ML21126A295

Attachment 27 - HI-STORM FW Amendment 7 Certificate of Compliance, Appendix a, Reorganization Evaluation Form

ML21126A295
Person / Time
Site:	07201032
Issue date:	05/06/2021
From:	Holtec
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML21126A266	List: ML21126A267 ML21126A268 ML21126A269 ML21126A270 ML21126A271 ML21126A273 ML21126A290 ML21126A291 ML21126A292 ML21126A293 ML21126A294 ML21126A295 ML21126A296 ML21126A297
References
5018083
Download: ML21126A295 (25)

Text

Attachment 27 to Holtec Letter 5018083 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 N/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 N/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 N/A the margin of safety for ISFSI or cask operation?

Evaluation Summary Retain in Appendix B Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).

Page 1 of 25

Attachment 27 to Holtec Letter 5018083 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 N/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 N/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 N/A the margin of safety for ISFSI or cask operation?

Evaluation Summary Retain in Appendix B Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).

Page 2 of 25

Attachment 27 to Holtec Letter 5018083 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 N/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 N/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 N/A the margin of safety for ISFSI or cask operation?

Evaluation Summary Retain in Appendix B Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).

Page 3 of 25

Attachment 27 to Holtec Letter 5018083 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 N/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 N/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 N/A the margin of safety for ISFSI or cask operation?

Evaluation Summary Retain in Appendix B Section 1 as it meets the criterion for inclusion in the new TS format (Use and Application).

Page 4 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 Yes Technical Conditions for L2 Yes Specifications Operation (LCOs)* L3 Yes and Surveillance Requirements (SRs)

(Selection Criteria)

Section 4 Administrative No Controls A significant increase in Yes the probability or These LCO and SR applicability requirements are consequences of an necessary to ensure that safety functions are accident previously maintained as described in the individual LCOs and evaluated in the cask SRs.

Risk Insight**: FSAR?

Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?

A Significant reduction in Yes the margin of safety for These LCO and SR applicability requirements are ISFSI or cask operation? necessary to ensure that safety functions are maintained as described in the individual LCOs and SRs.

Evaluation Summary Retain in Appendix B Section 3.0. Applies generically to all three criteria (L1, L2, L3).

Page 5 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No 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 Yes Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)

(Selection Criteria)

Section 4 Administrative No Controls A significant increase in N/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 N/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 N/A the margin of safety for ISFSI or cask operation?

Page 6 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Evaluation Summary Retain in 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)

Page 7 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No 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 Yes Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)

(Selection Criteria)

Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an Risk Insight**:

accident previously Will removing evaluated in the cask this FSAR?

requirement The possibility of a new or N/A from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?

Page 8 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A A Significant reduction in N/A the margin of safety for ISFSI or cask operation?

Evaluation Summary Retain in 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)

Page 9 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No 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 Yes Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)

(Selection Criteria)

Section 4 Administrative No Controls A significant increase in N/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 N/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 N/A the margin of safety for ISFSI or cask operation?

Page 10 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Evaluation Summary Retain in 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)

Page 11 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No 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 Yes Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)

(Selection Criteria)

Section 4 Administrative No Controls A significant increase in N/A the probability or Risk Insight**:

consequences of an Will removing accident previously this evaluated in the cask requirement FSAR?

from the CoC/TS The possibility of a new or N/A result in different kind of accident being created compared Page 12 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A to those previously evaluated in the FSAR?

A Significant reduction in N/A the margin of safety for ISFSI or cask operation?

Evaluation Summary Retain in 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)

Page 13 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No 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 Yes Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)

(Selection Criteria)

Section 4 Administrative No Controls Risk Insight**: A significant increase in N/A Will removing the probability or this consequences of an requirement accident previously Page 14 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A from the CoC/TS evaluated in the cask result in FSAR?

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

A Significant reduction in N/A the margin of safety for ISFSI or cask operation?

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)

Page 15 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No 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 Yes Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)

(Selection Criteria)

Section 4 Administrative No Controls A significant increase in N/A the probability or Risk Insight**:

consequences of an Will removing accident previously this evaluated in the cask requirement FSAR?

from the CoC/TS The possibility of a new or N/A result in different kind of accident being created compared Page 16 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A to those previously evaluated in the FSAR?

A Significant reduction in N/A the margin of safety for ISFSI or cask operation?

Evaluation Summary Retain in Appendix B Section 3 as this LCO ensures that a subcritical configuration is maintained.

(Criterion L2)

Page 17 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 Yes Technical Conditions for Referenced by LCO 3.1.1 Specifications Operation (LCOs)* L2 No and Surveillance L3 No Requirements (SRs)

(Selection Criteria)

Section 4 Administrative No Controls A significant increase in N/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 N/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 N/A the margin of safety for ISFSI or cask operation?

Evaluation Summary Retain in Appendix B Section 3 as these tables provide information needed to complete LCO 3.1.1.

(Criterion L1)

Page 18 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 Yes Technical Conditions for Referenced by LCO 3.1.1 Specifications Operation (LCOs)* L2 No and Surveillance L3 No Requirements (SRs)

(Selection Criteria)

Section 4 Administrative No Controls A significant increase in N/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 N/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 N/A the margin of safety for ISFSI or cask operation?

Evaluation Summary Retain in Appendix B Section 3 as these Tables provide information needed to complete LCO 3.1.1.

(Criterion L1)

Page 19 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A 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).

CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No 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 Yes Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask Risk Insight**: FSAR?

Will removing The possibility of a new or No this different kind of accident requirement being created compared from the CoC/TS to those previously result in evaluated in the FSAR?

A Significant reduction in First statement (quoted in Evaluation Summary the margin of safety for below) - No ISFSI or cask operation? Rest of section - Yes Without this control program, radioactive material may not be controlled appropriately.

Page 20 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A Evaluation Summary Remove This program implements the requirements of 10 CFR 72.44(d) as this is a regulatory requirement that must be met.

Retain the rest of the text in Appendix B Section 4, Administrative Controls, 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.

Page 21 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No 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 Yes Controls Risk Insight**: A significant increase in No Will removing the probability or Page 22 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A this consequences of an requirement accident previously from the CoC/TS evaluated in the cask result in FSAR?

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

A Significant reduction in Yes the margin of safety for A significant reduction in the margin of safety for ISFSI or cask operation? 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.

Page 23 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A 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 Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No 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 Yes Controls A significant increase in No the probability or consequences of an accident previously evaluated in the cask FSAR?

Risk Insight**:

The possibility of a new or No Will removing different kind of accident this being created compared requirement to those previously from the CoC/TS evaluated in the FSAR?

result in A Significant reduction in 5.3.2 - No the margin of safety for 5.3.3 through 5.3.8 - Yes, based on the importance of ISFSI or cask operation? radiation safety and the unique nature of the HI-STORM design, if the requirements in this were not met a significant reduction in margin could potentially occur.

Evaluation Summary 5.3.1 -Retain in Appendix B section 4, Administrative Controls.

Page 24 of 25

Attachment 27 to Holtec Letter 5018083 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A 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 necessary to assure that the operations involved in the storage of spent fuel in an ISFSI are performed in a safe manner.

Page 25 of 25