ML24002B131
| ML24002B131 | |
| Person / Time | |
|---|---|
| Site: | 07201032 |
| Issue date: | 01/04/2024 |
| From: | Storage and Transportation Licensing Branch |
| To: | |
| Shared Package | |
| ML24002B127 | List: |
| References | |
| EPID L-2022-LLA-0027 | |
| Download: ML24002B131 (1) | |
Text
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 1 of 29 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 5018102 Attachment 4 1 of 4
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 2 of 29 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 5018102 Attachment 4 2 of 4
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 3 of 29 No change to text as the existing Purpose, Background, and Examples are helpful to understand the use and application of Logical Connectors.
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 4 of 29 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 5018102 Attachment 4 3 of 4
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 5 of 29 No change to text as the existing Purpose, Background, Description, Examples, and Immediate Completion Time are helpful to provide guidance on the use and application of Completion Times.
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 6 of 29 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 5018102 Attachment 4 4 of 4
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 7 of 29 No change to text as the existing Purpose, Description, and Examples are helpful to understand the use and application of Frequency.
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 8 of 29 CoC Condition/TS Identifier: ___A-3.0______
- 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 3.0: LCO and SR Applicability 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 No 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 Yes L2 Yes L3 Yes 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?
Yes These LCO and SR applicability requirements are necessary to ensure that safety functions are maintained as described in the individual LCOs and SRs.
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 These LCO and SR applicability requirements are necessary to ensure that safety functions are maintained as described in the individual LCOs and SRs.
Evaluation Summary Move to Appendix B Section 3.0. Applies generically to all three criteria (L1, L2, L3).
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 9 of 29 CoC Condition/TS Identifier: ___A-3.1.1_______
- 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 LCO 3.1.1: Multi-Purpose Canister (MPC)
The MPC shall be dry and helium filled.
Table 3-1 provides decay heat and burnup limits for forced helium dehydration (FHD) and vacuum drying.
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 No 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 Yes 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 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 This LCO ensures an inert atmosphere around the fuel cladding, and that oxidation of the fuel cladding
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 10 of 29 does not occur, preserving the integrity of the fuel cladding fission product barrier. Its removal would reduce the margin of safety for confinement.
Evaluation Summary Move to Appendix B Section 3 as this LCO ensures an inert atmosphere around the fuel cladding and that oxidation of the fuel cladding does not occur, preserving the integrity of the fuel cladding fission product barrier. (Criterion L2)
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 11 of 29 CoC Condition/TS Identifier: __A-3.1.2________
- 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 LCO 3.1.2: SFSC Heat Removal System The SFSC Heat Removal System shall be operable.
Note: The SFSC Heat Removal System is operable when 50% or more of each of the inlet and outlet vent areas are unblocked and available for flow or when air temperature requirements are met. This LCO only applies to the VENTILATED OVERPACKs.
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 No 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 Yes 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 The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
No
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 12 of 29 A Significant reduction in the margin of safety for ISFSI or cask operation?
Yes This LCO ensures fuel cladding temperatures remain below the limit for normal storage operations, preserving the integrity of the fuel cladding fission product barrier. Its removal would reduce the margin of safety for confinement.
Evaluation Summary Move to Appendix B Section 3 as this LCO ensures fuel cladding temperatures remain below the limit for normal storage operations, preserving the integrity of the fuel cladding fission product barrier. (Criterion L2)
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 13 of 29 CoC Condition/TS Identifier: __A-3.1.3________
- 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 LCO 3.1.3: MPC Cavity Reflooding The MPC cavity pressure shall be < 100 psig Note: The LCO is only applicable to wet UNLOADING OPERATIONS.
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 No 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 Yes 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 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 This LCO ensures that the MPC cavity pressure limit is not exceeded during reflooding such that the
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 14 of 29 integrity of the MPC enclosure vessel confinement boundary is compromised.
Evaluation Summary Move to Appendix B Section 3 as this LCO ensures that the MPC cavity pressure is below the 100 psig limit before reflooding operations the MPC is then reflooded with water at a controlled rate and/or the pressure monitored to ensure that the pressure remains below 100 psig. The integrity of the MPC depends on maintaining the internal cavity pressures within design limits. This is accomplished by introducing water to the cavity in a controlled manner such that there is no sudden formation of large quantities of steam during MPC reflooding.,
preserving the integrity of the MPC enclosure vessel confinement boundary (fission product barrier).
