ML21068A393

Attachment 31 - HI-STORM 100 Amendment 16 Certificate of Compliance, Appendix B Reorganization Evaluation Form (Non-Proprietary)

ML21068A393
Person / Time
Site:	Holtec
Issue date:	03/09/2021
From:	Holtec
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML21068A360	List: ML21068A361 ML21068A362 ML21068A363 ML21068A364 ML21068A366 ML21068A367 ML21068A368 ML21068A369 ML21068A370 ML21068A372 ML21068A383 ML21068A384 ML21068A385 ML21068A386 ML21068A387 ML21068A388 ML21068A389 ML21068A390 ML21068A391 ML21068A392 ML21068A393 ML21068A394 ML21068A395 ML21068A396 ML21068A397 ML21068A398
References
5014917, CoC No. 1014
Download: ML21068A393 (61)

Text

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 1 of 61 CoC Condition/TS Identifier: ___B-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 B Section 2.1: Fuel Specifications and Loading Conditions 2.1.1: Fuel to be Stored In The HI-STORM 100 SFSC System 2.1.2: Uniform Fuel Loading 2.1.3: Regionalized Fuel Loading 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 Yes A2 Yes A3 Yes 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?

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

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

N/A 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 2 of 61 Evaluation Summary Retain in Appendix B Section 2. Applies generically to all three criteria (A1, A2, A3).

1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 3 of 61 CoC Condition/TS Identifier: __B-2.2________

• 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 B Section 2.2: Violations If any Fuel Specifications or Loading Conditions of 2.1 are violated, the following actions shall be completed:

2.2.1 The affected fuel assemblies shall be placed in a safe condition.

2.2.2 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, notify the NRC Operations Center.

2.2.3 Within 30 days, submit a special report which describes the cause of the violation, and actions taken to restore compliance and prevent recurrence.

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?

N/A The possibility of a new or different kind of accident being created compared N/A 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 4 of 61 to those previously evaluated in the FSAR?

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

N/A Evaluation Summary Retain in Appendix B Section 4 as these are procedural and record keeping administrative controls.

1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 5 of 61 CoC Condition/TS Identifier: ___B-Fig. 2.1-1 through 2.1-4_______

• 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 B Figures 2.1-1 through 2.1-4 illustrate the fuel loading regions for the applicable MPCs 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as these tables illustrate fuel loading information necessary to understand the information in other tables in this section. (Criterion A2) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 6 of 61 CoC Condition/TS Identifier: __B-Table 2.1-1________

• 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 B Table 2.1-1: Fuel Assembly 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Table provides information such as enrichment, cooling time, and assembly condition (72.236(a)). (Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 7 of 61 CoC Condition/TS Identifier: ___B-Table 2.1-2_______

• 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 B Table 2.1-2: PWR Fuel Assembly Characteristics 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Table provides information such as enrichment (72.236(a)).

(Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 8 of 61 CoC Condition/TS Identifier: ___B-Table 2.1-3_______

• 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 B Table 2.1-3: BWR Fuel Assembly Characteristics 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Table provides information such as enrichment (72.236(a)).

(Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 9 of 61 CoC Condition/TS Identifier: ___B-Table 2.1-8 _______

• 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 Appendix B Table 2.1-8: Non-Fuel Hardware Cooling and Average Burnup 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Table provides cooling time and burnup for approved content.

(Criterion A2) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 10 of 61 CoC Condition/TS Identifier: __B-Table 2.1-9_ _______

• 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 Appendix B Table 2.1-9: Restrictions for Partial Gadolinium Credit in MPC-68M 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Table provides cooling time and burnup for approved content.

(Criterion A2) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 11 of 61 CoC Condition/TS Identifier: ___B-2.4.1 _______

• 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 B Section 2.4: Decay Heat Limits for ZR-Clad Fuel This section provides the limits on ZR-clad fuel assembly decay heat, burnup, and cooling time for storage in the HI-STORM 100 System. The method to calculate the limits and verify compliance, including examples, is provided in Chapter 12 of the HI-STORM 100 FSAR.

