ML23069A238

Attachment 9: HI-STORM 100 Amendment 19 CoC, Appendix a Reorganization Evaluation Form

ML23069A238
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
CoC No. 1014, CAC 001028, EPID L-2022-LLA-0028, 5014959
Download: ML23069A238 (5)

Text

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 1 of 42 CoC Condition/TS Identifier: ___A-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 A Section 1.1: Definitions CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application Yes Section 2 Approved Contents (Selection Criteria)

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

and Surveillance Requirements (SRs)

(Selection Criteria)

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

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

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

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

No/A Evaluation Summary Move to Appendix B Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).

Holtec Letter 5014959 Attachment 9 1 of 5

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 2 of 42 CoC Condition/TS Identifier: ___A-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 A Section 1.2: Logical Connectors: The purpose of this section is to explain the meaning of logical connectors.

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

Technical Specifications Section 1 Definitions, Use and Application Yes Section 2 Approved Contents (Selection Criteria)

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

and Surveillance Requirements (SRs)

(Selection Criteria)

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

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

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

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

No/A Evaluation Summary Move to Appendix B Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).

Holtec Letter 5014959 Attachment 9 2 of 5

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 4 of 42 CoC Condition/TS Identifier: ___A-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 A Section 1.3: Completion Times: The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

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

Technical Specifications Section 1 Definitions, Use and Application Yes Section 2 Approved Contents (Selection Criteria)

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

and Surveillance Requirements (SRs)

(Selection Criteria)

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

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

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

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

No/A Evaluation Summary Move to Appendix B Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).

Holtec Letter 5014959 Attachment 9 3 of 5

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 6 of 42 CoC Condition/TS Identifier: ___A-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 A Section 1.4: Frequency: The purpose of this section is to define the proper use and application of Frequency requirements.

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

Technical Specifications Section 1 Definitions, Use and Application Yes Section 2 Approved Contents (Selection Criteria)

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

and Surveillance Requirements (SRs)

(Selection Criteria)

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

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

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

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

No/A Evaluation Summary Move to Appendix B Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).

Holtec Letter 5014959 Attachment 9 4 of 5

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 39 of 42 CoC Condition/TS Identifier: ___A-5.8_______

• 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 A Section 5.8: Fabrication Helium Leak Test At completion of welding the MPC shell to baseplate, an MPC confinement weld helium leak test shall be performed using a helium mass spectrometer. This test shall include the base metals of the MPC shell and baseplate. A helium leak test shall also be performed on the base metal of the fabricated MPC lid. The confinement boundary leakage rate tests shall be performed in accordance with ANSI N14.5 to leaktight criteria. If a leakage rate exceeding the acceptance criteria is detected, then the area of leakage shall be determined and the area repaired per ASME Code Section III, Subsection NB requirements. Re-testing shall be performed until the leakage rate acceptance criterion is met.

Casks initially loaded to Amendments No. 2 through 7 must meet the following:

Casks fabricated on or after July 1, 2009 a fabrication helium leak test at completion of the welding of the MPC shell to baseplate must be performed in accordance with the above requirements.

Casks loaded before July 1, 2009 must meet the fabrication helium leak test requirements of the lid base metal of the amendment to which they were originally loaded.

Casks loaded before July 1, 2009 do not meet the above fabrication helium leak test requirements after MPC shell to baseplate welding. These casks may be upgraded to Amendment 15.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations YesNo Section 1 Definitions, Use and Application NoYes Holtec Letter 5014959 Attachment 9 5 of 5