Text

Exemption Request from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 to Support the Dry Fuel Loading Campaign
	ML17142A358
Person / Time
Site:	Vermont Yankee, Holtec
Issue date:	05/16/2017
From:	Chappell C; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
	BVY 17-006
	Download: ML17142A358 (66)
	v • d • e

Withhold from public disclosure under 10 CFR 2.390(a)(4)

Entergy Nuclear Operations, Inc .

Vermont Yankee 320 Governor Hunt Rd.

~ Entergy Vernon, VT 05354 802-257-7711 Coley Chappell Manager, Design and Programs 10 CFR 72.7 BVY 17-006 May16, 2017 ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington , DC 20555-0001

SUBJECT:

Exemption Request from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 to Support the Dry Fuel Loading Campaign Vermont Yankee Nuclear Power Station License No. DPR-28 Docket Nos. 50-271, 72-59 and 72-1014

REFERENCES:

1. Letter, USN RC to Holtec International, "Certificate of Compliance No. 1014, Amendment No. 10 for the HI-STORM 100 Cask System (CAC No. L24979) ," dated May 25, 2016 (ML16144A177)

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Schedule Change for Dry Fuel Loading Campaign," BVY 17-013, dated April 12, 2017 (ML17104A050)

Dear Sir or Madam:

Pursuant to 10 CFR 72.7, "Specific Exemptions," Entergy Nuclear Operations , Inc. (ENO) requests an exemption from certain requirements of 10 CFR 72.212 and 10 CFR 72.214 for Vermont Yankee Nuclear Power Station (VY) . These regulations require , in part, compliance with the terms and conditions of the Holtec International (Holtec) H 1- S T 0 RM 1 OO Cask System Certificate of Compliance (CoC) No. 72-1014 Amendment No.1 O (Reference 1) for spent fuel storage at the VY Independent Spent Fuel Storage Installation (ISFSI). Specifically, the requested exemption would allow the loading of selected fuel assemblies with shorter cooling times and higher heat loads than those specified in Reference 1 into MPC-68M multi-purpose canisters (MPCs) , and an optional regionalized loading pattern for the MPC-68M. The requested exemption, if approved, is expected to result in significant operational benefits including substantial avoided costs due to earlier completion of the transfer to dry fuel storage.

The exemption req uest is provided in Attachment 1 to this letter. Attachment 2 provides additional information that supports this exemption request as referenced in Attachment 1. provides a mark-up of the pertinent pages of Appendices A and B to the CoC to aid in the review of this exemption request. Attachment 4 contains an analysis of the avoided costs resulting from earlier completion of the VY dry fuel storage loading campaign. rJ; L1 ~ /)

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BVY 17-006 I Page 2 of 3 Attachment 5 to this letter is an affidavit prepared in accordance with 10 CFR 2.390 requesting that the proprietary reports provided in Attachment 6 be withheld from public disclosure. Any questions regarding the withholding of proprietary information should be addressed to: Holtec International, Ms. Kimberly Manzione, Licensing Manager, One Holtec Drive, Marlton, NJ 08053.

Attachment 6 contains (1) a proprietary Cask Dose Rate Limits Report, which provides an analysis of the surface dose rates for the transfer cask and HI-STORM overpacks, and (2) a proprietary Dose Versus Distance Report , which provides an analysis of the off-site dose rate from the VY ISFSI.

These reports demonstrate compliance with the applicable sections of the CoC and with applicable federal and state regulations for the representative VY cask loading plan based on the requested exemption.

When separated from Attachment 6, this cover letter and Attachments 1 through 5 are decontrolled.

ENO requests approval of this exemption request by October 31, 2017, to support VY's dry fuel storage loading campaign schedule (Reference 2).

This letter contains no new regulatory commitments. Should you have any questions concerning this letter, please contact me at (802) 451-3374.

Sincerely,

~

CCC/tbs Attachments:

1. Request for Specific Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214

2. Supporting FSAR Pages from HI-STORM 100 Amendment Request No. 12

3. Markup of CoC Appendices A and B pages to aid in the Review of Exemption Request

4. Cost Avoidance Analysis of Dry Fuel Storage Completion in 2018 vs. 2020

5. Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure

6. Cask Dose Rate Limits Report and Dose Versus Distance Report (Proprietary)

BVY 17-006 I Page 3 of 3 cc: Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. Jack D. Parrott, Sr. Project Manager Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Mail Stop T-8F5 Washington, DC 20555 Ms. Yen-Ju Chen, Sr. Project Manager Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Mail Stop T-48-34 Washington, DC 20555 Ms. June Tierney, Commissioner Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05602-2601 (w/o Attachment 6)

I

BVY 17-006 Docket Nos. 50-271, 72-59, and 72- 1014 Attachment 1 Vermont Yankee Nuclear Power Station Request for Specific Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214

BVY 17-006 I Attachment 1 I Page 1 of 25 REQUEST FOR SPECIFIC EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 72.212 and 10 CFR 72.214 FOR VERMONT YANKEE NUCLEAR POWER STATION I. Request for Exemption Pursuant to 10 CFR 72.7, "Specific Exemptions," Entergy Nuclear Operations, Inc. (ENO) requests an exemption from certain requirements of 10 CFR 72.212(a)(2) , 10 CFR 72.212(b)(3),

10 CFR 72.212(b)(5)(i) , 10 CFR 72.212(b)(11) , and 10 CFR 72.214 for Vermont Yankee Nuclear Power Station (VY). These regulations require, in part, that a licensee store its irradiated fuel in compliance with the terms and conditions of the spent fuel storage cask's Certificate of Compliance (CoC). Specifically, ENO is requesting an exemption from certain requirements in Amendment No. 1O of the Holtec International (Holtec) CoC No. 72-1014 for the HI-STORM 100 Cask System (Reference 1). If approved , the exemption will allow the loading of irradiated fuel with shorter cooling times and higher heat loads than currently specified in Amendment No. 10 of Holtec HI-STORM 100 Coe No. 72-1014.

II. Background VY is currently planning to utilize the HI-STORM 100 Cask System under CoC No. 72-1014, Amendment No. 1O for dry storage of spent nuclear fuel in specific Multi-purpose Canisters (MPC) (i.e. , MPC-68M canisters). The spent fuel to be stored in the MPC-68M must meet the requirements of CoC No. 72-1014 Appendix B, including Section 2.4, which provides a maximum allowable decay heat for each fuel storage location . Additionally , CoC No. 72.1014, Appendix B, Section 2.4.3 provides a method of calculating maximum allowable burnup based on assembly decay heat, minimum enrichment, average burnup, and a cooling time between three (3) and twenty (20) years. Based on Amendment No. 10 of CoC No. 72-1014, VY is limited to loading fuel with a cooling time greater than three (3) years . VY is preparing loading plans for transferring all irradiated fuel assemblies from the Spent Fuel Pool (SFP) into dry storage in support of decommissioning. The transfer of VY's irradiated fuel stored in its SFP is scheduled to begin in May, 2017 . A total of 45 MPC-68/68M canisters will be loaded to completely offload the SFP. This exemption request is proposed to be utilized on 19 of the 45 casks. The transfer of spent fuel to the Independent Spent Fuel Storage Installation (ISFSI) could be completed in 2018 if the optimized loading pattern described in this exemption request is utilized.

With the th ree-year cooling time limit as defined in Amendment No. 1O of the Holtec HI-STORM 100 CoC No. 72-1014, the population of canisters must be divided into two groups. The irradiated fuel assemblies that have been cooled for three-years or longer would be loaded in the first loading campaign. The load ing campaign would then be suspended for several months to meet the current three-year limitation. The first loading campaign will utilize the "older and colder assemblies, leaving the second set of canisters with elevated heat loads. This second set of canisters could be loaded to meet the limits in Amendment No. 1O of the Holtec CoC No. 72-101 4.

BVY 17-006 I Attachment 1 I Page 2 of 25 However, this is not an optimal approach. ENO proposes to utilize a loading campaign for VY that would allow for the loading of all spent fuel assemblies in an optimized manner. Thus, the requested exemption would permit specific changes proposed in proposed Amendment Nos. 11 and 12 of the HI-STORM 100 CoC No. 72-1014 to be utilized in the loading campaign. VY is requesting the exemption, because the NRG approval for Amendment Request Nos. 11 and 12 for Holtec HI-STORM 100 CoC No. 72-1014 is not likely to occur until the end of 2017. This schedule would not permit VY to utilize the "optimal canister loading plan" in its 2017 loading campaign.

If granted, this exemption would allow for storage of Boiling Water Reactor (BWR) fuel assemblies with higher heat loads and assemblies with cooling times as low as two (2) years in the MPC-68M. An optimized canister loading plan that utilizes the regionalization regimen set forth in the HI-STORM technical specification, submitted with Holtec HI-STORM 100 CoC 72-1014 Amendment Request No. 12 (Reference 3), specifies the storage location for each fuel assembly in its designated place in its designated canister. This would permit irradiated fuel assemblies with shorter cooling times to be loaded into designated locations interior to the peripheral locations of the basket, while the longer cooled fuel assemblies to be equally distributed among all casks and in the outer region of the basket.

VY would recognize significant operational benefits due to the capability to complete the transfer of irradiated fuel to the ISFSI within a shorter time period. The "optimized canister loading plan" would permit the SFP-related structures, systems, and components (SSC's) to be removed from service earlier, and allow for staffing reductions to a level commensurate with dry fuel storage only operations. This would significantly reduce VY's costs associated with the maintenance of SSC's associated with wet fuel storage and the impact of those costs on the Decommissioning Trust Fund .

Approval of the requested exemption will facilitate a continuous dry fuel storage loading campaign thereby avoiding an extended interruption of activities in the middle of the campaign.

The suspension of loading could have adverse effects such as the potential loss of trained and experienced personnel (technicians and craft labor) and the possible replacement with new, relatively inexperienced personnel. Such personnel replacements usually exact a toll in occupational dose and human performance errors. It would be beneficial to avoid these concerns by continuing the loading without interruption by using the "optimized canister loading plan" allowed by the granting of this exemption. Also, a delay in the loading campaign would extend the operation and maintenance of the SFP-related SSC's and the associated costs of those activities.

In summary, NRC approval of this exemption will lead to significant operational benefits including preservation of the decommissioning trust fund .

Ill. Exemption Request The technical analysis upon which this exemption request is based has been provided in Amendment Request Nos. 11 and 12 for the Holtec HI-STORM 100 CoC No. 72-1014 and supporting submittals. Holtec submitted Amendment Request No. 11 to the NRG for review on

BVY 17-006 I Attachment 1 I Page 3 of 25 January 29, 2016 and a revised version submitted June 6, 2016 (References 2 and 11) and the Amendment Request No. 12 was submitted to the NRC on June 14, 2016 (Reference 3).

