ML23069A237

Attachment 8: HI-STORM 100 Amendment 19 CoC Reorganization Evaluation Form

ML23069A237
Person / Time
Site:	Holtec
Issue date:	03/10/2023
From:	Holtec
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML23069A227	List: ML23069A229 ML23069A230 ML23069A231 ML23069A232 ML23069A233 ML23069A234 ML23069A235 ML23069A236 ML23069A237 ML23069A238 ML23069A239 ML23069A240 ML23069A241
References
CAC 001028, CoC No. 1014, EPID L-2022-LLA-0028, 5014959
Download: ML23069A237 (1)

Text

CoC Condition/Technical Specification Evaluation Form - CoC original Page 16 of 35 the probability of a cask drop would occur if these heavy load handing procedures are not followed.

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

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

No Evaluation Summary Based on this evaluation these Heavy Load Requirements should be moved to Section 4 of Appendixes B, D, and B-100U - Administrative Controls. Note that this administrative control is applicable to heavy load lifting procedures at the ISFSI. Lifts within the Reactor Building are governed by existing 10 CFR Part 50 license requirements.

However, Appendix B-100U is not being updated at this time. So, to avoid complicating the relationships between the CoC main body and the Appendixes, these requirements will remain in the CoC main body for now.

Holtec Letter 5014959 Attachment 8 1 of 3

CoC Condition/Technical Specification Evaluation Form - CoC original Page 25 of 35 training exercises ensure that the equipment will operate and perform safety functions as designed.

The specifics of dry run training should be performed by the general licensee prior to initial use of the system to load spent fuel. In addition, the general license's training program is subject to NRC inspection.

However, Appendix B-100U is not being updated at this time. So, to avoid complicating the relationships between the CoC main body and the Appendixes, these requirements will remain in the CoC main body for now.

Holtec Letter 5014959 Attachment 8 2 of 3

CoC Condition/Technical Specification Evaluation Form - CoC original Page 33 of 35 and Surveillance Requirements (SRs)

(Selection Criteria)

Section 4 Administrative Controls No Risk Insight**:

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

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

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

Yes - if the site 72.212 evaluations are not updated appropriately when the CoC is renewed, the 72.212 may be missing up-to-date information important to safety conclusions.

Evaluation Summary Move to Appendix A, C, and A-100U Section 2 as this information important to the site-specific 72.212 evaluations.

Holtec Letter 5014959 Attachment 8 3 of 3