2.4.1: Uniform Fuel Loading Decay Heat Limits for ZR-clad fuel for VENTILATED OVERPACK Table 2.4-1 provides the maximum allowable decay heat per fuel storage location for ZR-clad fuel in uniform fuel loading for each MPC model.

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 Yes 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?

N/A 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 12 of 61 The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on decay heat limits (72.236(a)).

(Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 13 of 61 CoC Condition/TS Identifier: ___ B-Table 2.4-1_______

• 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 B Table 2.4-1: Maximum Allowable Decay Heat per Fuel Storage Location (Uniform Loading, ZR-Clad)

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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on decay heat limits (72.236(a)).

(Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 14 of 61 CoC Condition/TS Identifier: __B-2.4.2_ _______

• 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 B Section 2.4.2 Regionalized Fuel Loading Decay Heat Limits for ZR-Clad Fuel for VENTILATED OVERPACK The maximum allowable decay heat per fuel storage location for intact or undamaged fuel assemblies in regionalized loading is determined using the following equations:

Q(X) = 2 x Q0 / (1 + Xy) y = 0.23 / X0.1 q2 = Q(X) / (n1 x X +n2) q1 = q2 x X Where:

Q0 = Maximum uniform storage MPC decay heat (34 kW)

X = Inner region to outer region assembly decay heat ratio (0.5 X 3) n1 = Number of storage locations in inner region from Table 2.4-2.

n2 = Number of storage locations in outer region from Table 2.4-2.

Allowable heat loads for Damaged Fuel and Fuel Debris in regionalized loading are shown in Table 2.4-

5.

Optional loading patterns for MPC-68M are shown in Figures 2.4-1 through 2.4-4.

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 A1 Yes A2 No 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 15 of 61 Section 2 Approved Contents (Selection Criteria)

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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on decay heat limits (72.236(a)).

(Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 16 of 61 CoC Condition/TS Identifier: ___B-Table 2.4-2 _______

• 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 B Table 2.4-2: Fuel Storage Regions per MPC 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this table provides information on acceptable loading patterns for an MPC. (Criterion A2) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 17 of 61 CoC Condition/TS Identifier: ___B-Table 2.4-5 _______

• 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 B Table 2.4-5: Allowable Heat Load for Damaged Fuel Assemblies and Fuel Debris under Regionalized Loading 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this table provides information on acceptable loading patterns for an MPC. (Criterion A2) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 18 of 61 CoC Condition/TS Identifier: ___B-2.4.3 _______

• 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 B Section 2.4.3: Burnup Limits as a Function of Cooling Time for ZR-Clad Fuel for Ventilated Overpack The maximum allowable ZR-clad fuel assembly average burnup varies with the minimum required fuel assembly cooling time. Tables 2.4-3 and 2.4-4 provide for each MPC the allowable maximum burnup based on the assemblys particular cooling time.

2.4.3.1 Linear interpolation of burnups between cooling times is permitted. For example, the allowable burnup for a cooling time of 4.5 years may be interpolated between those burnups calculated for 4 year and 5 years.

2.4.3.2 Calculated burnup limits shall be rounded down to the nearest integer.

2.4.3.3 Calculated burnup limits greater than 68,200 MWD/MTU for PWR fuel and 65,000 MWD/MTU for BWR must be reduced to be equal to these values.

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 Yes 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 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 19 of 61 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on decay heat limits (72.236(a)).

(Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 20 of 61 CoC Condition/TS Identifier: __B-2.4.4_ _______

• 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 B Section 2.4.4: When complying with the maximum fuel storage location decay heat limits, users must account for the decay heat from both the fuel assembly and any NON-FUEL HARDWARE, as applicable for the particular fuel storage location, to ensure the decay heat emitted by all contents in a storage location does not exceed the limit.