ENO's exemption request for VY involves a portion of the changes that have been submitted as Amendment Request No. 11 (Change 9 below) and Amendment Request No. 12 (all other Changes defined below) for Holtec's HI-STORM 100 Coe No. 72-1014. The Holtec CoC Amendment Requests provide the supporting technical justification and related CoC and Final Safety Analysis Report (FSAR) changes. However, due to the anticipated review times associated with those Amendment Requests, VY is requesting this exemption to utilize the optimized canister loading plan during its 2017 fuel loading campaign for MPC-68Ms scheduled to be loaded as early as late October 2017 contingent upon approval of this exemption request.

VY would like to rely on the technical review performed or in progress by the NRC Staff of Amendment Request Nos. 11 and 12 for Holtec Hi-STORM 100 CoC No. 72-1014. In support of this exemption request for VY, ENO hereby incorporates by reference the documents listed in Section IX of this attachment. Additionally, Attachment 2 provides the Holtec HI-STORM 100 FSAR pages that support this exemption request. Attachment 3 provides a mark-up of the pertinent pages of the Coe Appendices A and B to aid in the review of this exemption request. provides an analysis of the avoided costs that could be realized by earlier completion of the transfer to dry fuel storage if the exemption is granted, as a supporting basis for this request. Attachment 5 to this letter is an affidavit prepared in accordance with 10 CFR 2.390 requesting that Attachment 6 be withheld from public disclosure. contains (1) a proprietary Cask Dose Rate Limits Report, which provides an analysis of the surface dose rates for the transfer cask and HI-STORM overpacks, and (2) a proprietary Dose Versus Distance Report, which provides an analysis of the off-site dose rate from the VY ISFSI. This exemption request involves three primary proposed changes from Amendment 1O:

The introduction of an optional regionalized loading pattern for the MPC-68M as described in proposed new Figure 2.4-1 (as referenced in the changes to CoC Appendix B Section 2.4.2). Figure 2.4-1 defines alternate regions for the MPC-68M (as compared to Figure 2.1-4) to allow VY to load fuel from the final operating cycle with cooler fuel, and provide for storage of damaged fuel or fuel debris in a damaged fuel container (DFC) in specified cell locations.

The allowance for fuel cooled ~ 2 years to be loaded into the MPC-68M as a change to Table 2.1-1, compared to minimum cooling time of~ 3 years as specified in CoC Appendix B Section 2.4.3 (and Table 2.4-4 for BWR fuel) for calculating burnup limit, based on the specified range of minimum cooling times. This change is to accommodate the loading of fuel from VY's final operating cycle. Based on the VY loading plan using the requested exemption, the earliest load dates for a select number (6 total) of MPC-68M canisters results in minimum cooling times ranging from 2.83 to 2.99 years. The minimum cooling time for the remaining canisters is ~ 3 years.

The establishment of a per cell maximum average burnup limit at ::; 65,000 megawatt days per metric ton of uranium (MWD/MTU) as a change to Table 2.1-1 , compared to a

BVY 17-006 I Attachment 1 I Page 4 of 25 calculated maximum allowable fuel assembly average burnup for minimum cooling times specified in Section 2.4.3. This is partly required due to Section 2.4.3 being not applicable when using the proposed new Figure 2.4-1 , and partly due to the equations and tables associated with Section 2.4.3 being specified for fuel cooled ~ 3 years.

This exemption request is primarily focused on the above three changes from Amendment 10, and results in additional consistency, or complementary, changes. Each of these changes to Appendix A and Appendix B of CoC Amendment 10 are described below.

ENO proposes to revise the language in Amendment No. 1O of Holtec HI-STORM 100 CoC No.

72-1014, Appendices A and Bas follows:

1. Modify CoC Appendix A, Technical Specification 3.1.2, "SFSC Heat Removal System,"

Surveillance Requirement (SR) 3.1 .2:

SURVEILLANCE FREQUENCY SR 3.1.2 Verify all OVERPACK inlets and outlets are 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months free of blockage from solid debris or floodwater.

OR For OVERPACKS with installed temperature 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months monitoring equipment, verify that the difference between the average OVERPACK air outlet temperature and ISFSI ambient temperature is$ 155°F for OVERPACKS containing PWR MPCs, $ 137°F for OVERPACKS containing BWR MPCs (except MPC-68M) and$ 164°F for OVERPACKS containing MPC-68M.

Basis for proposed Change 1:

This change reflects the proposed addition of a new optional regionalized loading pattern (implemented in Change 6 and presented in Change 8) with higher total heat load capacities. With the higher total heat load allowances, there is a corresponding change in the OVERPACK surveillance requirements regarding the difference between the average OVERPACK air outlet temperature and ISFSI ambient temperature. This proposed change reflects the above restrictions I action criteria within surveillance requirement SR 3.1 .2.

The other option of implementing SR 3.1.2 by visual observation that all OVERPACK inlets and outlets are unobstructed remains unchanged.

BVY 17-006 I Attachment 1 I Page 5 of 25

2. Modify CoC Appendix A, Table 3-1, "MPC Cavity Drying Limits for all MPC Types ," by adding the following limitations for the MPC-68M canister and Note 7:

Table 3-1 MPC Cavity Drying Limits for all MPC Types Method of Moisture Fuel Burnup M PC Heat Load (kW) Removal (MWD/MTU)

(Notes 1 and 2)

s 30Note 5 (MPC-24/24E/24EF, MPC-32/32F, MPC-68/68F/68FF)

All Assemblies :s 45,000 :s 35_9Note 6 {MPC-68M) VOS or FHD

s 42.8Note 7 (MPC-68M)

> 30Note 6 (MPC-24/24E/24EF, All Assemblies :s 45,000 MPC-32/32F, MPC-68/68F/68FF)

FHD One or more assemblies

> 45,000

s 29 (MPC-68M) VDSNote 4 or FHD

S 35 _9Note 5 (MPC-One or more assemblies 24/24E/24EF/MPC-32/32F/MPC-FHD

> 45,000 68/68F/68FF/MPC-68M

s 42.sNote 7 (MPC-68M)

Note 7: Maximum per assembly allowable heat loads defined in Appendix B, Figure 2.4-1.

Basis for proposed Change 2:

This is a consistency change associated with the proposed addition of a new optional regionalized loading pattern in Appendix B, Figure 2.4-1. When using this revised loading pattern, the maximum MPC Heat Load is equal to 42.8 kilowatts (kW). The addition of this change specifies that forced helium dehydration (FHD) is the required method of moisture removal when loading fuel to Figure 2.4-1 (and one or more assemblies> 45,000 MWD/MTU). When VY is loading fuel per Figure 2.4-1 , each MPC-68M is planned to contain at least one assembly with burnup > 45,000 M.WD/MTU .

Accordingly, VY will be using FHD for all casks in the upcoming campaign . There are no proposed changes to Notes 1 through 6 of Table 3-1.

BVY 17-006 I Attachment 1 I Page 6 of 25

3. Modify Appendix A, Table 3-2, "MPC Helium Backfill Limits ," by revising the backfill limits when loading an MPC-68M in accordance with Figure 2.4-1; and a clarifying change to Table 3-3:

Table 3-2 MPG Helium Backfill Limits 1 MPC MODEL LIMIT MPC-68/68F/68FF/68M

i. Cask Heat Load :5 28.19 kW - 0.1218 +/-10% g-moles/I uniformly distributed per Table 3-4 OR or regionalized loading per Table 3-3 ;::: 29.3 psig and :5 48.5 psig ii. Cask Heat Load > 28.19 kW -

uniformly distributed

45.5 psig and

5 48.5 psig or greater than regionalized load limits per Table 3-3 iii. Cask Heat Load :5 42.8 kW (MPC-68M) -

Regionalized Loading Pattern shown in ;::: 43.5 psig and :5 46.5 psig Appendix B, Figure 2.4-1 Table 3-3: Regionalized StorageNote 2 Cell Heat Load Limits MPC Type Number of Storage Cell Number of Storage Cell Cells in Inner Heat Load Cells in Outer Heat Load RegionNote 1 (Inner Region) RegionNote 1 (Outer Region)

(kW) (kW)

MPC- 32 0.500 36 0.275 68/68F/68FF/68M Basis for proposed Change 3:

Change 3 provides MPC helium backfill limits for MPC-68M when applying the optional regionalized loading pattern shown in proposed Appendix B, Figure 2.4-1 (see proposed Changes 6 and 8). The proposed change to Table 3-3 is to clarify that the heat load limits for MPC-68/68F/68FF as provided are also applicable to MPC-68M, consistent with the CoC analysis previously pert ormed and provided in the FSAR. It is noted that the inner and outer regionalized loading shown in Table 3-3 is not applicable when loading fuel in accordance with proposed Figure 2.4-1 .

BVY 17-006 I Attachment 1 I Page 7 of 25

4. Revise Appendix B, Section 2.1 .3, "Regionalized Fuel Loading" as follows:

"Users may choose to store fuel using regionalized loading in lieu of uniform loading to allow higher heat emitting fuel assemblies to be stored than would otherwise be able to be stored using uniform loading. Regionalized loading is limited to INTACT FUEL ASSEMBLIES or UNDAMAGED FUEL ASSEMBLIES with ZR cladding.

Figures 2.1-1 through 2.1-4 define the regions for the MPC-24, MPC-24E, MPC-24EF, MPC-32, MPC-32F, MPC-68, MPC-68FF, and MPC-68M models, respectively. Fuel assembly burnup, decay heat, and cooling time limits for regionalized loading are specified in Section 2.4.2. Fuel assemblies used in regionalized loading shall meet all other applicable limits specified in Table 2.1-1 through 2.1-3."

Basis for proposed Change 4:

This is a consistency change associated with the proposed addition of an optional regionalized loading pattern (Appendix B, Figure 2.4-1). The optional regionalized loading pattern added as Figure 2.4-1 allows for the storage of damaged fuel or fuel debris in a Damaged Fuel Container (DFC) in specified locations in the MPC-68M. The ability to store damaged fuel I fuel debris in a DFC in a regionalized loading pattern would allow VY to optimize the loading of canisters using dose reduction strategies.

Proposed Change 4 is necessary to reflect this revised allowance provided by the adoption of Figure 2.4-1 and the changes to Table 2.1-1 specifying the fuel assembly burnup and cooling time limits for MPC-68M. It is noted that Section 2.4.2 (Change 6) references proposed Figure 2.4-1 (Change 8) as an optional regionalized loading pattern for MPC-68M (compared to Figure 2.1-4) .

5. Revise Appendix B, Table 2.1-1 , "Fuel Assembly Limits," items VI , "MPC-68M ,"

(A)(1)(d)(ii) and (A)(2)(d)(ii): 1 ii. All Other Array/Classes As specified in Section 2 .4. Cooling time::::: 2 years, an average burnup::; 65,000 MWD/MTU, and decay heat as specified in Section 2.4.2.

