ML23069A240
| ML23069A240 | |
| Person / Time | |
|---|---|
| Site: | Holtec |
| Issue date: | 03/10/2023 |
| From: | Holtec |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML23069A227 | List: |
| References | |
| EPID L-2022-LLA-0028, CoC No. 1014, CAC 001028, 5014959 | |
| Download: ML23069A240 (5) | |
Text
Holtec Letter 5014959 Attachment 11 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix C CoC Condition/TS Identifier: ___C-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 C Section 1.1: Definitions CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix C - Inspections, Tests, and No Evaluations Section 1 Definitions, Use Yes and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix D. 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/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 No/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 No/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Move to Appendix D Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).
Page 1 of 40 1 of 5
Holtec Letter 5014959 Attachment 11 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix C CoC Condition/TS Identifier: ___C-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 C Section 1.2: Logical Connectors: The purpose of this section is to explain the meaning of logical connectors.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix C - Inspections, Tests, and No Evaluations Section 1 Definitions, Use Yes and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix D. 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/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 No/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 No/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Move to Appendix D Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).
Page 2 of 40 2 of 5
Holtec Letter 5014959 Attachment 11 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix C CoC Condition/TS Identifier: ___C-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 C 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 Section I. Technology No Certified Design Section II. Design Features No Appendix C - Inspections, Tests, and No Evaluations Section 1 Definitions, Use Yes and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix D. 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/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 No/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 No/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Move to Appendix D Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).
Page 4 of 40 3 of 5
Holtec Letter 5014959 Attachment 11 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix C CoC Condition/TS Identifier: ___C-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 C Section 1.4: Frequency: The purpose of this section is to define the proper use and application of Frequency requirements.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix C - Inspections, Tests, and No Evaluations Section 1 Definitions, Use Yes and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix D. 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/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 No/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 No/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Move to Appendix D Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).
Page 6 of 40 4 of 5
Holtec Letter 5014959 Attachment 11 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix C CoC Condition/TS Identifier: ___C-5.4_______
- 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 C Section 5.4: 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.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix C - Inspections, Tests, and YesNo Evaluations Section 1 Definitions, Use NoYes and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix D. 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 Will removing the probability or This test confirms the MPC has been manufactured this consequences of an correctly and will provide confinement as designed.
requirement accident previously Page 37 of 40 5 of 5