ML23072A431

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Attachment 4: Holtec International, HI-STORM FW Amendment 9 CoC, Appendix a Reorganization Evaluation Form
ML23072A431
Person / Time
Site: 07201032
Issue date: 03/13/2023
From:
Holtec
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML23072A426 List:
References
5018102
Download: ML23072A431 (1)


Text

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A

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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - 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 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/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 B Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).

Page 1 of 29 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A

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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - 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 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/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 B Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).

Page 2 of 29 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A

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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - 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 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/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 B Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).

Page 4 of 29 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A

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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - 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 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/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 B Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).

Page 6 of 29