Basis for proposed Change 5:

The first part of this change introduces the first major change associated with this exemption request; that being the requirement for fuel to be stored in an MPC-68M must be cooled ::::: 2 years versus the previous limitation of ::::: 3 years. The second part of this change identifies the second major change associated with this exemption request, that all fuel assemblies to be loaded in an MPC-68M must have an average burnup of

5 65,000 MWD/MTU. The final part of Change 5 reiterates that individual assembly decay heat values must satisfy the limitations identified in Section 2.4.2.

1 Proposed Holtec HI-STORM 100 CoC No. 72-1014 Amendment Bequest No. 11 revises this table from "As Specified in Section 2.4" to "Cooling time;;:: 3 years and an average burnup:,; 65,000 MWD/MTU".

Amendment Request No. 12 proposes to revise this table from " ;;:: 3 years ... " to";;:: 2 years ... ".

BVY 17-006 I Attachment 1 I Page 8 of 25

6. Modify Appendix B, Section 2.4.2, as identified:

2.4.2 Regionalized Fuel Loading Decay Heat Limits for ZR-Clad Fuel (Intact or Undamaged Fuel only)

The maximum allowable decay heat per fuel storage location for intact fuel assemblies in regionalized loading is determined using the following equations:

Q(X) = 2 x 0 0 I (1 + XY) y = 0.23 I x 0 *1 q2 = Q(X) I (n1 x X +n 2) q1 =q2 xx Where:

0 0 = Maximum uniform storage MPC decay heat (34 kW)

X = Inner region to outer region assembly decay heat ratio (0.5::;; x::;; 3) n 1 = 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.

An optional regionalized loading pattern for MPC-68M is shown in Figure 2.4-1.

The actual heat load value for each assembly is calculated utilizing SCALE 4.3, based on the assembly burnup, enrichment, and cooling time, the operating parameters in Section 5.2 of the FSAR, and the fuel parameters from Table 2.1-1. For calculating the heat load, it is acceptable use a higher burnup ,

and/or a lower enrichment, and/or a shorter cooling time than the actual values. This calculated heat load is compared to the maximum allowable decay heat for the assembly storage location that was determined by using one of the two options above (utilizing Table 2.4-2 or Figure 2.4-1).

Basis for proposed Change 6:

The first part of this change proposes to delete the restriction that only "Intact or Undamaged Fuel" be loaded in a regionalized manner. This is a complimentary change since the proposed optional regionalized loading pattern (to be introduced as Appendix B, Figure 2.4-1), allows for the loading of damaged fuel in a regionalized manner.

The second part of this change identifies that when loading fuel in accordance with the existing two region method (i.e., Table 2.4-2), the requirement that all fuel assemblies be intact continues to apply. This exemption request does not alter this requirement.

The third part of this change introduces an optional regionalized loading pattern for the MPC-68M as shown in Appendix B, Figure 2.4-1. When loading fuel to Figure 2.4-1 , the maximum allowable heat load per cell does not need to be calculated as is done for the two region method (using Table 2.4-2). Rather, the maximum allowable heat load per cell is identified directly from Figure2.4-1. This proposed change allows for storage of a

BVY 17-006 I Attachment 1 I Page 9 of 25 select number of fuel assemblies with higher per assembly heat loads in the MPC-68M.

These higher heat loads allow for VY fuel that has been cooled greater than 2 years to be stored in the MPC-68M. The proposed optional regionalized loading pattern has been thermally evaluated and found to maintain component temperatures below the required limits.

Figure 2.4-1 allows for the storage of damaged fuel or fuel debris in a DFC in specified locations as shown on the figure. Allowing for the storage of damaged fuel I fuel debris in DFCs in a regionalized pattern will allow VY to load the MPC-68M canisters with better dose reduction strategies. The impact of DFCs in the revised regionalized loading pattern has been evaluated, and a heat load reduction factor has been incorporated.

Specifically, the loading of damaged fuel I fuel debris is restricted to 16 periphery locations of the MPC-68M, and the maximum allowable decay heat per cell location is reduced from 0.5kW to 0.35kW. Of the 45 casks scheduled to be loaded to transfer all of VY's remaining fuel into dry fuel storage, 16 of the last 18 casks are planned to be loaded in accordance with Figure 2.4-1.

The fourth part of Change 6 directs that actual assembly heat load be calculated by utilizing SCALE 4.3, based on the assembly burnup, enrichment, and cooling time, the operating parameters in Section 5.2 of the FSAR, and the fuel parameters from Table 2.1-1. This calculated assembly heat load is compared to the maximum allowable decay heat for the assembly storage location that was determined by 'Using one of the two options above, that is by calculation , if using the existing two region loading (Table 2.4-2) , or taken directly from the proposed regionalized loading pattern shown in Figure 2.4-1. It is noted that the method described above has been utilized by VY to calculate the actual assembly heat load for all casks to be loaded during the upcoming campaigns.

BVY 17-006 I Attachment 1 I Page 10 of 25

7. Add Note 1 to Appendix B, Table 2.4-2, "Fuel Storage Regions per MPC," for the MPC-68/68FF/68M entry:

Table 2.4-2 Fuel Storage Regions per MPC MPC Model Number of Storage Locations Number of Storage in Inner Region (Region 1) Locations in Outer Region (Region 2)

MPC-24 and MPC-24E/EF 12 12 MPC- 32/32F 12 20 1

MPC-68/68FF/68MNote 32 36 Note 1 : For an optional regionalized loading pattern for MPC-68M, see Figure 2.4-1 .

Basis for proposed Change 7:

This is a consistency change associated with Change 6 above, which reflects the proposed addition of an optional regionalized loading pattern, Figure 2.4-1 of Appendix B. While the new loading pattern utilizes a regionalized approach, it uses regions which differ from those in Table 2.4-2. Table 2.4-2 is not utilized when loading fuel in accordance with Figure 2.4-1. Table 2.4-2 is applicable when loading fuel per Section 2.4.2.

8. Add Figure 2.4 "Per Cell Allowable Heat Loads (kW) - MPC-68M" to Appendix B (provided at the end of this Attachment).

Basis for proposed Change 8:

Change 8 adds Figure 2.4-1 to Appendix B; its use is provided as an optional regionalized loading pattern in Section 2.4.2 per Change 6 above. This proposed change allows for the storage of fuel assemblies with higher per assembly heat loads in an MPC-68M. Figure 2.4-1 allows for the loading of 16 assemblies (per cask) with a decay heat of :5 1200 watts. This is compared to the maximum regionalized heat load limits for two region {Table 2.4-2) loading of an MPC-68/68M, using the calculational method in Section 2.4.2, of 710 watts (for X-ratio = 0.5, Outer Region) and 685 watts (for X-ratio = 3.0, Inner Region) (Reference 1, FSAR, Table 2.1.30 - which provides a list of X values for all MPC types). The VY site specific loading plan has approximately 132 assemblies with heat loads > 71 O watts, with the hottest being 912 watts. For this site specific exemption request, there is a degree of margin of 24% between the highest cell allowable heat load limit in Figure 2.4-1 and the hottest VY assembly.

The proposed optional regionalized loading pattern has been found to be bounded by the limits for thermal, structural and shielding previously reviewed by Amendment 10.

There are no changes to the criticality or confinement characteristics.

BVY 17-006 I Attachment 1 I Page 11 of 25

9. Applicability of Appendix B, Section 2.4.3, "Burnup Limits as a Function of Cooling Time for ZR-Clad Fuel":

Basis for proposed Change 9:

Change 9 is a consistency change or clarifying change as a result of changes proposed to Appendix B, Table 2.1-1 (Change 5 above) which identifies, among other requirements, that the maximum average burnup is limited to :s; 65,000 MWD/MTU.

Once this exemption request is approved , VY plans to use the :5 65,000 MWD/MTU burnup limit as specified in Table 2.1-1 in lieu of calculating individual burnup limits as specified in Section 2.4.3. This change is necessary since some of the site specific fuel VY plans to store in MPC-68Ms will be cooled ~ 2 years, and the method to calculate individual cell burnup limits per Section 2.4.3 applies to fuel cooled ~ 3 years. Since the maximum average burnup for any fuel assembly to be stored per this exemption request is :5 52,000 MWD/MTU , the difference between the :5 65,000 MWD/MTU burnup limit and the actual site specific value of :5 52,000 MWD/MTU is at least 20%. This margin is substantially greater than a 5% conservatism built into the equations of Section 2.4.3 and accompanying tables (see discussion under Shielding Justification in Section V.C .

below).

IV. Implementation of Proposed Changes The effort to offload all of the fuel from the spent fuel pool and place in dry fuel storage will utilize 45 casks. Of these casks , 19 of the last 21 casks are proposed to be loaded in accordance with this exemption request. All of the subject casks will be MPC-68M's and all of the drying will be via FHD, accordingly, there are no changes proposed which apply to MPC-68's or the vacuum drying process. Of the 19 casks proposed to utilize this exemption request, the first three (3) casks will be loaded via the existing two reg ion method identified in Section 2.4.2 of Appendix B. The plan for these three casks involve all fuel satisfying the burnup limit of :5 65,000 MWD/MTU , with some fuel which has been cooled~ 2 years with the majority having been cooled much greater than 3 years. The remaining 16 casks are scheduled to be loaded in accordance with Figure 2.4-1, and again with some fuel cooled ~ 2 years and all fuel satisfying the burnup limit of :s; 65,000 MWD/MTU.

BVY 17-006 I Attachment 1 I Page 12 of 25 V. Technical Justification The technical analysis upon which this exemption request is based has been provided in Amendment Request Nos. 11and12 for the Holtec HI-STORM 100 Coe No. 72-1014 and supporting submittals. Holtec submitted Amendment Request No. 11 to the NRC for review on January 29, 2016 and a revised version submitted June 6, 2016 (References 2 and 11) and Amendment Request No. 12 was submitted to the NRC on June 14, 2016 (Reference 3). While this exemption request is primarily focused on three (3) changes from the current Amendment 1O, it results in the nine (9) changes described in the previous section ; with the majority of those changes being consistency or complementary changes. The primary changes being requested by this exemption request are as follows:

The introduction of an optional regionalized loading pattern for the MPC-68M as described in proposed new Figure 2.4-1 (as referenced in the changes to CoC Appendix B Section 2.4.2). Figure 2.4-1 defines alternate regions for the MPC-68M (as compared to Figure 2.1-4) to allow VY to load fuel from the final operating cycle with cooler fuel, and provide for storage of damaged fuel or fuel debris in a damaged fuel container (DFC) in specified cell locations.

The allowance for fuel cooled;:::; 2 years to be loaded into the MPC-68M as a change to Table 2.1-1 , compared to minimum cooling time of;:::; 3 years as specified in CoC Appendix B Section 2.4.3 (and Table 2.4-4 for BWR fuel) for calculating burnup limit, based on the specified range of minimum cooling times. This change is to accommodate the loading of fuel from VY's final operating cycle . Based on the VY loading plan using the requested exemption, the earliest load dates for a select number (6 total) of MPC-68M canisters results in minimum cooling times ranging from 2.83 to 2.99 years. The minimum cooling time for the remaining canisters is;:::; 3 years.

