ML23072A430
| ML23072A430 | |
| Person / Time | |
|---|---|
| Site: | 07201032 |
| Issue date: | 03/13/2023 |
| From: | Holtec |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML23072A426 | List: |
| References | |
| 5018102 | |
| Download: ML23072A430 (1) | |
Text
CoC Condition/Technical Specification Evaluation Form - CoC original
Evaluation Summary As this is an introductory statement it does not fit into any of the CoC of Appendix Sections outlines on this evaluation form. Therefore, it will remain in the CoC before Section I. Rewrite to specify correct contents of reorganized Appendices: This certificate is conditioned upon fulfilling the requirements of 10 CFR Part 72, as applicable, the attached Appendix A (Inspections, Tests and Evaluations), Appendix B (Technical Specifications), and the conditions specified below:
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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: Special Requirements for First System in Place: The air mass flow rate through the cask system will be determined by direct measurements of air velocity in the overpack cooling passages for the first HI-STORM FW MPC Cask System placed into service by any user with a heat load equal to or greater than 30 kW. The velocity will be measured using direct measurements of air velocity in the inlet vents. An analysis shall be performed of the cask system with the taken measurements to demonstrate that the measurements validate the analytic methods described in Chapter 4 of the FSAR.
The thermal validation test and analysis results shall be submitted in a letter report to the NRC pursuant to 10 CFR 72.4. To satisfy condition 8 for casks of the same system type, in lieu of additional submittals pursuant to 10 CFR 72.4, users may document in their 72.212 report a previously performed test and analysis submitted by letter report to the NRC that demonstrates validation of the analytic methods described in Chapter 4 of the FSAR.
This condition does not apply to the unventilated version of the system.
CoC Body Section I. Technology No Certified Design Section II. Design Features No Appendix A - Inspections, Tests, and NoYes Evaluations Section 1 Definitions, Use No and Application Appendix B. Section 2 Approved A1 No Technical Contents (Selection A2 No Specifications Criteria) A3 No Section 3 Limiting L1 No Conditions for L2 No Operation (LCOs)* L3 No
Page 18 of 23 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: Pre-operational Testing and Training Exercise: A dry run training exercise of the loading, closure, handling, unloading, and transfer of the HI-STORM FW MPC Storage System shall be conducted by the licensee prior to the first use of the system to load spent fuel assemblies. The training exercise shall not be conducted with spent fuel in the MPC. The dry run may be performed in an alternate step sequence from the actual procedures, but all steps must be performed CoC Body 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/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 No/A different kind of accident being created compared
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to those previously evaluated in the FSAR?
A Significant reduction in No/A the margin of safety for ISFSI or cask operation?
Evaluation Summary Move to Appendix B as these testing and training exercises ensure that the equipment will operate and perform safety functions as designed.
The specifics of dry run training should be performed by the general licensee prior to initial use of the system to load spent fuel. In addition, the general license's training program is subject to NRC inspection.
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