ML21068A391
| ML21068A391 | |
| Person / Time | |
|---|---|
| Site: | Holtec |
| Issue date: | 03/09/2021 |
| From: | Holtec |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML21068A360 | List: |
| References | |
| 5014917, CoC No. 1014 | |
| Download: ML21068A391 (25) | |
Text
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original CoC Condition/TS Identifier: ____CoC-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 CoC Condition 1:
- a. Model No.: HI-STORM 100 Cask System
- b. Description CoC Body Section I. Technology Yes 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 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 CoC Section I.
Page 1 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original CoC Condition/TS Identifier: ____CoC-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 CoC Condition 2: Operating Procedures: Written operating procedures shall be prepared for cask handling, loading, movement, surveillance, and maintenance. The users site-specific written operating procedures shall be consistent with the technical basis described in Chapter 8 of the FSAR.
CoC Body Section I. Technology No Certified Design Section II. Design Features Yes 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 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 2 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Evaluation Summary Retain in CoC Section II Page 3 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original CoC Condition/TS Identifier: ____CoC-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 CoC Condition 3: Acceptance tests and maintenance program: Written cask acceptance tests and maintenance program shall be prepared consistent with the technical basis described in Chapter 9 of the FSAR.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes 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 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 Statement retained in Appendix A Section 1 Page 4 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original CoC Condition/TS Identifier: ___CoC-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 CoC Condition 4: Quality: Activities in the areas of design, purchase, fabrication, assembly, inspection, testing, operation, maintenance, repair, modification of structures, systems and components, and decommissioning that are important to safety shall be conducted in accordance with a Commission-approved quality assurance program which satisfies the applicable requirements of 10 CFR Part 72, Subpart G, and which is established, maintained, and executed with regard to the cask system.
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 No Controls A significant increase in No 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 No from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 5 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original A Significant reduction in No the margin of safety for ISFSI or cask operation?
Evaluation Summary Eliminate from CoC - not required as compliance with the QA provisions in 10 CFR 72 Subpart G is a regulatory requirement that must be met.
Page 6 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original CoC Condition/TS Identifier: ____CoC-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 CoC Condition 5: Heavy Loads Requirements: Each lift of an MPC, a HI-TRAC transfer cask, or any HI-STORM overpack must be made in accordance to the existing heavy loads requirements and procedures of the licensed facility at which the lift is made. A plant-specific review (under 10 CFR 50.59 or 10 CFR 72.48, if applicable) is required to show operational compliance with existing plant specific heavy loads requirements. Lifting operations outside of structures governed by 10 CFR Part 50 must be in accordance with Section 5.5 of Appendix A or Section 5.2 of Appendix C and Sections 3.4.6 and 3.5 (if applicable) of Appendix B or D, for above ground systems, section 5.5 of Appendix A-100U for the underground systems.
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 N/A Will removing the probability or this consequences of an requirement accident previously from the CoC/TS evaluated in the cask result in FSAR?
Page 7 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original 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 Page 8 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original CoC Condition/TS Identifier: ___CoC-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 CoC Condition 6: Approved Contents: Contents of the HI-STORM 100 Cask System must meet the fuel specifications given in Appendices B or D, as applicable, for aboveground systems or B-100U for underground systems to this certificate.
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 Yes Contents (Selection A2 Criteria) A3 Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in No the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or No requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in No the margin of safety for ISFSI or cask operation?
Evaluation Summary Remove from the CoC - This statement in the CoC merely points to information in the Appendices.
Page 9 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original CoC Condition/TS Identifier: ___CoC-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 CoC Condition 7: Design Features: Features or characteristics for the site, cask or ancillary equipment must be in accordance with Appendices B for aboveground systems or B-100U for underground systems to this certificate.
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 No Controls A significant increase in No 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 No from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 10 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original A Significant reduction in No the margin of safety for All important design features will be discussed in the ISFSI or cask operation? CoC Evaluation Summary Deleted as this information will now be in the CoC.
Page 11 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original 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: Changes to the CoC: The holder of this certificate who desires to make changes to the certificate, which includes Appendices A and A-100U (Technical Specifications) and Appendices B and B-100U (Approved Contents and Design Features), shall submit an application for amendment of the certificate.
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 No Controls A significant increase in No 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 No from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 12 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original A Significant reduction in No the margin of safety for ISFSI or cask operation?
Evaluation Summary Eliminate from CoC - not required as 10CFR72 does not allow changes to the CoC of its appendices without an application for amendment to the certificate.