(Criterion L2)
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 15 of 29 CoC Condition/TS Identifier: ____ A-3.1.4______
- 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 LCO 3.1.4: Transfer Cask Heat Removal System The HI-TRAC VW Version V or V2 Heat Removal System shall be operable.
Note: The HI-TRAC Version V or V2 Heat Removal System is operable when 100% of the inlet and outlet vent areas are unblocked and available for flow. If surveillance shows partial blockage ( 100%) of the duct areas, the blockage shall be removed.
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 No 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 Yes 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 The possibility of a new or different kind of accident being created compared No
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 16 of 29 to those previously evaluated in the FSAR?
A Significant reduction in the margin of safety for ISFSI or cask operation?
Yes This LCO ensures fuel cladding temperatures remain below the limit for normal storage operations, preserving the integrity of the fuel cladding fission product barrier. Its removal would reduce the margin of safety for confinement.
Evaluation Summary Move to Appendix B Section 3 as this LCO ensures fuel cladding temperatures remain below the limit for normal storage operations, preserving the integrity of the fuel cladding fission product barrier. (Criterion L2)
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 17 of 29 CoC Condition/TS Identifier: ___A-3.2.1_______
- 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 LCO 3.2.1: Transfer Cask Surface Contamination Removable contamination on the exterior surfaces of the TRANSFER CASK and accessible portions of the MPC shall each not exceed:
- a. 1000 dpm/100 cm2 from beta and gamma sources
- b. 20 dpm/100 cm2 from alpha sources.
Note: This LCO is not applicable to the TRANSFER CASK if MPC TRANSFER operations occur inside the FUEL BUILDING.
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 No 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 Yes Section 4 Administrative Controls No Risk Insight**:
Will removing this requirement A significant increase in the probability or consequences of an accident previously No increase to the probability of any accident.
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 18 of 29 from the CoC/TS result in evaluated in the cask FSAR?
Slight increase in consequences due to increased dose from contamination, but not a significant increase.
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 Retain in Appendix B Section 3 as this LCO ensures compliance with contamination limits for normal storage operations when not occurring in Fuel Building. (Criterion L3)
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 19 of 29 CoC Condition/TS Identifier: __A-3.3.1________
- 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 LCO 3.3.1: Boron Concentration The concentration of boron in the water in the MPC shall meet the following limits for the applicable MPC model and the most limiting fuel assembly array/class to be stored in the MPC:
MPC-37, MPC-32ML, MPC-37P, or MPC-44: Minimum soluble boron concentration as required by the table below.
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 No 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 Yes 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?
Yes The probability of a criticality accident is increased.
The possibility of a new or different kind of accident being created compared No
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 20 of 29 to those previously evaluated in the FSAR?
A Significant reduction in the margin of safety for ISFSI or cask operation?
Yes Loss of criticality control would cause a significant reduction in the margin of safety.
Evaluation Summary Retain in Appendix B Section 3 as this LCO ensures that a subcritical configuration is maintained.
(Criterion L2)
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 21 of 29 CoC Condition/TS Identifier: __A-Tables 3-1_______
- 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 Table 3-1: MPC Cavity Drying Limits 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 No 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 Yes Referenced by LCO 3.1.1 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?
See evaluation of LCO 3.1.1 above The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
See evaluation of LCO 3.1.1 above A Significant reduction in the margin of safety for ISFSI or cask operation?
See evaluation of LCO 3.1.1 above Evaluation Summary Retain in Appendix B Section 3 as these tables provide information needed to complete LCO 3.1.1.
(Criterion L1)
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 22 of 29 CoC Condition/TS Identifier: ___A-Tables 3-2_______
- 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 Table 3-2: MPC Helium Backfill Limits 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 No 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 Yes Referenced by LCO 3.1.1 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?
See evaluation of LCO 3.1.1 above The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?
See evaluation of LCO 3.1.1 above A Significant reduction in the margin of safety for ISFSI or cask operation?
See evaluation of LCO 3.1.1 above Evaluation Summary Retain in Appendix B Section 3 as these Tables provide information needed to complete LCO 3.1.1.
(Criterion L1)
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 23 of 29 CoC Condition/TS Identifier: ___A-5.1_______
- 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 5.1: Radioactive Effluent Control Program This program implements the requirements of 10 CFR 72.44(d).