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 Yes 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?

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

N/A 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 21 of 61 A Significant reduction in the margin of safety for ISFSI or cask operation?

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on decay heat limits (72.236(a)).

(Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 22 of 61 CoC Condition/TS Identifier: __B-2.4.5_ _______

• 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 B Section 2.4.5: Fuel Loading Decay Heat Limits for Unventilated Overpack Tables 2.4-6a and 2.4-6b provide the maximum allowable decay heat per fuel storage location for MPC-68M in HI-STORM 100 Version UVH.

A minor deviation from the prescribed loading pattern in an MPCs permissible contents to allow one slightly thermally-discrepant fuel assembly per quadrant to be loaded as long as the peak cladding temperature for the MPC remains below the ISG-11 Rev 3 requirements is permitted for essential dry storage campaigns to support decommissioning.

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 Yes 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 A significant increase in the probability or consequences of an accident previously N/A 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 23 of 61 from the CoC/TS result in 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?

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on decay heat limits (72.236(a)).

(Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 24 of 61 CoC Condition/TS Identifier: __B-2.4.6_ _______

• 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 B Section 2.4.6: Burnup and Cooling Time Qualifications for the MPC-68M for Unventilated Overpack The burnup and cooling time for every fuel loaded into the MPC-68M must satisfy the following equation:

= 3 + 2 + +

where, Ct

= Minimum cooling time (years),

Bu

= Assembly-average burnup (MWd/mtU),

A, B, C, D

= Polynomial coefficients listed in Table 2.4-9 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 Yes 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?

N/A 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 25 of 61 The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on burnup and cooling time (72.236(a)). (Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 26 of 61 CoC Condition/TS Identifier: ___B-Table 2.4-3 _______

• 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 B Table 2.4-3: PWR Fuel Assembly Burnup and Cooling Time Limits for Ventilated Overpack 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on fuel assembly burnup and cooling time limits (72.236(a)). (Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 27 of 61 CoC Condition/TS Identifier: ___B-Table 2.4-4 _______

• 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 B Table 2.4-4: BWR Fuel Assembly Burnup and Cooling Time Limits for Ventilated Overpack 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on fuel assembly burnup and cooling time limits (72.236(a)). (Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 28 of 61 CoC Condition/TS Identifier: ___B-Table 2.4-6a _______

• 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 B Table 2.4-6a: MPC-68M Heat Load Data for Unventilated Overpack 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)).

(Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 29 of 61 CoC Condition/TS Identifier: ___B-Table 2.4-6b _______

• 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 B Table 2.4-6b: MPC-68M Requirements on Developing Regionalized Heat Load Patterns for Unventilated Overpack 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)).

(Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 30 of 61 CoC Condition/TS Identifier: ___B-Table 2.4-7 _______

• 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 B Table 2.4-7: Section Heat Load Calculations for MPC-68M for Unventilated Overpack 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)).

(Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 31 of 61 CoC Condition/TS Identifier: ___B-Table 2.4-8 _______

• 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 Appendix B Table 2.4-8: DFC and DFI Storage Locations with Heat Load penalties for MPC-68M for Unventilated Overpack 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)).

(Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 32 of 61 CoC Condition/TS Identifier: ___B-Table 2.4-9 _______

• 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 Appendix B Table 2.4-9: Burnup and Cooling Time Fuel Qualification Requirements for MPC-68M for Unventilated Overpack 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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on burnup and cooling time limits (72.236(a)). (Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 33 of 61 CoC Condition/TS Identifier: __B-Fig. 2.4-1 through 2.4-4_ _______

• 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 B Figures 2.4-1 through 2.4-4: QSHL through QSHL-4 Patterns Per Cell Allowable Heat Loads (kW) - MP68M.

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 Yes 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?

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

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

N/A Evaluation Summary Retain in Appendix B Section 2 as this Section provides information on heat load limits (72.236(a)).

