ML21068A394
| ML21068A394 | |
| 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: ML21068A394 (27) | |
Text
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: ___AU-1.1_______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix A-100U Section 1.1: Definitions CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use Yes and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 1 Page 1 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: ___AU-1.2_______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix A-100U Section 1.2: Logical Connectors:
The purpose of this section is to explain the meaning of logical connectors.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use Yes and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 1 Page 2 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: ___AU-1.3_______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix A-100U Section 1.3: Completion Times: The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use Yes and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 1 Page 3 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: ___AU-1.4_______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix A-100U Section 1.4: Frequency: The purpose of this section is to define the proper use and application of Frequency requirements.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use Yes and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 1 Page 4 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: ___AU-3.0______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix A-100U Section 3.0: LCO and SR Applicability CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 Yes Technical Conditions for L2 Yes Specifications Operation (LCOs)* L3 Yes and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 3.0. Applies generically to all three criteria (L1, L2, L3).
Page 5 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: ___AU-3.1.1_______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix A-100U LCO 3.1.1: Multi-Purpose Canister (MPC)
The MPC shall be dry and helium filled.
Table 3-1 provides decay heat and burnup limits for forced helium dehydration (FHD) and vacuum drying.
FHD is not subject to time limits. Vacuum drying is subject to the following time limits, from the end of bulk water removal until the start of helium backfill:
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 Yes Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or Risk Insight**:
consequences of an Will removing accident previously this evaluated in the cask requirement FSAR?
from the CoC/TS The possibility of a new or N/A result in different kind of accident being created compared Page 6 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U 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-100U Section 3 as this LCO ensures an inert atmosphere around the fuel cladding and that oxidation of the fuel cladding does not occur, preserving the integrity of the fuel cladding fission product barrier. (Criterion L2)
Page 7 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: __AU-3.1.2________
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix A-100U LCO 3.1.2: SFSC Heat Removal System The SFSC Heat Removal System shall be operable.
Note: The SFSC Heat Removal System is operable when 50% or more of the inlet and outlet vent areas are unblocked and available for flow or when air temperature requirements are met.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 Yes Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an Risk Insight**:
accident previously Will removing evaluated in the cask this FSAR?
requirement The possibility of a new or N/A from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 8 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 3 as this LCO ensures fuel cladding temperatures remain below the limit for normal storage operations, preserving the integrity of the fuel cladding fission product barrier.
(Criterion L2)
Page 9 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: __AU-3.1.3________
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix A-100U LCO 3.1.3: MPC Cavity Reflooding The MPC cavity pressure shall be < 100 psig Note: The LCO is only applicable to wet UNLOADING OPERATIONS.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 Yes Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Page 10 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U Evaluation Summary Retain in Appendix B-100U Section 3 as this LCO ensures an inert atmosphere around the fuel cladding and that oxidation of the fuel cladding does not occur, preserving the integrity of the fuel cladding fission product barrier. (Criterion L2)
Page 11 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: ____ AU-3.1.5______
- 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 A-100U LCO 3.1.5: Impressed Current Cathodic Protection System (ICCPS)
The ICCPS shall be maintained operative.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 Yes Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Page 12 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U Evaluation Summary Retain in Appendix B-100U Section 3 as this LCO ensures the integrity of the containment barrier (Criterion L2)
Page 13 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: ___AU-3.2.2_______
- 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 A-100U LCO 3.2.2: Transfer Cask Surface Contamination Removable contamination on the exterior surfaces of the TRANSFER CASK and accessible portions of the MPC shall each not exceed:
- a. 1000 dpm/100 cm2 from beta and gamma sources
- b. 20 dpm/100 cm2 from alpha sources.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 Yes Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A Risk Insight**: the probability or Will removing consequences of an this accident previously requirement evaluated in the cask from the CoC/TS FSAR?
result in The possibility of a new or N/A different kind of accident Page 14 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U 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-100U Section 3 as this LCO ensures compliance with contamination limits for normal storage operations when not occurring in Fuel Building. (Criterion L3)
Page 15 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: __AU-3.3.1________
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix A-100U LCO 3.3.1: Boron Concentration As required by CoC Appendix B-100U, Table 2.1-2, the concentration of boron in the water in the MPC shall meet the following limits for the applicable MPC model and the most limiting fuel assembly array/class and classification to be stored in the MPC:
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 Yes Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an Risk Insight**:
accident previously Will removing evaluated in the cask this FSAR?
requirement The possibility of a new or N/A from the CoC/TS different kind of accident result in being created compared to those previously evaluated in the FSAR?