The establishment of a per cell maximum average burnup limit at ::;; 65,000 megawatt days per metric ton of uranium (MWD/MTU) as a change to Table 2.1-1, compared to a calculated maximum allowable fuel assembly average burnup for minimum cooling times specified in Section 2.4~3. This is partly required due to Section 2.4.3 being not applicable when using the proposed new Figure 2.4-1, and partly due to the equations and tables associated with Section 2.4.3 being specified for fuel cooled;:::; 3 years.

The following provides the thermal, structural, and shielding technical justifications related to the storage of irradiated fuel in MPC-68M casks per this exemption request. There are no changes to the criticality or cont inement characteristics.

There are no additional site specific issues associated with the adoption of these changes.

However, a qualitative assessment of the expected reduction in cumulative occupational and public doses is provided.

BVY 17-006 I Attachment 1 I Page 13 of 25 A. Thermal Justification The thermal evaluation that supports the storage of shorter cooled fuel, in the proposed optional regionalized pattern 2 (termed "QSHL" for Quarter Symmetric Heat Load) , was submitted with Holtec's HI-STORM 100 Coe No. 72-1014 Amendment Request No. 12. As stated in the proposed FSAR pages submitted with that amendment request (Reference 4, page 32 of 66):

"The QSHL pattern has also been analyzed using the same FLUENT model previously used in this FSAR: no changes were made to the existing thermal model. The selected heat loads in Figure 2.111.1 are suitably limited to ensure that the peak cladding temperature in the MPC remains below that in the governing MPC analyzed in this FSAR (MPC-32) under all thermal scenarios. Thus the peak cladding temperature for the QSHL pattern is limited by a previously analyzed and licensed MPC.

"Other important safety aspects of the QSHL pattern are:

1. The hottest fuel assemblies are located in-board of the peripheral locations in the basket so that the colder fuel in the peripheral cells help block the radiation emitted by the hottest fuel assemblies.

2. The cell specific heat load, q, provided in Figure 2.111.1 is the maximum value permitted for that location. In virtually every case, the actual heat load in every cell will be lower than the allowed limit, thus resulting in a lower cladding temperature field overall than that computed herein.

3. The fuel cladding temperature for QSHL pattern under long term storage in HI-STORM is presented in Table 4.lll.3a. The predicted PCT is higher than that for the scenario with decay heat based on regionalized parameter X defined in Chapter 2. For this reason , QSHL pattern is adopted as the licensing basis pattern for MPC-68M .

4. The PCT and basket temperatures under the QSHL pattern is lower than that in the thermally governing case (MPC-32)."

The supporting figures and tables demonstrating that the MPC-68M with the QSHL pattern meets the temperature and pressure limits are included in Attachment 2 to this exemption request.

Additionally, the QSHL pattern was evaluated under off-normal and accident conditions, and the maximum temperatures and pressures have been reported in the FSAR pages submitted with Holtec's CoC No. 72-1014 Amendment Request No. 12 (Reference 4). The tables reporting these off-normal and accident condition temperatures and pressures are also included in to this exemption request.

The QSHL pattern allows for the loading of 16 assemblies (per cask) with a decay heat load of

1200 watts. The VY site specific loading plan has approximately 132 assemblies with heat loads >710 watts, with the hottest being 912 watts. For this site specific exemption request, 2

The optional regionalized loading pattern is identified as Figure 2.4-1 in Appendix B of the CoC, and as Figure 2.111. 1 in the HI-STORM 100 FSAR. Additionally, the optional regionalized loading pattern is also referred to as a Quarter Symmetric Heat Load pattern in the FSAR thermal analysis discussion.

BVY 17-006 I Attachment 1 I Page 14 of 25 there is a conservatism of 24% between the highest cell allowable heat load limit in Figure 2.4-1 and the hottest VY assembly.

The PCT and basket thermal results from the new heat load pattern in the MPC-68M lead to the conclusion that it remains bounded by the existing governing case in the MPC-32. In addition, all additional thermal results remain bounded by the design temperature limits of Table 2.2.3 of the FSAR. This conclusion is documented by the calculation package submitted in support of the HI-STORM 100 Coe No. 72-1014 Amendment Request No. 12 (Attachment 1 to Reference 5).

B. Structural Justification Based on the temperatures calculated in the thermal analyses, all temperatures remain below the bounding temperatures used as input to the design basis structural calculations, except for the Metamic-HT fuel basket. The structural analyses for the elastic stability and yielding of the MPC-68M fuel basket were re-visited to ensure safety factors were maintained. These analyses are described in Section 3.111.4.4.3.2 of the FSAR pages submitted with HI-STORM 100 CoC No.

72-1014 Amendment Request No. 12 (Reference 4, page 16 of 66). The safety factor was concluded to be well above 1, in Table 3.111.4, which is included in Attachment 2 of this exemption request. The structural calculation package in support of Holtec's HI-STORM 100 CoC No. 72-1014 Amendment Request No. 12 Amendment Request may be found as Attachment 2 to Reference 5.

C. Shielding Justification The optional regionalized loading pattern 3 was also evaluated from a shielding perspective to I

I ensure that the HI-STORM 100 System design provides reasonable assurance that the systems I

stored on a site will meet the site boundary dose rate limits. Compliance with the limits of 10 CFR 72.104 has been demonstrated in the site boundary dose calculations for VY, which incorporates the actual site configuration and loaded fuel. However, the generic application for Holtec HI-STORM 100 CoC No. 72-1014 Amendment Request No. 12 provides calculations which demonstrate that the heat load pattern for 2-year cooled fuel in the MPC-68M is bounded by the existing patterns. A summary of the results of the shielding analysis is described in the proposed revised FSAR pages submitted as part of Holtec's HI-STORM 100 CoC No. 72-1014 Amendment Request No. 12 Responses to Request for Supplemental Information (page 11 of 16, Attachment 3 to Reference 10):

"As discussed in Subsection 2.0.1, each MPG basket, except MPC-68F, allows for two loading strategies, namely the uniform fuel loading and the regionalized loading with two regions. An additional 3-region loading pattern, shown in Figure 2.111.1, is evaluated to determine acceptability as approved contents in the MPC-68M only. This evaluation performs a dose rate comparison between a uniform loading pattern (results shown in Table 5.4.9) and a 3-region pattern (Table 5.111.1) in which one region contains 2-year cooled spent nuclear fuel.

3 The optional regionalized loading pattern is identified as Figure 2.4-1 in Appendix B of the CoC, and as Figure 2.111.1 in the HI-STORM 100 FSAR. Additionally, the optional regionalized loading pattern is also referred to as a 3-region loading pattern in the FSAR shielding analysis discussion.

BVY 17-006 I Attachment 1 I Page 15 of 25 "It should be noted that the design basis GE 7x7 source term calculations, discussed in Section 5.2 of the main part of this chapter, are performed using the SCALE 4.3 system (5.1.2, 5.1.3]. The evaluation in this Supplement 5.111 is performed with an updated version of SCALE (SCALE 5.1) which is consistent with other approved Holtec applications [5.111.3]. (SCALE 4.3 is no longer maintained by Oak Ridge National Laboratory, and does not work on contemporary computer operating systems.) To ensure that the dose rate comparison is not affected by the SCALE code version, a comparison between results generated using SCALE 4.3 and SCALE 5.1 was performed. There were no significant differences in the neutron and fuel gamma source terms between the two SCALE versions. The Cobalt-60 photon source calculated with SCALE 5.1 were substantially higher than the Cobalt-60 source calculated using SCALE 4.3 which is encompassed in the first two dose rate results columns of Table 5.111.2. The remaining comparisons shown in Table 5.111.2 are performed using the updated version of SCALE (SCALE 5.1 ), which compared the uniform loading pattern (50,000 MWD/MTU, 3-year cooling time) against the 3-region loading pattern presented in Table 5.111.1 for both the MPC-68 1 and MPC-68M.

"Table 5.111.2 shows the dose rates for the 3-region loading pattern (Figure 2.111.1 and Table 5.111.1) are bounded by the uniform loading pattern (50,000 MWD/MTU and 3-year cooling). For this reason, the 3-region loading pattern shown in Figure 2.111.1 is added as approved contents of the MPC-68M. The minimum cooling time criteria for the MPC-68M is updated to 2.0 years (see Table 2.0.1 ). The minimum cooling time criteria for the MPC-68 remains at 3.0 years (see Table 2.0.1)."

1 "The 3-region loading pattern shown in Figure 2 Ill.I and Table 5.111.1 is approved for the MPC-68M only. All results related to the 3-region loading pattern (in Figure 2.111.1 and Table 5.111.1 ) in the MPC-68 are for the purposes of comparison only."

The shielding conclusions , supported by the dose rate calculations performed for the proposed optional regionalized loading pattern (3-region loading pattern) are captured in the above proposed change to Chapter 5 of the FSAR. These calculations were performed to support Holtec's Response to Request for Supplemental Information , question 5-1(Reference10). The results of the calculations confirm that the dose rates when using the proposed optional regionalized loading pattern are bounded by the uniform loading pattern shown in Table 5.111.2 of the Holtec HI-STORM 100 FSAR .

The establishment of set burnup limits in Appendix B, Table 2.1-1 (Change 5) and the corresponding removal of the burnup equation as identified in Change 9 have also been reviewed for potential impacts to the shielding analysis of the system. The equation and associated coefficients in Section 2.4.3 were initially introduced for BWR fuel in Amendment No. 2 to CoC No. 72-1014. For Amendment No. 2, the NRC SER (Reference 6) recognized and accepted that the coefficients were determined such that 5% is added to the calculated heat loads for BWR fuel to account for uncertainties in the heat load calculations performed utilizing SCALE Version 4.3. Hence, the coefficients in Amendment No. 1O include a 5% addition for BWR fuel. It is understood that removing the coefficients completely from the CoC would also

BVY 17-006 I Attachment 1 I Page 16 of 25 remove this additional margin from the heat load determination of the fuel assemblies. In order to retain the margin, Section 2.4.3 will be replaced with the procedural steps identified in the proposed revised text to Section 2.4.2 (Change 6) for determination of assembly heat loads.

Those steps are a simpler and more direct approach than using the formulas and coefficients, and will achieve the same goal. Since Holtec has already calculated heat loads for a large range of burnup, enrichment, and cooling times, to determine the coefficients, the determination would simply involve a table lookup, and it is only necessary to perform new calculations in cases where values are outside of the previously calculated ranges (e.g., more than 20 years cooling time). Any new calculations would utilize the same methodology and incorporate the same conservatism as the existing calculations based on the procedural steps added.

Overall this approach assures that the uncertainty margin in the determination of the assembly heat loads is maintained. It further assures that the burnup, enrichment, and cooling times of loaded assemblies are limited to be consistent with the heat load limits. Since the maximum average burn up for any VY fuel assembly to be loaded per this exemption request is

~ 52,000 MWD/MTU, the difference between the ~ 65,000 MWD/MTU burnup limit and the actual site specific value of~ 52,000 MWD/MTU is at least 20%. This margin is substantially greater than a 5% conservatism built into the equations of Section 2.4.3 and accompanying tables.