(Criterion A1) 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 34 of 61 CoC Condition/TS Identifier: ___B-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 B Section 3.1: Site 3.1.1: Site Location The HI-STORM 100 Cask System is authorized for general use by 10 CFR Part 50 license holders at various site locations under the provisions of 10 CFR 72, Subpart K.

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 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 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 35 of 61 A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary Eliminate from CoC - not required as compliance with the QA provisions in 10 CFR 72 Subpart K is a regulatory requirement that must be met.

1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 36 of 61 CoC Condition/TS Identifier: ___B-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 B Section 3.2: Design Features Important for Criticality Control 3.2.1 MPC-24

1. Flux trap size: 1.09 in.

2. 10B loading in the neutron absorbers:

0.0267 g/cm2 (Boral) and 0.0223 g/cm2 (METAMIC) 3.2.2 MPC-68 and MPC-68FF

1. Fuel cell pitch: 6.43 in.

2. 10B loading in the neutron absorbers:

0.0372 g/cm2 (Boral) and 0.0310 g/cm2 (METAMIC) 3.2.3 MPC-68F

1. Fuel cell pitch: 6.43 in.

2. 10B loading in the Boral neutron absorbers:

0.01 g/cm2 3.2.4 MPC-24E and MPC-24EF

1. Flux trap size:

i.

Cells 3, 6, 19, and 22: 0.776 inch ii.

All Other Cells: 1.076 inches

2. 10B loading in the neutron absorbers:

0.0372 g/cm2 (Boral) and 0.0310 g/cm2 (METAMIC) 3.2.5 MPC-32 and MPC-32F

1. Fuel cell pitch: 9.158 inches

2.

10B loading in the neutron absorbers:

0.0372 g/cm2 (Boral) and 0.0310 g/cm2 (METAMIC) 3.2.6 MPC-68M

1. Basket Cell wall thickness 0.4 in. (nom.)

2. B4C content in METAMIC-HT shall be 10 wt.

3.2.7 Fuel spacers shall be sized to ensure that the active fuel region of intact or undamaged fuel assemblies remains within the neutron poison region of the MPC basket with water in the MPC.

3.2.8 The B4C content in METAMIC shall be 33.0 wt.%. 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 37 of 61 CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes 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 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?

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

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

N/A Evaluation Summary Retain in Appendix A - design feature important to criticality control 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 38 of 61 CoC Condition/TS Identifier: ___B-3.2.9 _______

• 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 Appendix B Section 3.2.9: Neutron Absorber Tests Boral and Metamic Classic Section 9.1.5.3 of the HI-STORM 100 FSAR is hereby incorporated by reference into the HI-STORM 100 CoC. For each MPC model specified in Sections 3.2.1 through 3.2.5 above, the neutron absorber shall meet the minimum requirements for 10B areal density or B4C content, as applicable.

Metamic-HT (Section 3.2.6 above)

1. The weight percentage of the boron carbide must be confirmed to be greater than or equal to 10% in each lot of Al/B4C powder.

2. The areal density of the B-10 isotope corresponding to the 10% min. weight density in the manufactured Metamic-HT panels shall be independently confirmed by the neutron attenuation test method by testing at least one coupon from a randomly selected panel in each lot.

3. If the B-10 areal density criterion in the tested panels fails to meet the specific minimum, then the manufacturer has the option to reject the entire lot or to test a statistically significant number of panels and perform statistical analysis for acceptance.

4. All test procedures used in demonstrating compliance with the above requirements shall conform to the cask designers QA program which has been approved by the USNRC under docket number 71-0784.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No A1 No 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 39 of 61 Section 2 Approved Contents (Selection Criteria)

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?

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

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

N/A Evaluation Summary Retain in Appendix A as the described tests ensure the MPC has been manufactured and will operate in conformance with the certified design, and that the safety functions of confinement, sub-criticality and shielding will be performed.

