ML23072A430

Attachment 3: Holtec International, HI-STORM FW Amendment 9 CoC Reorganization Evaluation Form

ML23072A430
Person / Time
Site:	07201032
Issue date:	03/13/2023
From:	Holtec
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML23072A426	List: ML23072A427 ML23072A428 ML23072A429 ML23072A430 ML23072A431 ML23072A432
References
5018102
Download: ML23072A430 (1)

Text

CoC Condition/Technical Specification Evaluation Form - CoC original Page 2 of 23 Evaluation Summary As this is an introductory statement it does not fit into any of the CoC of Appendix Sections outlines on this evaluation form. Therefore, it will remain in the CoC before Section I. Rewrite to specify correct contents of reorganized Appendices: This certificate is conditioned upon fulfilling the requirements of 10 CFR Part 72, as applicable, the attached Appendix A (Inspections, Tests and Evaluations), Appendix B (Technical Specifications), and the conditions specified below:

Holtec Letter 5018102 Attachment 3 1 of 4

CoC Condition/Technical Specification Evaluation Form - CoC original Page 18 of 23 CoC Condition/TS Identifier: ___CoC-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 CoC Condition 8: Special Requirements for First System in Place: The air mass flow rate through the cask system will be determined by direct measurements of air velocity in the overpack cooling passages for the first HI-STORM FW MPC Cask System placed into service by any user with a heat load equal to or greater than 30 kW. The velocity will be measured using direct measurements of air velocity in the inlet vents. An analysis shall be performed of the cask system with the taken measurements to demonstrate that the measurements validate the analytic methods described in Chapter 4 of the FSAR.

The thermal validation test and analysis results shall be submitted in a letter report to the NRC pursuant to 10 CFR 72.4. To satisfy condition 8 for casks of the same system type, in lieu of additional submittals pursuant to 10 CFR 72.4, users may document in their 72.212 report a previously performed test and analysis submitted by letter report to the NRC that demonstrates validation of the analytic methods described in Chapter 4 of the FSAR.

This condition does not apply to the unventilated version of the system.

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

L1 No L2 No L3 No Holtec Letter 5018102 Attachment 3 2 of 4

CoC Condition/Technical Specification Evaluation Form - CoC original Page 20 of 23 CoC Condition/TS Identifier: ____CoC-9______

• 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 CoC Condition 9: Pre-operational Testing and Training Exercise: A dry run training exercise of the loading, closure, handling, unloading, and transfer of the HI-STORM FW MPC Storage System shall be conducted by the licensee prior to the first use of the system to load spent fuel assemblies. The training exercise shall not be conducted with spent fuel in the MPC. The dry run may be performed in an alternate step sequence from the actual procedures, but all steps must be performed 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/A The possibility of a new or different kind of accident being created compared No/A Holtec Letter 5018102 Attachment 3 3 of 4

CoC Condition/Technical Specification Evaluation Form - CoC original Page 21 of 23 to those previously evaluated in the FSAR?

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

No/A Evaluation Summary Move to Appendix B as these testing and training exercises ensure that the equipment will operate and perform safety functions as designed.

The specifics of dry run training should be performed by the general licensee prior to initial use of the system to load spent fuel. In addition, the general license's training program is subject to NRC inspection.

Holtec Letter 5018102 Attachment 3 4 of 4