Since this exemption request is site specific to VY, it is noted that calculations have been performed which demonstrate compliance with the NRC's and State of Vermont's regulations for dose limits to the public, and this exemption request does not seek to modify any of those dose limits. A VY fuel loading plan has been developed which would implement this exemption request. Based upon this fuel loading plan, VY has demonstrated compliance with the regulatory limits. In support of the shielding justification, Attachment 6 to this letter provides two reports: 1) "HI-STORM CoC Radiation Protection Program Dose Rate Limits" and 2) "Dose Versus Distance from HI-STORM 1OOS Containing MPC-68 and MPC-68M for Vermont Yankee."

D. Cumulative Occupational and Public Dose Consideration Currently, Holtec HI-STORM 100 CoC Amendment No. 10 restricts the loading of BWR assemblies into MPC-68M to assemblies with the minimum cooling time of three years as described in Section 2.4.3 and Table 2.4-4 of the CoC. Further, the heat load of the BWR assemblies is restricted according to regionalized loading defined in Section 2.4.2 of the CoC.

Under these restrictions in the HI-STORM 100 CoC Amendment No. 10, a large number of fuel assemblies with shorter cooling time must be deferred to casks loaded later in the loading campaigns , i.e., beyond three years from the final shutdown. The loading plans thus contain a number of casks loaded with relatively long cooled assemblies in early loading campaigns and a number of casks loaded with relatively short cooled assemblies in the later campaigns. This is not an optimal approach.

ENO would prefer to load the VY assemblies with shorter cooling times concurrent with the longer cooled assemblies in the same loading campaign. For the first three casks to be loaded using this exemption, the assemblies with shorter cooling times would be loaded into the inner

BVY 17-006 I Attachment 1 I Page 17 of 25 regions of the basket, while the longer cooled assemblies would be equally distributed among all casks and loaded in the outer region of the basket. This approach would result in some reduction of the cumulative occupational and public doses.

Previously, ENO demonstrated how loading hotter assemblies with cooler assemblies results in in reduced cumulative occupational and public doses in the ENO exemption request submitted on November 9, 2016, and a subsequent response to a request for supplemental information submitted on January 9, 2017 (References 7 and 8). The previous exemption request allows for a modification to certain requirements in Appendix B, Table 2.1-3, Note 19 of Amendment No. 10 to the Holtec HI-STORM 100 CoC No. 72-1014. It permits certain low enriched channeled fuel classified as "undamaged" per the CoC to be loaded in the same MPC as higher enriched fuel. Reference 8 provided a comparison of dose rates at a distance of 100 meters from the HI-STORM 100 for two casks loaded as required by Amendment No. 1Oto the HI-STORM 100 CoC No. 72-1014, and loaded as permitted by the exemption requested in Reference 7. The comparison showed that a net reduction of dose was observed from the two casks. These casks were considered representative of casks to be loaded across the entire campaign. Thus, a reduction in sum total dose across the campaign would be expected.

Reference 8 further states that this case was an illustration of a typical dose rate reduction, and that further optimization may be performed for the entire loading plan with the revised CoC.

Similar to the optimized loading pattern discussed in References 7 and 8, a significant effect of this requested exemption with respect to cask dose rates is the allowance to load assemblies with cooling times 2: 2 years, therefore this parameter is considered for the following qualitative discussion. Under the requirements of CoC Amendment 10, the assemblies with the shortest cooling times must be deferred to the end of the cask loading schedule to meet the minimum cooling time~ 3 years requirement. However, based on a representative loading plan utilizing the requested exemption, the short-cooled assemblies are allowed to be loaded earlier in the schedule. This results in minimal changes to the dose rates for these earlier casks since the short-cooled assemblies would be loaded into the inner regions of the casks and the inner region is shielded by the longer-cooled assemblies loaded in the peripheral locations. This frees locations for longer-cooled assemblies to be loaded on the periphery of casks scheduled later in the campaign , and reduces the dose rates for these casks (approximately the last ten casks to be loaded under the requested exemption) by approximately 50 percent. Thus, implementation of the requested exemption would result in an overall reduction in the cask dose rates, estimated to be on the order of 200 mrem/year.

Further, as discussed in the Shielding Justification section, the site specific loading of fuel per this exemption request has been performed along with individual cask locations on the ISFSI pad. This evaluation demonstrates that the dose at 100 meters from the VY ISFSI remains below NRC as well as State of Vermont regulatory limits.

BVY 17-006 I Attachment 1 I Page 18 of 25 VI. Regulatory Considerations The provisions of 10 CFR 72.7 allow specific exemptions from the requirements of 10 CFR 72 provided the exemptions are authorized by law, will not endanger life or property or the common defense and security, and are otherwise in the public interest. As described above, the specific exemptions requested herein from 10 CFR 72.212(a)(2), 10 CFR 72.212(b)(3),

10 CFR 72.212(b)(5)(i) , 10 CFR 72.212(b)(11) and 10 CFR 72.214 to permit an alternative method of compliance with Section 2.4 in Appendix B of the HI-STORM 100 CoC satisfies the criteria and requirements of 10 CFR 72.7. The requested exemption continues to meet all regulatory limits for the HI-STORM 100 System, and provides no danger to life, property, or the common defense and security.

A. The exemption is authorized by law 10 CFR 72.7 allows the NRC to grant exemptions from the requirements of 10 CFR Part 72, therefore granting the proposed exemption is consistent with the Atomic Energy Act of 1954, as amended, and the Commission's regulations . Thus, the exemption would be authorized by law.

B. The exemption will not present an undue risk to public health and safety The requested exemption does not create a new accident precursor or result in an increase in the probability of any postulated accident. The requested exemption does not result in an increase in the consequences of postulated accidents. The requested exemption does not result in any change to the types or amounts of effluents that may be released offsite. Implementation of this exemption request would not result in an increase of cumulative occupational and public doses. Therefore , the requested exemption does not result in undue risk to public health and safety.

C. The exemption is consistent with the common defense and security The requested exemption does not alter the scope or implementation of the Vermont Yankee Physical Security Plan, and does not affect any other requirements related to the security of the facility. Therefore, the common defense and security is not impacted by the requested exemption.

D. Special Circumstances While 10 CFR 72.7 does not specify a requirement for "special circumstances" similar to those required for exemptions from 10 CFR Part 50, the exemption request can be supported by consideration of the special circumstances identified in 10 CFR 50.12(a)(2):

(ii) Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.

The underlying purpose of 10 CFR 72.212 is to allow licensees to utilize dry fuel storage casks that have previously been found to be sate and appropriately analyzed for use by

BVY 17-006 I Attachment 1 I Page 19 of 25 the CoC holder, the general licensee, and the NRC. As stated in the sections above, the change requested by this exemption has been analyzed with the submission of HI-STORM 100 Amendment Request Nos. 11 and 12 (References 2 and 3) to the NRC, and determined to meet the requirements of 10 CFR Part 72.

This proposed exemption allows for storage of fuel assemblies with higher per assembly heat loads in the MPC-68M. These higher heat loads allow for fuel that has been cooled over two years to be stored in the MPC-68M. The new loading pattern has been thermally evaluated and found to maintain component temperatures below the required limits. The requested exemption allows VY to remove fuel from its SFP in the optimized operational manner, without changing the ability of the system to continue to meet its safety functions, and therefore achieves the underlying purpose of the rule, which is the safe storage of spent nuclear fuel.

(iii) Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated.

Without the exemption, VY must meet the loading requirements of Amendment No. 1O of Holtec HI-STORM 100 CoC No. 1014. This would result in a delay of transferring some irradiated fuel from the SFP to the ISFSI. In this respect, this exemption request is consistent with a best practices approach for submission of decommissioning licensing actions, such as described in Reference 9.

For the additional time period that the irradiated fuel is stored in the SFP, VY would recognize significant operational benefits due to the capability to complete the transfer of irradiated fuel to the ISFSI within a shorter time period . This transfer would permit the SFP-related structures, systems, and components (SSC's) to be removed from service earlier, and allow for staffing reductions to a level commensurate with dry fuel storage only operations. Additionally, a second loading campaign would have to be conducted that would result in the additional expenditure of funds to resume the campaign. These costs are avoidable and an unnecessary expenditure of funds from the Decommissioning Trust Fund. ENO estimates that the cost savings associated with the staffing reductions and SFP maintenance costs would be on the order of 64 million dollars (See the cost avoidance analysis provided in Attachment 4).

As discussed above in Section V.D., ENO expects that lower doses to the site personnel during the loading campaign would be realized if the exemption request were granted.

ENO also expects lower overall dose at the site boundary during the time that the irradiated fuel is stored at the ISFSI. Thus, the exemption request would provide a benefit to site personnel and to the health and safety of the public without a reduction in safety margin .

Accordingly, compliance with the loading requirements of Amendment No. 1O to Holtec HI-STORM 100 CoC No. 72-1014 would result in an undue hardship due to the expenditures of significant costs that could be avoided by the granting and

BVY 17-006 I Attachment 1 I Page 20 of 25 implementation of this exemption request. In addition , if granted, the exemption request would result in additional risk reductions that are consistent with the NRC's previous findings in Reference 9.

VII. Environmental Considerations While the proposed exemption does not meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22{c)(25) , there are no significant environmental impacts associated with the proposed action . The proposed exemption does not:

Increase the probability or consequences of accidents (see no significant hazards consideration provided below)

Change the types of effluents released offsite;

Increase the occupational or public radiation exposure ;

Involve any construction or other ground disturbing activities;

Change the footprint of the existing ISFSI, SFP, or any other supporting structures;

Change the physical aspects of the dry or wet fuel storage features at the facility;

Have any impacts on aquatic or terrestrial habitats in the vicinity of Vermont Yankee;

Have any impacts on threatened, endangered, or protected species; and

Have the potential to cause effects on historic or cultural properties, assum ing such properties are present at the Vermont Yankee site .

In addition , as discussed below, the proposed exemption meets the first five criteria of 10 CFR 51.22(c)(25) , because it involves: (i) no significant hazards consideration; (ii) no significant change in the types or significant increase in the amounts of any effluents that may be released offsite; (iii) no significant increase in individual or cumulative public or occupational radiation exposure; (iv) no significant construction impact; and (v) no significant increase in the potential for or consequences from radiological accidents. However, the exemption does not satisfy the requirement of 10 CFR 51.22(c)(25)(vi) , because it involves requirements that are not: (A)

Recordkeeping requirements; (B) Reporting requirements ; (C) Inspection or surveillance requirements ; (D) Equipment servicing or maintenance scheduling requirements; (E) Education, training , experience, qualification , requalification or other employment suitability requirements ;

(F) Safeguard plans, and materials control and accounting inventory scheduling requirements; (G) Scheduling requirements; (H) Surety, insurance or indemnity requirements ; or (I) Other requirements of an administrative, managerial , or organizational nature.