1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 40 of 61 CoC Condition/TS Identifier: ___B-3.3 _______

• 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 B Section 3.3: Codes and Standards The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 1995 Edition with Addenda through 1997, is the governing Code for the HI-STORM 100 System MPCs, OVERPACKs, and TRANSFER CASKs, as clarified in Specification 3.3.1 below, except for Code Sections V and IX. The latest effective editions of ASME Code Sections V and IX, including addenda, may be used for activities governed by those sections, provided a written reconciliation of the later edition against the 1995 Edition, including addenda, is performed by the certificate holder. American Concrete Institute (ACI) 349-85 is the governing Code for plain concrete as clarified in Appendix 1.D of the Final Safety Analysis Report for the HI-STORM 100 Cask System.

CoC Body Certified Design Section I. Technology No Section II. Design Features Yes 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 No Risk Insight**:

Will removing this A significant increase in the probability or consequences of an N/A 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 41 of 61 requirement from the CoC/TS result in 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?

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

N/A Evaluation Summary Retain in CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs.

1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 42 of 61 CoC Condition/TS Identifier: ___B-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 B Section: Alternatives to Codes, Standards, and Criteria Table 3-1 lists approved alternatives to the ASME Code for the design of the MPCs, OVERPACKs, and TRANSFER CASKs of the HI-STORM 100 Cask System CoC Body Certified Design Section I. Technology No Section II. Design Features Yes 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 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?

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

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

N/A 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 43 of 61 Evaluation Summary Retain in CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs.

1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 44 of 61 CoC Condition/TS Identifier: ___B-3.3.2 _______

• 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 B Section 3.3.2: Construction/Fabrication Alternatives to Codes, Standards, and Criteria Proposed alternatives to the ASME Code, Sections II and III, 1995 Edition with Addenda through 1997 including modifications to the alternatives allowed by Specification 3.3.1 may be used on a case-specific basis when authorized by the Director of the Office of Nuclear Material Safety and Safeguards or designee.

The request for such alternative should demonstrate that:

1. The proposed alternatives would provide an acceptable level of quality and safety, or

2. Compliance with the specified requirements of the ASME Code,Section III, 1995 Edition with Addenda through 1997, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Requests for alternatives shall be submitted in accordance with 10 CFR 72.4.

CoC Body Certified Design Section I. Technology No Section II. Design Features Yes Appendix A - Inspections, Tests, and Evaluations 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 L1 No L2 No L3 No 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 45 of 61 Requirements (SRs)

(Selection Criteria)

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?

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

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

N/A Evaluation Summary Retain in CoC Section II as this explains which Codes and Standards are applicable to the cask and canister designs.

1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 46 of 61 CoC Condition/TS Identifier: ___ B-Table 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 B Table 3-1: List of ASME Code Alternatives for HI-STORM 100 Cask System CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes 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 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?

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

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

N/A Evaluation Summary While this Table could potentially be removed without any risk impact, the removal could increase the need for cumbersome alternative code use 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 47 of 61 approval requests. Therefore, this table will be retained in Appendix A.

1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 48 of 61 CoC Condition/TS Identifier: ___B-3.4 _______

• 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 B Section 3.4: Site Specific Parameters and Analyses that will require verification by the system user CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes 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 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?

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

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

N/A 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 49 of 61 Evaluation Summary Retained in Appendix A as this includes key generic design criteria used by the CoC holder in the cask design, which require general licensee evaluation.

1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 50 of 61 CoC Condition/TS Identifier: ___B-3.5 _______

• 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 B Section 3.5: Cask Transfer Facility (CTF) 3.5.1: Transfer Cask and MPC Lifters 3.5.2: CTF Structure Requirements 3.5.2.1: Cask Transfer Station and Stationary Lifting Devices 3.5.2.2: Mobile Lift Devices CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes 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 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?