Page 16 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 3 as this LCO ensures that a subcritical configuration is maintained.
(Criterion L2)
Page 17 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: __AU-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 A-100U Table 3-1: MPC Cavity Drying Limits for All MPC Types CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 Yes Technical Conditions for Referenced by LCO 3.1.1 Specifications Operation (LCOs)* L2 No and Surveillance L3 No Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 3 as this table provides information needed to complete LCO 3.1.1.
(Criterion L1)
Page 18 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U Page 19 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: ___AU-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 A-100U Table 3-2: Helium Backfill Limits CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 Yes Technical Conditions for Referenced by LCO 3.1.1 Specifications Operation (LCOs)* L2 No and Surveillance L3 No Requirements (SRs)
(Selection Criteria)
Section 4 Administrative No Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 3 as these Tables provide information needed to complete LCO 3.1.1.
(Criterion L1)
Page 20 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: ___AU-5.4_______
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix A-100U Section 5.4: Radioactive Effluent Control Program This program implements the requirements of 10 CFR 72.44(d).
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative Yes Controls A significant increase in No the probability or consequences of an accident previously 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?
Page 21 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U Evaluation Summary Remove This program implements the requirements of 10 CFR 72.44(d) as this is a regulatory requirement that must be met. Retain the rest of the text in Appendix B-100U Section 4.
Page 22 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: ___AU-5.5_______
- 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 A-100U Section 5.5: Cask Transport Evaluation Program This program provides a means for evaluating various transport configurations and transport route conditions to ensure that the design basis drop limits are met. For lifting of the loaded TRANSFER CASK or OVERPACK using devices which are integral to a structure governed by 10 CFR Part 50 regulations, 10 CFR 50 requirements apply. This program is not applicable when the TRANSFER CASK or OVERPACK is in the FUEL BUILDING or is being handled by a device providing support from underneath (i.e., on a rail car, heavy haul trailer, air pads, etc...) or is being handled by a device designed in accordance with the increased safety factors of ANSI N14.6 and having redundant drop protection.
Pursuant to 10 CFR 72.212, this program shall evaluate the site-specific transport route conditions.
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 Page 23 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 4.
Page 24 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: __AU-Table 5-1________
- All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s),
Surveillance Requirement(s), and Frequency(ies). Refer to NUREG-1745 for additional guidance.
- In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less conservative direction?
Requirement Appendix A-100U Table 5-1 Transfer Cask Lifting Requirements CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative Yes Controls A significant increase in N/A the probability or consequences of an accident previously Risk Insight**: evaluated in the cask Will removing FSAR?
this The possibility of a new or N/A requirement different kind of accident from the CoC/TS being created compared result in to those previously evaluated in the FSAR?
A Significant reduction in N/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Retain in Appendix B-100U Section 4.
Page 25 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U CoC Condition/TS Identifier: __AU-5.7________
- 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 A-100U Section 5.7: Radiation Protection Program CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and No Evaluations Section 1 Definitions, Use No and Application Section 2 Approved A1 No Contents (Selection A2 No Criteria) A3 No Appendix B. Section 3 Limiting L1 No Technical Conditions for L2 No Specifications Operation (LCOs)* L3 No and Surveillance Requirements (SRs)
(Selection Criteria)
Section 4 Administrative Yes Controls A significant increase in No the probability or consequences of an accident previously 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 5.7.1 -Retain in Appendix B-100U section 4 5.7.2 - Combine main statement with existing Section 5.7.3 as these discussions are currently repetitive.
Refer to appropriate Part 72 Section: 72.212(b)(5)(iii)
Page 26 of 27
Attachment 32 to Holtec Letter 5014917 CoC Condition/Technical Specification Evaluation Form - CoC original Appendix A-100U 5.7.3 through 9- Retain in Appendix B-100U section 4 Page 27 of 27