(i) No Significant Hazards Consideration Determination Entergy Nuclear Operations, Inc. (ENO) has evaluated the proposed exemption to determine whether or not a significant hazards consideration is involved by focus ing on the three standards set forth in 10 CFR 50.92(c) as discussed below:

1. Does the proposed exemption involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No

BVY 17-006 I Attachment 1 I Page 21 of 25 The proposed exemption has no effect on structures , systems, and components (SSCs) and no effect on the capability of any facility SSC to perform its design function. The proposed exemption would not increase the likelihood of the malfunction of any facility SSC. The form, fit and function of facility SSC's are not affected, as their operation remains unchanged by this exemption request.

The probability of occurrence of previously evaluated accidents is not increased, since the probability and consequences of the accidents previously evaluated in the Holtec HI-STORM 100 Cask System FSAR and the VY DSAR are unaffected by the proposed exemption. The method of handling fuel and the number of fuel assemblies to be handled remain the same as if this exemption request were not granted. The method of handling casks once loaded with fuel remains unaffected by this request.

Therefore, the proposed exemption does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed exemption create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed exemption does not involve a physical alteration of the facility (only a change to the cask loading pattern). No new or different type of equipment will be installed and there are no physical modifications to existing SSCs associated with the proposed exemption. Similarly, the proposed exemption will not physically change any SSCs involved in the mitigation of any accidents. Thus, no new initiators or precursors of a new or different kind of accident are created. Furthermore, the proposed exemption does not create the possibility of a new accident as a result of new failure modes associated with any equipment or personnel failures. No changes are being made to setpoints which initiate protective or mitigative actions, and no new failure modes are being introduced. This proposed exemption allows for storage of fuel assemblies with higher per assembly heat loads in the MPC-68M. These higher heat loads allow for fuel that has been cooled over two years to be stored in the MPC-68M . The new loading patterns have been thermally evaluated and it has been determined that the component temperatures remain bounded by pre-established limits. In addition, the site specific loading patterns per this exemption request have been found to have an actual cask heat load which is lower than cask heat loads previously authorized by Amendment 10.

The requested exemption allows Vermont Yankee to remove fuel from its SFP in the optimized operational manner, without changing the ability of the system to continue to meet its safety functions.

Therefore, the proposed exemption does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed exemption involve a significant reduction in a margin of safety?

Response: No

BVY 17-006 I Attachment 1 I Page 22 of 25 The proposed exemption does not impact facility operation or any SSC that is relied upon for accident mitigation. This proposed exemption allows for storage of BWR fuel assemblies with higher heat loads and cooling times as low as 2 years in the MPC-68M.

The new regionalized loading pattern has been thermally evaluated and found to maintain component temperatures below the required limits. The requested exemption allows VY to remove irradiated fuel from its SFP in an optimized operational manner, without changing the ability of the system to continue to meet its safety functions.

Therefore, the proposed exemption does not involve a significant reduction in a margin of safety.

Based on the above, ENO concludes that the proposed exemption presents no significant hazards consideration, and, accordingly, a finding of "no significant hazards consideration" is justified.

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

There are no changes in the types , characteristics, or quantities of effluents discharged to the environment associated with the proposed exemption. There are no materials or chemicals introduced into the facility that could aft ect the characteristics or types of effluents released offsite. In addition, the method of operation of waste processing systems will not be affected by the exemption. The proposed exemption will not result in changes to the design basis requirements of SSCs that function to limit or monitor the release of effluents. Therefore, the proposed exemption will result in no significant change to the types or significant increase in the amounts of any effluents that may be released offsite.

(iii) There is no significant increase in individual or cumulative public or occupational radiation exposure.

The proposed exemption does not involve any physical alterations to the facility configuration or any changes to the operation of the facility that could lead to a significant increase in individual or cumulative occupational radiation exposure. If granted and implemented, ENO expects that lower doses to the site personnel during the loading campaign would be realized. ENO also expects lower overall dose at the site boundary during the time that the irradiated fuel is stored at the ISFSI. Thus, the exemption request would provide a benefit to site personnel and to the health and safety of the public without a reduction in safety margin. The proposed exemption meets the NRC and State of Vermont regulatory limits, and does not alter these requirements.

(iv) There is no significant construction impact.

No construction activities are associated with the proposed exemption.

(v) There is no significant increase in the potential for or consequences from radiological accidents.

See the no significant hazards considerations discussion in Item (i)(1 ) above.

BVY 17-006 I Attachment 1 I Page 23 of 25 VIII. Summary In conclusion , pursuant to 10 CFR 72.7, ENO requests an exemption from the requirements of 10 CFR 72.212(a)(2) , 10 CFR 72.212{b)(3), 10 CFR 72.212{b)(5)(i) , 10 CFR 72.212{b)(11) , and 10 CFR 72.214. Specifically, an exemption is requested to permit an alternative method of compliance from that defined in Amendment No. 1o of Holtec HI-STORM 100 CoC No. 72 1014.

As described above, ENO considers this exemption to be technically justified and allowable under the 10 CFR Part 72 regulations.

IX. References

1. Letter, USN RC to Holtec International, "Certificate of Compliance No. 1014, Amendment No.

10 for the HI-STORM 100 Cask System (CAC No. L24979) ," dated May 25, 2016 (ML16144A177)

2. Letter, Holtec International to USN RC , "Holtec International HI-STORM 100 Multipurpose Canister Storage System Amendment Request 1014-11 ," dated January 29, 2016 (ML16029A529)

3. Letter, Holtec International to USNRC, "Holtec International HI-STORM 100 Multipurpose Canister Storage System Amendment Request 1014-12," dated June 14, 2016 (ML16169A363 - package)

4. Letter, Holtec International to USN RC , "HI-STORM 100 FSAR Proposed Changed pages" (Attachment 5 to Amendment 12 Request) , dated June 14, 2016 (ML16169A358)

5. Letter, Holtec International to USNRC, "Holtec International HI-STORM 100 Multipurpose Canister Storage System Amendment Request 1014-12 Supporting Calculation Packages",

dated July 22, 2016 (ML 1621OA130)

6. Letter, USN RC to Holtec International, "Amendment 2 to Certificate of Compliance No. 1014 for the Holtec International HI-STORM 100 Cask System" dated June 7, 2005 (ML051580459)

7. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Exemption Request from certain requirements of 10 CFR 72.212 and 10 CFR 72.214," dated November 9, 2016 (ML16319A102)

8. Letter, Entergy Nuclear Operations , Inc. to USNRC , "Response to Request for Supplemental Information Related to Exemption Request from certain requirements of 10 CFR 72.212 and 10 CFR 72.214," dated January 9, 2017 (ML1701 OA300)

9. USNRC Report, "Power Reactor Transition from Operations to Decommissioning Lessons Learned Report," October 2016 (ML16085A029)

BVY 17-006 I Attachment 1 I Page 24 of 25

10. Letter, Holtec International to USNRC, "HI-STORM 100 Amendment 12 Responses to Requests for Supplemental Information", dated November 4, 2016(ML16313A201)

11. Letter, Holtec International to USNRC, "Transmittal of RSI Responses Supporting HI-STORM 100 LAR 1014-11 ," dated June 6, 2016 (ML16159A344)

BVY 17-006 I Attachment 1 I Page 25 of 25 1 2 0.5* 0.5*

3 4 5 6 7 8 0.5* 0.5 1.2 1.2 0.5 0.5*

9 10 11 12 13 14 15 16 0.5* 0.5 1.2 0.4 0.4 1.2 0.5 0.5*

17 18 19 20 21 22 23 24 0.5 1.2 0.4 0.4 0.4 0.4 1.2 0.5 25 26 27 28 29 30 31 32 33 34 0.5* 1.2 0.4 0.4 0.4 0.4 0.4 0.4 1.2 0.5*

35 36 37 38 39 40 41 42 43 44 0.5* 1.2 0.4 0.4 0.4 0.4 0.4 0.4 1.2 0.5*

45 46 47 48 49 50 51 52 0.5 1.2 0.4 0.4 0.4 0.4 1.2 0.5 53 54 55 56 57 58 59 60 0.5* 0.5 1.2 0.4 0.4 1.2 0.5 0.5*

61 62 63 64 65 66 0.5* 0.5 1.2 1.2 0.5 0.5*

Cell ID 67 68 Heat Load 0.5* 0.5*

(kW)

When DAMAGED FUEL or FUEL DEBRIS is stored in this location (in a DFC) , the allowable heat load of the cell is limited to 0.35 kW Figure 2.4-1 Per Cell Allowable Heat Loads (kW) - MPC-68M

BVY 17-006 Docket Nos. 50-271 , 72-59, and 72-1014 Attachment 2 Vermont Yankee Nuclear Power Station Supporting FSAR Pages from HI-STORM 100 Amendment Request No. 12

BVY 17-006 I Attachment 2 I Page 1of11 ATTACHMENT 5 TO HOLTEC LETTER 5014811 Table l .III. l Key Parameters for MPC-68M BWR MPC internal environment (all pressure ranges are at a Helium fill reference temperature of (99.995% fill helium purity) 70°F)

(heat load_::; 28.19 kW) ~ 29.3 psig and _::; 48.5 psig OR 0.1218 +/-10% g-moles/liter (heat load >28.19 kW) 2: 45.5 psig and S 48.5 psig Quarter Symmetric Heat Load

~ 43 .5 psig and _::; 46.5 psig (QSHL)

B4 C content in Metamic-HT As specified on drawing in (wt.%) Section 1.5 HOL TEC INfERNA TI ON AL COPYRIGHfED MATERIAL HI-STORM 100 FSAR I I Proposed Rev. 1 4~

REPORT HI-2002444 I l.ID-11 I Page 11of67

BVY 17-006 I Attachment 2 I Page 2of11 ATTACHMENT 5 TO HOLTEC LETTER 5014811 Table 4.IIl.3a: Fuel Loading Patten Screening Evaluations Total Decay Loading Pattern Peak Cladding Temperature, °F Heat, kW X=0.5 (Note 1) 36.9 598 QSHL (Note 2) 42.8 708 Note 1: The decay heat disu*ibution is described in Section 2.1.9.

Note 2: Quarter symmetric heat load pattern is defined in Figure 2.IIl.1 Note 3: Since the highest PCT is reached for the QSHL pattern, it is adopted for all the licensing basis evaluations of fuel storage in MPC-68M.

Table 4.III.3b: Maximum Temperatures Under Normal Long-Term Storage Component Temperature (°F)

Fuel Cladding 708~

Basket 67~

Basket Shims 563~

MPC Shell 4994#

Overpack Inner Shell 358 1W9 Overpack Body Concrete 2 252~

2 Overpack Lid Concrete 257~

Overpack Outer Shell 190M9 Area Averaged Air Outlet3 ~244 1

Nominal exceedance of temperature limits has no risk on its structural integrity.