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

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

N/A 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 51 of 61 Evaluation Summary Retained in Appendix A as this includes design features for equipment that is only needed under specified circumstances, unlike the main equipment for the system described in CoC Sections I and II.

1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 52 of 61 CoC Condition/TS Identifier: ___B-Table 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 B Table 3-2: Load Combinations and Service Condition Definitions for the CTF Structure CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes 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 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?

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

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

N/A Evaluation Summary Retained in Appendix A as this includes design features for equipment that is only needed under specified circumstances, unlike the main equipment for the system described in CoC Sections I and II. 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 53 of 61 CoC Condition/TS Identifier: ___B-3.6 _______

• 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 B Section 3.6: Forced Helium Dehydration System 3.6.1: System Description 3.6.2: Design Criteria 3.6.3: Fuel Cladding Temperature 3.6.4: Pressure Monitoring During FHD Malfunction CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes 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 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?

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

N/A 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 54 of 61 A Significant reduction in the margin of safety for ISFSI or cask operation?

N/A Evaluation Summary Retained in Appendix A as this includes design features for equipment that is only needed under specified circumstances, unlike the main equipment for the system described in CoC Sections I and II.

1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 55 of 61 CoC Condition/TS Identifier: ___B-3.7 _______

• 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 B Section 3.7: Supplemental Cooling System 3.7.1: System Description 3.7.2: Design Criteria CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes 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 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?

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

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

N/A Evaluation Summary Retained in Appendix A as this includes design features for equipment that is only needed under 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 56 of 61 specified circumstances, unlike the main equipment for the system described in CoC Sections I and II.

1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 57 of 61 CoC Condition/TS Identifier: ___B-Table 3-3 _______

• 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 B Table 3-3: Requirements for Supplemental Cooling System CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes 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 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?

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

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

N/A Evaluation Summary Retained in Appendix A as this contains information important to the use of the Supplemental Cooling System.

1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 58 of 61 CoC Condition/TS Identifier: ___B-3.8 _______

• 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 Appendix B Section 3.8: Combustible Gas Monitoring During MPC Lid Welding and Cutting During MPC lid-to-shell welding and cutting operations, combustible gas monitoring of the space under the MPC lid is required, to ensure that there is no combustible mixture present.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes 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 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?

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

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

N/A 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 59 of 61 Evaluation Summary Retained in Appendix A as these are monitoring requirements 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 60 of 61 CoC Condition/TS Identifier: ___B-3.9 _______

• 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 Appendix B Section 3.9: Environmental Temperature Requirements TRANSPORT OPERATIONS involving the HI-TRAC transfer cask can be carried out if the reference ambient temperature (three day average around the cask) is above 0°F and below the Threshold Temperature of 110 deg. F ambient temperature, applicable during HI-TRAC transfer operations inside the 10 CFR Part 50 or 10 CFR Part 52 structural boundary and 90 deg. F outside of it. The determination of the Threshold Temperature compliance shall be made based on the best available thermal data for the site.

If the reference ambient temperature exceeds the corresponding Threshold Temperature then a site specific analysis shall be performed using the actual heat load and reference ambient temperature equal to the three day average to ensure that the steady state peak fuel cladding temperature will remain below the 400°C limit. If the peak fuel cladding temperature exceeds 400°C limit then the operation of a Supplemental Cooling System (SCS) in accordance with LCO 3.1.4 is mandatory.

SCS operation is mandatory if site data is not available or if a user elects to deploy Supplemental Cooling in lieu of site ambient temperature evaluation.

CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations Yes Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No A1 No A2 No 1 to Holtec Letter 5014917

CoC Condition/Technical Specification Evaluation Form - CoC original Appendix B Page 61 of 61 Section 2 Approved Contents (Selection Criteria)

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?

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

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

N/A Evaluation Summary Retained in Appendix A as this includes design features for equipment that is only needed under specified circumstances, unlike the main equipment for the system described in CoC Sections I and II.

1 to Holtec Letter 5014917