023 International HI-STORM 100 Amendment 16 Responses to Requests for Additional Information (Batch 4) Additional Supporting Document ML23005A0042023-01-0404 January 2023 Attachment 2 - HI-STORM 100 Amendment 16 Response to Request for Additional Information (Batch 4) ML22276A2872022-10-0303 October 2022 HI-STORM 100 Amendment 16 Responses to Requests for Additional Information (Batch 3) ML22249A3502022-09-0909 September 2022 Attachment 2: HI-STORM 100 Amendment 16 RAI Responses ML22245A1052022-09-0202 September 2022 Attachment 1: HI-STORM 100 Amendment 18 Rsi Responses ML22243A2722022-08-31031 August 2022 Attachment 2: Holtec Response to Request for Additional Information (Batch 1 and Partial Batch 2) ML22243A2702022-08-31031 August 2022 HI-STORM 100 Amendment 16 Responses to Requests for Additional Information (Batches 1 and 2) ML22038A9422022-02-0707 February 2022 International, RAI Responses on Report HI-2210161, Topical Report on the Radiological Fuel Qualification Methodology for Dry Storage Systems ML21230A3382021-08-18018 August 2021 Attachment 1: Holtec International Responses to Requests for Supplemental Information Topical Report on Methodology for Fuel Qualification ML21223A0482021-08-11011 August 2021 Attachment 2: HI-STORM 100 Amendment 16 Rsi Responses (non-proprietary) ML21109A3702021-04-19019 April 2021 Attachment 2: Holtec International, HI-STORM 100 CoC Renewal Responses to Requests for Clarification of Responses to Requests for Additional Information ML21092A1652021-04-0202 April 2021 Attachment 3: Responses to NRC Staff'S Open Items ML20318A3232020-11-13013 November 2020 Attachment 1 - Responses to NRC Clarification Questions on HI-STAR 100 License Renewal Application ML20290A8222020-10-16016 October 2020 HI-STORM 100 CoC Renewal Responses to Requests for Additional Information ML20290A8242020-10-16016 October 2020 Certificate of Compliance Renewal Application for the HI-STORM 100 Dry Storage System ML20229A0042020-08-14014 August 2020 Attachment 2: HI-STORM 100 FSAR Proposed Changed Pages ML20229A0032020-08-14014 August 2020 Attachment 1: Responses to RAIs on HI-STORM 100 Amendment 15 ML20164A2972020-06-12012 June 2020 HI-STORM 100 Amendment 15 RAI Response Supplemental Information ML20136A4772020-05-15015 May 2020 Attachment 1 - Responses to Requests for Additional Information (Rais) 3-1 and 3-6 for HI-STORM 100 LAR 1014-14 (Non-Proprietary) BVY 17-031, Response to Request for Additional Information Re Exemption Request from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 to Support the Dry Fuel Loading Campaign2017-09-0707 September 2017 Response to Request for Additional Information Re Exemption Request from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 to Support the Dry Fuel Loading Campaign BVY 17-001, Response to Request for Supplemental Information Related to Exemption2017-01-0909 January 2017 Response to Request for Supplemental Information Related to Exemption 2023-09-08
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Holtec Letter 5014959 Attachment 1 Holtec Response to Request for Supplemental Information Docket No. 72-1014 Holtec International HI-STORM 100 Multipurpose Canister Storage System Certificate of Compliance No. 1014 Amendment No. 19 RSI-1 Provide justification for not updating appendices A-100U and B-100U.
Holtec International (Holtec, the applicant) stated that it would not update appendices A-100U and B-100U but did not provide any explanation nor justification for the decision.
The U.S. Nuclear Regulatory Commission (NRC) staff notes that not updating appendices A-100U and B-100U could cause inconsistencies and confusion as described below:
- 1. Per the NRCs endorsement on the graded approach (Agencywide Document Access and Management System [ADAMS] Accession No. ML19353D337), administrative controls technical specifications (TS) would be in appendix B, section 4. The applicant stated that it will not update appendix B-100U, so some administrative controls will remain in the certificate of compliance (CoC) to avoid complication. For example, condition 5, heavy load requirements (Form ID: CoC-5), and condition 10, pre-operational testing and training exercise (Form ID: CoC-10), will remain in CoC instead of moving to appendices B, D, and B-100U.Therefore, some administrative controls will be in the CoC and some in appendices B and D. This practice defeats the goal of streamlining the CoC & TS and could potentially cause confusion.