2 Maximum thru thickness section average temperature reported.

3 Reported herein for the *option of outlet ducts air temperature surveillance set forth in the Technical s;pec1"fi canons.

HOL TEC INTERNATIONAL COPYRIGHTED MATERIAL HI-STORM 100 FSAR I I Proposed Rev. l~

REPORT HI-2002444 I 4.lll-20 I Page46 of67

BVY 17-006 I Attachment 2 I Page 3of11 ATTACHMENT 5 TO HOLTEC LETTER 5014811 Table 4.III.6: Maximum Steady State HI-TRAC Temperatures and Pressures YaEief-During On-site Transfer Operations Component Temperature [°FJ Fuel Cladding 709~1 MPC Basket 676~

Basket Periphery 606~

MPC Gtlter-Shell Sm=faee 48844-i Aluminwn Shims 555~

HI-TRAC Inner Shell lfleer gy1:faee 286JJ..l.

WateF Jael~e~ IRRBF gYFfaeeHI-TRAC 27~

Outer Shell EnelesYFe ghell GmeF gYFfiieeWater 263~

Jacket Shell Water Jacket Bulk Water 257~

Top Lid Neutrnn Shield (Holtite )2 289~

Pressure (psig)

Initial Maximum Backfill 46&.5 Operating Pressure 100.5+.6

\\Zith 1% Fees FHf!ttm!l WU With 19% f'eas ffifltl:it'e 96:-9 The calculated value is below the pem1issible limit for highcburnup fud. Therefore auxiliary cooling of the HI-TRAC i5 not necessary to ensure cladding safety under onsite transfer oper3Lion5 involving the MPC-68M.

Accordingly SCS cooling is not mandated in the MPC-68M Technical Specifications 2 L oca1neutron s h.1eld section temperature.

HOLlEC INTERNATIONAL COPYRIGHTED MATERIAL fll-STORM 100 FSAR I I Proposed Rev. I~

REPORT fll-2002444 I 4.III-22 I Page48 of67

BVY 17-006 I Attachment 2 I Page 4of11 ATTACHMENT 5 TO HOLTEC LETTER 5014811 Table 4.IIl.7: Maximum Temperatures and Pressures Under 32-Hour 100% Air Inlets Blockage Accident Component Temoeraturef'F)

Fuel Cladding 849~

Fuel Basket 818'.7(}9.

Basket Shims 7026U MPC Shell 639.§..+.l.

MPC Lid Nole 1 599~

Overpack Inner Shell 5314-Q Body Concrete (Local Temoerature) 525~

Lid Concrete (Local Temperature)

Pressure (psi!)

447~ I MPC ~116.3 Note 1: Maximum thru thickness section avenU!.e temperature reported. I Table 4.JIJ.8: Differential Thermal Expansion Gap Description Differential Expansion

mm(in)

Fuel Basket-to-MPC Radial Gap 3.24 (0.128)~.~~ EQ.Hll1 Fuel Basket-to-MPC Axial Gap 11.50 (0.453)9.69 EQ . d8~1 MPC-to-Overpack Radial Gap 3.55 (0.140)~.Q+ EQ.1~11 MPC-to-Overpack Minimum Axial Gap 14.91 (0.587)ld .le EQ . ~~1

>l<The differential expansion values reported in this table are bounded by the nominal cold gaps presented on the drawings in Section 1.5.

HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-STORM 100 FSAR I I Proposed Rev. 14.l REPORT HI-2002444 I 4.IH-23 I Page 49 of67

BVY 17-006 I Attachment 2 I Page 5of11 ATTACHMENT 5 TO HOLTEC LETTER 5014811 Table 4.III.9: MPC-68M Pressure Under HI-TRAC Fire Accident Initial Operating Pressure See~'.:~.~ ~;:;*;:;Table 4.III.6 Fire Pressure Rise 2.9 psig Fire Accident Pressure 103.4~ psig Table 4.III.10: Open Loop Low Pressure Drying (LPD) Method Parameters for MPC-68M MPG-

,-o, L ~* 1 T Not used for th is exemption req uest HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-STORM 100 FSAR I I Proposed Rev. 1~

REPORT HI-2002444 I 4.III-24 I Page SO of 67

BVY 17-006 I Attachment 2 I Page 6of11 ATTACHMENT 5 TO HOLTEC LETTER 5014811 T able 4 III 11 HI - STORM T emperatures Un der Fue lDe b ns . Storage Component Temperature, °F Fuel Cladding 687~6¥Nole I Basket 65~QF Aluminum Shims 538~QF MPC Shell 4824G6QF Overpack Inner Shell 342~Q¥ Overpack Outer Shell 189~'1<-

Overpack Body Concrete Note 2 239.f.9441¥ Overpack Lid Concrete Note 1 2532.t-~tl'-

Average Air Outlet 24~QF Note 1: It is recognized that the assumption ofall 16 DFC locations having fuel debris instead of permitted 8 cells has the effect of slightly understating the MPC heat load because of the lower per assembly heat permitted in DFC cells. However, because the effect is small (32.28840.4 kW with all 16 cells versus 33 .14 441. 6 kW with pemtitted 8 cells) and the margins from lin1its are substantial, this has no adverse effect on the reported temperatures or conclusions. Moreover, the DFC is stored I

in the basket periphery cells. The effect ofaslight change in the heat load in the periphery cell s will have a second order effect on the peak cladding temperature which occurs in the inner cell locations.

Note 2: Maximum thru thickness section average temperature reported. I HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-STORM 100 FSAR I I Proposed Rev. 14J REPORT HI-2002444 I 4.III-25 I Page51of67

BVY 17-006 I Attachment 2 I Page 7of11 ATTACHMENT 5 TO HOLT EC LETTER 5014811 Table 4.IIl.13 HI-TRAC Transfer Cask with MPC-68M: Lowerbound Weights and Thermal Inertias Component Weight (lbs) Heat Capacity Thermal Inertia (Btu/lb-°F) (Btu/OF)

Lead 52,000 0.031 1,612 Carbon Steel 40,000 0.1 4,000 Alloy-X MPC (empty) 18,200 0.12 2,184 Fuel 47,600 0.056 2,665 Metamic-HT 6,670 0.196 1,307 Basket Shims (Alwninum) 4,500 0.207 931 MPC Cavity Wate/ 6,170 1.0 6,170 18,869 (Total)

Conserv ative lower bound water mass.

Table 4.III.14 Time-to-Boil for Water in the MPC-68M Cavity at QSHL Initial Time (hrs)

Temperature (°F) 80 17.0 90 15.7 100 14.4 110 13.l 120 11 .8 125 11.2 HOLIBC INTERNATIONAL COPYRIGHTED MATERIAL HI-STORM 100 FSAR I I Proposed Rev. 14.l REPORT HI-2002444 I 4.III-27 I Page52 of 67

BVY 17-006 I Attachment 2 I Page 8of11 ATTACHMENT 5 TO HOLTEC LETTER 501 4811 Table 4.IIl.15: Off-Normal Condition Maximum HI-STORM Temperatures and MPC Cavity Pressures Off-Normal Ambient Partial Inlet Ducts Component Temperature 1 ('F) Blockaee (°F)

Fuel Cladding 728 722 Basket 694 687 I MPC Shell 519 508 I Overpack Inner Shell 378 375 I Overpack Body Concrete (Local Temperature) 375 Note I 372 I Overpack Lid Concrete (Local Temperature) 328 Note1 327 I MPC Cavity Pressure (psig) I MPC Pressure 101.0 100.1 I Note 1: Obtained by adding the off-normal to ambient temperature difference of 20°F to the local maximum concrete temperatures dumg normal conditions. I Table 4.III.16: Summary of Burial under Debris Accident Results Item Results Burial Time 30.7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months MPC Cavity Pressure 133 .3 psig 1

Obtained by adding the off-normal-to-normal ambient temperature difference of 20°F to normal condition HI-STORM temperatw-es reported m. Tabl e 4.III 3b HOLIBC INfERNA110NAL COPYRIGHTED MATERIAL HI-STORM 100 FSAR I I Proposed Rev. 1 ~

REPORT Hl-2002444 I 4.III-28 I Page 53 of 67

BVY 17-006 I Attachment 2 I Page 9of11 ATTACHMENT 5 TO HOLTEC LETTER 5014811 Table 4.III.17: Extreme Environmental Accident Condition Maximum HI-STORM 1

Temperatures and MPC Cavity Pressure Component Temperature (°F)

Fuel Cladding 753 Basket 719 Basket Shims 608 MPC Shell 544 Overpack Inner Shell 403 Overpack Body Concrete (Local Temperature) 400 Note!

Overpack Lid Concrete (Local Temperature) 353 Note I Overpack Outer Shell 235 MPC Cavity Pressure (psig)

MPC Pressure 103.9 Note 1: Obtained by adding the extreme ambient to normal ambient temperature difference of 45°F to the local maximum concrete temperatures durng normal conditions.

1 Obtained by adding the extreme ambient to nonnal ambient temperature difference of 45°F to nonnal condition HI-STORM temoeratures reoorted m . Ta bl e 4.III 3b HOLIBC INTER.NATION AL COPYRIGHTED MATERIAL HI-STORM 100 FSAR I I Proposed Rev. l ikJ REPORT HI-2002444 I 4.III-29 I Page54 of 67

BVY 17-006 I Attachment 2 I Page 10of11 ATTACHMENT 5 TO HOLTEC LETTER 5014811 1 2 0.5* 0.5*

3 4 5 6 7 8 0.5* 0.5 1.2 1.2 0.5 0.5*

9 10 11 12 13 14 15 16 0.5* 0.5 1.2 0.4 0.4 1.2 0.5 0.5*

17 18 19 20 21 22 23 24 0.5 1.2 0.4 0.4 0.4 0.4 1.2 0.5 25 26 27 28 29 30 31 32 33 34 0.5* 1.2 0.4 0.4 0.4 0.4 0.4 0.4 1.2 0.5*

35 36 37 38 39 40 41 42 43 44 0.5* 1.2 0.4 0.4 0.4 0.4 0.4 0.4 1.2 0.5*

45 46 47 48 49 50 51 52 0.5 1.2 0.4 0.4 0.4 0.4 1.2 0.5 53 54 55 56 57 58 59 60 0.5* 0.5 1.2 0.4 0.4 1.2 0.5 0.5*

61 62 63 64 65 66 0.5* 0.5 1.2 1.2 0.5 0.5*

Cell ID 67 68 Heat Load 0.5* 0.5*

(kW)

Note: This figure provides per cell allowable heat loads for MPC-68M with all UNDAMAGED FUEL assemblies. For MPC-68M with DAMAGED FUEL and/or FUEL DEBRIS stored in this location (in a DFC), the per cell allowable heat load of the cell is limited to 0.35 kW.