Page 13 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original 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: Special Requirements for First System in Place 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 A Page 14 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original CoC Condition/TS Identifier: ____CoC-10______
- 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 10: Pre-operational Testing and Training Exercise CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and Yes 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 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 A Page 15 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original CoC Condition/TS Identifier: ___CoC-11_______
- 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 11: 11. The NRC has approved an exemption request by the CoC applicant from the requirements of 10 CFR 72.236(f), to allow a Supplemental Cooling System to provide for decay heat removal in accordance with Section 3.1.4 of Appendices A, C, and A-100U.
CoC Body Section I. Technology No Certified Design Section II. Design Features Yes 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 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 16 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Evaluation Summary Retain in Section II. The supplement cooling system is a design feature approved for decay heat removal.
Further information about the supplemental cooling system can be found in Appendix A.
Page 17 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original CoC Condition/TS Identifier: ____CoC-13______
- 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 13: Authorization: The HI-STORM 100 Cask System, which is authorized by this certificate, is hereby approved for general use by holders of 10 CFR Part 50 licenses for nuclear reactors at reactor sites under the general license issued pursuant to 10 CFR 72.210, subject to the conditions specified by 10 CFR 72.212, this certificate, and the attached Appendices A, B, A-100U, B-100U, C, and D as applicable. The HI-STORM 100 Cask System may be fabricated and used in accordance with any approved amendment to CoC No. 1014 listed in 10 CFR 72.214.
Each of the licensed HI-STORM 100 System components (i.e., the MPC, overpack, and transfer cask), if fabricated in accordance with any of the approved CoC Amendments, may be used with one another provided an assessment is performed by the CoC holder that demonstrates design compatibility.
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 No Controls Risk Insight**: A significant increase in No Will removing the probability or this consequences of an requirement accident previously from the CoC/TS evaluated in the cask result in FSAR?
Page 18 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original 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 No the margin of safety for ISFSI or cask operation?
Evaluation Summary Eliminate from CoC - not required as these are regulatory requirements (10 CFR 72.210 through 72.214) that must be met.
Page 19 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original CoC Condition/TS Identifier: ____CoC-14______
- 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 14: FSAR UPDATE FOR RENEWED COC: The CoC holder shall submit an updated FSAR to the Commission, in accordance with 10 CFR 72.4, within 90 days after the effective date of the renewal.
The updated FSAR shall reflect the changes and CoC holder commitments resulting from the review and approval of the renewal of the CoC.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Section III. CoC Renewal Yes 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 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 20 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary CoC Section III is not part of the proposed outline (reference), however, this information is judged to be significant enough to include in the main CoC.
Page 21 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original CoC Condition/TS Identifier: ____CoC-15______
- 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 15: 72.212 EVALUATIONS FOR RENEWED COC USE: Any general licensee that initiates spent fuel dry storage operations with the HI-STORM 100 system after the effective date of the renewal of the CoC and any general licensee operating a HI-STORM 100 system as of the effective date of the renewal of the CoC, including those that put additional storage systems into service after that date, shall:
- a. As part of the evaluations required by 10CFR72.212(b)(5), include the evaluations related to the terms, conditions, and specifications of this CoC amendment as modified (i.e., changed or added) as a result of the renewal of the CoC.
- b. As part of the document review required by 10CFR72.212(b)(6), include a review of the FSAR changes resulting from the renewal of the CoC; and
- c. Ensure that the evaluations required by 10CFR72.212(b)(7) and (8) capture the evaluations and review described in (a) and (b) of this CoC condition.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Section III. CoC Renewal Yes Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Appendix B.
Contents (Selection A2 No Technical Criteria) A3 No Specifications Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No Page 22 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original 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 CoC Section III is not part of the proposed outline (reference), however, this information is judged to be significant enough to include in the main CoC.
Page 23 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original CoC Condition/TS Identifier: ____CoC-16______
- 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 16: AMENDMENTS AND REVISIONS FOR RENEWED COC: All future amendments and revisions to this CoC shall include evaluations of the impacts to aging management activities (i.e., time limited aging analyses and aging management programs to assure they remain adequate for any changes to SSCs within the scope of renewal.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Section III. CoC Renewal Yes 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 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 24 of 25
Attachment 29 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary CoC Section III is not part of the proposed outline (reference), however, this information is judged to be significant enough to include in the main CoC.
Page 25 of 25