- 2. Form ID: CoC-15. CoC condition 15, 72.212 evaluations for renewed CoC use, is being moved to appendix A, section 2 as it is important to site-specific 72.212 evaluations. This information also applies to appendix A-100U, which Holtec decided not to update. By moving it to only appendix A, it creates a regulatory void.
- 3. Currently, appendix A-100U sections 1.1 through 1.4 refer to appendix A. All the referenced sections in appendix A are being moved to the new appendix B. Appendix A-100U would have several incorrect references if not updated.
- 4. Currently, appendix B-100U refers to appendices A and B in the following sections:
- Section 1.0, definitions, refers to appendix A.
- Section 3.3.1 refers to table 3-1 of appendix B.
- Section 3.6.2.2 refers to appendix A.
These referenced sections are being moved to other parts of the TS. Appendix B-100U would have several incorrect references if not updated.
The staff needs this information to determine compliance with Title 10 of the Code of Federal Regulations (10 CFR) 72.244.
Holtec RSI Response:
Holtec understands that the decision to not update CoC Appendixes A-100U and B-100U with the rest of the CoC Appendixes has introduced some incorrect cross-references/regulatory voids. Holtec has updated small sections of the CoC and Appendixes below to address these issues as described below. Holtec does not feel reorganization of these Appendixes A-100U and B-100U is worth the effort to propose (Holtec) and review (NRC Staff) at this time. Reorganization of these Appendixes 1 of 4
Holtec Letter 5014959 Attachment 1 may be proposed at a future time in a separate submittal.
- 1. Per the NRCs request, Holtec has incorporated the administrative controls for condition 5 (Form ID:
CoC-5), and 10 (Form ID: CoC-10) of the CoC to be included in Appendixes B, D, and A-100U. As Appendix A-100U contains the administrative changes section, it is more applicable to contain conditions 5 and 10 in section A-100U rather than in Appendix B-100U. In appendixes B and D, condition 5 and 10 are now located in sections 4.7 and 4.8 respectively. In appendix A-100U condition 5 and 10 are now located in sections 5.8 and 5.9 respectively. In addition, the CoC has been updated to remove sections II.c and II.d which represent condition 5 and 10. The appropriate Evaluation Forms and Matrix are also updated.
- 2. Per the reorganization matrix, the CoC condition 15 (Form ID: CoC-15) is moved to Appendix A section 2.5. This CoC condition 15 information is now also added to Appendix A-100U as section 2.1.
Adding this section into Appendix A-100U prevents the creation of a regulatory void and maintains consistency with the inclusion of condition 15 in Appendix A. The appropriate Evaluation Forms and Matrix are also updated.
- 3. Per the NRCs request, Holtec has modified Appendix A-100U to reference Appendix B for sections 1.1-1.4. By modifying the references, A-100U now correctly references the other Appendixes.
- 4. Similar to Appendix A-100U, Appendix B-100U also referred to Appendix A for definitions. To rectify this, Appendix B has been listed as the correct reference in section 1 of Appendix B-100U.
Section 3.3.1 in Appendix B-100U is now modified to reference Appendix A table 3-1 rather than the previous Appendix B table 3-1. By modifying the reference, this aligns the Appendix B-100U with the applicable data following the reorganization matrix.
Section 3.6.2.2 in Appendix B-100U currently references Appendix A since table 3-2 in Appendix A contains all the backfill pressures. Since table 3-2 maintains Appendix A as the applicable reference it will be left as is. Appendixes B and D reference the pressure in the MPC cavity during drying, while Appendixes A and C reference the backfill pressure. To align with this, Appendix B-100U will contain the same references to maintain consistency.