- a. The HI-STORM FW MPC Storage System does not create any radioactive materials or have any radioactive waste treatment systems.
Therefore, specific operating procedures for the control of radioactive effluents and annual reporting in accordance with 10 CFR 72.44(d)(3) are not required. Specification 3.1.1, Multi-Purpose Canister (MPC), provides assurance that there are not radioactive effluents from the SFSC.
- b. This program includes an environmental monitoring program. Each general license user may incorporate SFSC operations into their environmental monitoring programs for 10 CFR Part 50 operations.
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 No 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 Yes
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 24 of 29 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?
First statement (quoted in Evaluation Summary below) - No
- a. - No The first sentence establishes that the HI-STORM System does not create any radioactive materials or have any radioactive waste treatment systems. The second sentence merely explains that specific operating procedures and reporting is not required based on the first sentence. This is not necessary for safety as implementing the unnecessary procedures and reporting would not decrease any margin to safety for the system. Similarly, the third sentence merely points to an LCO providing additional assurance that the first statement is true.
- b. - Yes Without this environmental monitoring program, radioactive material may not be controlled appropriately.
Evaluation Summary Remove This program implements the requirements of 10 CFR 72.44(d) as this is a regulatory requirement that must be met. Also remove Specification 3.1.1, Multi-Purpose Canister (MPC),
provides assurance that there are not radioactive effluents from the SFSC. from item a as these are not necessary based on the risk insight discussion above.
Move the rest of the text to Appendix B Section 4, Administrative Controls. The remaining sentences in item a are not a safety concern but should be kept in the CoC Appendix B as they reduce the regulatory burden on the licensees. Item b should be kept in the CoC Appendix B as this program is necessary to assure that the operations involved in the storage of spent fuel in an ISFSI are performed in a safe manner.
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 25 of 29
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 26 of 29 CoC Condition/TS Identifier: ___A-5.2_______
- 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 5.2: Transport Evaluation Program
- a. For lifting of the loaded TRANSFER CASK or OVERPACK using devices which are integral to a structure governed by 10 CFR Part 50 regulations, 10 CFR 50 requirements apply.
- b. This program is not applicable when the TRANSFER CASK or OVERPACK is in the FUEL BUILDING or is being handled by equipment providing support from underneath (i.e., on a rail car, heavy haul trailer, air pads, etc...).
- c. The TRANSFER CASK or OVERPACK, when loaded with spent fuel, may be lifted to and carried at any height necessary during TRANSPORT OPERATIONS and MPC TRANSFER, provided the lifting equipment is designed in accordance with 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 No 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 Yes Risk Insight**:
Will removing A significant increase in the probability or No
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 27 of 29 this requirement from the CoC/TS result in consequences of an accident previously evaluated in the cask FSAR?
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 A significant reduction in the margin of safety for confinement is possible if there were no restrictions on equipment used for lifting a loaded cask.
Evaluation Summary Retain in Appendix B Section 4, Administrative Controls, as this provides restrictions on what equipment can used to transfer the HI-STORM System casks and canisters when they are loaded with fuel. These controls are necessary to assure that the operations involved in the storage of spent fuel in an ISFSI are performed in a safe manner such that the casks will not be dropped which could impact safety functions such as confinement.
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 28 of 29 CoC Condition/TS Identifier: __A-5.3________
- 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 5.3: Radiation Protection Program 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 No 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 Yes 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 There would be no increase in the probability of any accident.
There would only be an increase in the consequences of accidents due to increased dose from the Overpack or Transfer Cask if there was an area of reduced shielding. This protection program verifies that there is no such area of reduced shielding, but does not include an overt action involving an SSC that provides shielding.
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?
5.3.2 - No 5.3.1 and 5.3.3 through 5.3.8 - No.
CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Page 29 of 29 There would be a slight reduction in the margin of safety for the shielding function, but only if an area of reduced shielding exists.
Evaluation Summary 5.3.1 -Retain in Appendix B section 4, Administrative Controls.
5.3.2 - Combine main statement with existing Section 5.3.3 as these discussions are currently repetitive.
Refer to appropriate Part 72 Section: 72.212(b)(5)(iii) 5.3.3 through 8-Retain in Appendix B section 4, Administrative Controls. These controls are important as they provide dose rate information in assessing worker dose and potentially identifying a misload.