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Holtec Letter 5014959 Attachment 1 Observations O-1 Provide risk insight evaluation for the following forms:
- Form ID: A-1.1, definition
- Form ID: A-1.2, logical connectors
- Form ID: A-1.3, completion times
- Form ID: A-1.4, frequency
- Form ID: D-Table 3-1 As noted in the NRCs endorsement (ML19353D337), the graded approach criteria were developed to improve the spent fuel dry storage licensing process by applying risk insights to clarify the information required in the CoC and TS and removing or relocating details that are not risk significant to safety, thereby providing additional flexibility for licensees. Thus, the graded approach makes the contents of the CoC and TS more safety- and risk-focused and the level of detail more appropriate. The risk insight is an important part of the graded approach in providing the bases for removing or relocating the information in the CoC and TS.
The staff needs this information to determine compliance with 10 CFR 72.244.
Holtec RSI Response:
The requested justification for adding risk insight analysis has been updated and incorporated into the latest revisions of the Evaluation Forms. Holtec attempted to use the same level of detail used for similar items during The Pilot Program which has been approved by the NRC. By performing the full evaluation and not leaving N/A as a response Holtec provides a full and clarified evaluation for the NRC to review based upon the update.
O-2 Provide justification or additional information in the evaluation summary. The following are some examples:
- Form ID: A-5.8, fabrication helium leak test. The evaluation answered yes for appendix B section 1, but the summary states to stay in appendix A.
- Form ID: C-5.4, fabrication helium leak test. The evaluation answered yes for appendix D section 1, but the summary states to stay in appendix C.
The evaluation summaries for these forms are inconsistent with the information provided on the rest of the forms. The applicant did not provide sufficient justification to explain the differences.
The staff needs this information to determine compliance with 10 CFR 72.244.
Holtec RSI Response:
Holtec has reviewed the Evaluation Forms completed to ensure consistency between the evaluation rows and the summary statements on each form. The following items have been updated to correct inconsistent statements:
- Form ID: C-5.4 O-3 Provide justification for moving American Society of Mechanical Engineers (ASME) code alternatives to appendix A instead of a new appendix as done in the pilot.
In the pilot, ASME code alternatives were moved to a new appendix C. The applicant moved code alternatives from appendix B to the new appendix A (Form ID: B-Table 3-1) and from appendix D to the new appendix C (Form ID: D-Table 3-1) without justification for the difference from the pilot.
The staff needs this information to determine compliance with 10 CFR 72.244.
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Holtec Letter 5014959 Attachment 1 Holtec RSI Response:
The pilot program provided a lot of good guidance on restructuring/focusing a Part 72 CoC on safety per the graded approach. Holtec applied the guidance as applicable to the structure/content of our CoC.
While the final locations of the ASME code alternative information are different between the pilot program and Holtecs proposed HI-STORM 100 Amendment 19, both the pilot and Holtecs amendment concluded that the ASME code alternatives did need to remain in the CoC and that the evaluation form/proposed outline developed and described in RIRP-I-16-01 (ML17138A119) did not include a standard location for this information, nor does 10CFR72.244 indicate a specific location for this information. Therefore, the appropriate location of the ASME code alternative information is dependent on the specifics of the System being considered.
As explained in the pilot, the ASME code alternatives were moved into a new Appendix C. This was a reasonable decision considering the structure and format of the CoC evaluated in the pilot program. However, based on the current structure and format of the HI-STORM 100 CoC, it seems more straightforward to keep the table in its current location. The HI-STORM 100 CoC contained six Appendices prior to this Amendment 19 effort to reorganize the CoC. These six Appendices were paired in sets of two in order to organize information about various Versions of the HI-STORM 100. The CoC reorganization proposed in this Amendment 19 maintains these three pairs of Appendices (six total) in an effort to keep the separation of information about different versions of the HI-STORM 100 systems to ensure users of the CoC can easily track down information about specific versions.
Creating a new third Appendix for each existing pair of Appendices just to contain the appropriate ASME code alternatives would have resulted in three completely new appendices and a total of nine Appendices to the HI-STORM 100 CoC. Holtec did not think this appropriate for the HI-STORM 100 CoC as the numbering of the Appendices would be thrown off by the attrition of three more and the information can be easily fit into the reorganized Appendices A and C. While the pilot came up with one solution for where to locate the ASME code alternatives, Holtec is proposing a more appropriate location for the ASME code alternatives in the HI-STORM 100 CoC that does not conflict with the evaluation forms.
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