Figure 2.111.1 Per Cell Allowable Heat Loads (kW) for Quarter-Symmetric Pattern -

MPC-68M HOLTEC IN1ERNATIONAL COPYRIGHTED MATERIAL HI-STORM 100 FSAR I I Proposed Rev. l G REPORT HI-2002444 I 2.ill-10 I Page 14 of67

BVY 17-006 I Attachment 2 I Page 11of11 ATTACHMENT 5 TO HOLTEC LETTER 5014811 TABLE 3.III.4 MAXIMUM DISPLACEMENT IN MPC-68M FUEL BASKET Maximum Lateral Displacement in Fuel Basket Maximum Allowable VaJue Safety Factor Panel, 6 (dimensionless) of6 (from Table 2.ill.4)

(Note 1)

&-91.008 x 10-34 0.005 ~ . 96 Notes:

1. See Subsection 2.III.0.1 for definition of e.

HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-STORM 100 FSAR I I Proposed Rev. l H REPORT Hl-2002444 I 3.Ill-19 I Page21 of67

BVY 17-006 Docket Nos. 50-271 , 72-59, and 72-1014 Attachment 3 Vermont Yankee Nuclear Power Station Markup of CoC Appendix A & B pages to aid in the Review of Exemption Request

Mark up of Amendment 10 to reflect proposed Amendment 12 Exemption Request CERTIFICATE OF COMPLIANCE NO. 1014 APPENDIX A TECHNICAL SPECIFICATIONS FOR THE HI-STORM 100 CASK SYSTEM

SFSC Heat Removal System 3.1.2 COMPLETION CONDITION REQUIRED ACTION TIME 64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months (Storage C.2.2 Transfer the MPC into a TRANSFER CASK. cell heat loads_:::

Tables 3-3 or 3-4 limits) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Storage cell heat loads>

Tables 3-3 or 3-4 limits)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1 .2 Verify all OVERPACK inlets and outlets are free 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of blockage from solid debris or floodwater.

OR For OVERPACKS with installed temperature 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months mon itoring equipment, verify that the difference between the average OVERPACK air outlet temperature and ISFSI ambient temperature is

_::: 155°F for OVERPACKS containing PWR MPCs, _::: 137°F for OVERPACKS containing BWRMPCs. '

(except MPC-68M) and~ 164°F for OVERPACKS containing MPC-68M.

Certificate of Compliance No. 1014 Amendment No. 10 Appendix A 3.1.2-2

MPC Cavity Drying Lim its Table 3-1 Table 3-1 MPC Cavity Drying Limits for all MPC Types Method of Moisture Fuel Burnup MPC Heat Load (kW) Removal (MWD/MTU)

(Notes 1 and 2)

30Note 5 (M PC-24/24E/24EF, MPC-32/32F, MPC-68/68F/68FF)

All Assemblies :::; 45,000 VOS or FHD

36 .9Note 6 (MPC-68M)

42 .aNote 7 (MPC-68M)

> 30Note 6 (MPC-24/24E/24EF, All Assemblies :::; 45,000 FHD MPC-32/32F, MPC-68/68F/68FF)

One or more assemblies VDSNote 4 or FHD

5 29 (M PC-68M)

> 45,000

36.9Note 6 (MPC-One or more assemblies 24/24E/24EF/MPC-32/32F/MPC-FHD

> 45,000 68/68F /68FF /MPC-68M

42 .aNote 7 (MPC-68M)

Notes :

1. VOS means a vacuum drying system. The acceptance criterion when using a VOS is MPC cavity pressure shall be < 3 torr for > 30 minutes.

2. FHD means a forced helium dehydration system. The acceptance criterion when using an FHD system is the gas temperature exiting the demoisturizer shall be< 21°F for> 30 minutes or the gas dew point exiting the MPC shall be< 22 .9°F for> 30 minutes.

3. Deleted

4. The maximum allowable decay heat per fuel storage location is 0.426 kW.

5. Maximum allowable storage cell heat load is 1.25 kW (MPC-24/24E/24EF) , 0.937 kW (MPC-32/32F) and 0.441 kW (MPC-68/68F/68FF).

6. Maximum allowable heat loads under uniform or regionalized storage defined in Appendix B, Section 2.4.1 or 2.4.2.

7. Maximum per assembly allowable heat loads defined in Appendix B, Figure 2.4-1.

Certificate of Compliance No. 1014 Amendment No. 1O Append ix A 3.4- 1 3.4-1

MPC Helium Backfill Limits Table 3-2 Table 3-2 MPC Helium Backfill Limits 1 MPC MODEL LIMIT MPC-24/24E/24EF

i. Cask Heat Load s; 27.77 kW (MPC-24) 0.1212 +/-10% g-moles/I or s; 28.17 kW (MPC-24E/EF) -

OR uniformly distributed per Table 3-4 or ;:: 29.3 psig ands; 48.5 psig regionalized loading per Table 3-3 ii. Cask Heat Load >27.77 kW (MPC-24) or > 28.17 kW (MPC-24E/EF) -

un iformly distributed

45.5 psig ands; 48.5 psig or greater than reg ionalized heat load limits per Table 3-3 M PC-68/68 F/68FF /68M

i. Cask Heat Load s; 28. 19 kW - 0.1218 +/-10% g-moles/I uniform ly distributed per Table 3-4 OR or regional ized loading per Table 3-3 ;:: 29.3 psig and s; 48.5 psig

11. Cask Heat Load > 28 .19 kW -

uniformly distributed or ;:: 45.5 psig and s; 48.5 psig greater than regionalized heat load See revised text below limits per Table 3-3 MPC-32/32F

i. Cask Heat Loads; 28.74 kW-uniformly distributed per Table 3-4 ;:: 29.3 psig and s; 48.5 psig or regionalized loading per Table 3-3 ii. Cask Heat Load >28 .74 kW -

uniformly distributed or ;:: 45.5 psig ands; 48.5 psig greater than reg ionalized heat load limits per Table 3-3 1

Helium used for backfill of MPC shall have a purity of 2: 99.995% . Pressure range is at a reference temperature of 70°F Certificate of Compliance No. 1014 Amendment No. 10 Appendix A 3.4-2

Table 3-2 MPC Helium Backfill Limits 1 MPC MODEL LIMIT MPC-68/68F/68FF/68M

i. Cask Heat Load ::5 28.19 kW - 0 .1218 +/-10% g-moles/I uniformly distributed per Table 3-4 OR or regionalized loading per Table 3-3 ~ 29.3 psig and ::5 48.5 psig ii. Cask Heat Load > 28.19 kW -

uniformly distributed

~ 45 .5 psig and ::5 48.5 psig or greater than regionalized load limits per Table 3-3 iii. Cask Heat Load ::5 42 .8 kW (MPC-68M) -

Regionalized Loading Pattern shown in ~ 43.5 psig and ::5 46.5 psig Appendix B, Figure 2.4-1

MPC Heat Load Limits Table 3-3 Table 3-3: Regionalized StorageNote 2 Cell Heat Load Limits MPC Type Number of Storage Cell Number of Storage Cell Cells in Inner Heat Load Cells in Outer Heat Load RegionNote 1 (Inner Region) RegionNote 1 (Outer Region)

(kW) (kW) .

MPC-24 4 1.470 20 0.900 MPC-24E/EF 4 1.540 20 0.900 MPC-32/32F 12 1.131 20 0.600 MPC- 0.500 36 0.275 68/68F/68FF ~ ... 1/68M 12 Note 1: The location of MPC-32 and MPC-68 inner and outer region cells are defined in Appendix B Figures 2.1-3 and 2.1-4 respectively .

The MPC-24 and MPC-24E/EF cell locations are defined below:

Inner Region Cell numbers 9, 10, 15, 16 in Appendix B Figures 2.1-1 and 2.1-2 respectively .

Outer Region Cell numbers 1-8, 11-14, 17-24 in Appendix B Figures 2.1-1and2.1-2 respectively.

Note 2: The storage cell regional ization is defined in Note 1 in accordance with safety analyses under the heat load limits of this Table.

Table 3-4: Uniform Storage Cell Heat Load Limits MPC Type Heat Load (kW)

MPC-24 1.157 MPC-24E/EF 1.173 M PC-68/68F/68FF 0.414 MPC-32 0.898 Certificate of Compliance No. 1014 Amendment No. 10 Appendix A 3.4-3

Mark up of Amendment 10 to reflect proposed Amendment 12 Exemption Request CERTIFICATE OF COMPLIANCE NO. 1014 APPENDIX B APPROVED CONTENTS AND DESIGN FEATURES FOR THE HI-STORM 100 CASK SYSTEM

Approved Contents 2.0

2. 0 Approved Contents 2.1 Fuel Specifications and Loading Conditions (cont'd) 2.1.3 Regionalized Fuel Loading Users may choose to store fuel using reg ionalized loading in lieu of uniform loading to allow higher heat emitting fuel assemblies to be stored than would otherwise be able to be stored using uniform loading.

Regionalized loading is limited to INTACT FUEL ASSEMBLIES or UNDAMAGED FUEL ASSEMBLIES with ZR cladding . Figures 2.1-1 through 2.1-4 define the regions for the MPC-24, MPC-24E, MPC-24EF, MPC-32, MPC-32F, MPC-68 , MPC-68FF, and MPC-68M models, respectively 1 . Fuel assembly burnup, decay heat, and coo ling time limits for regionalized loading are specified in Section 2.4.2. Fuel assemblies used in regionalized loading shall meet all other applicable limits specified in Tables 2.1-1through2.1-3.

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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , 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.

2.3 Not Used These figures are only intended to distinguish the fuel loading regions. Other details of the basket design are illustrative and may not reflect the actual basket design details.

The design drawings should be consulted for basket design details.

Certificate of Compliance No. 1014 Amendment No. 10 Append ix B 2-2

Approved Contents 2.0 Table 2. 1-1 (page 25 of 29)

Fuel Assembly Limits VI. MPC MODEL: MPC-68M A. Allowable Contents

1. Uranium oxide BWR UNDAMAGED FUEL ASSEMBLIES listed in Table 2.1-3, with or without channels and meeting the following specifications:

a. Cladding Type: ZR

b. Maximum PLANAR-AVERAGE As specified in Table 2.1-3 for the INITIAL ENRICHMENT: applicable fuel assembly array/class.

c. Initial Maximum Rod Enrichment As specified in Table 2.1-3 for the applicable fuel assembly array/class.

d. Post-irradiation Cool ing Time and Average Burnup Per Assembly

i. Array/Class 8x8F Cooling time ~ 10 years and an average burnup s; 27,500 MWD/MTU .

ii. All Other Array/Classes Cooling time~ 2 years, average burnup ~ 65 ,000 MWD/MTU, and decay heat as specified in Section 2.4 .2.

Certificate of Compliance No. 1014 Amendment No. 10 Appendix 8 2-31

Approved Contents 2.0 Table 2. 1-1 (page 27 of 29)

Fuel Assembly Lim its VI. MPC MODEL: MPC-68M (continued)

A. Allowable Contents (continued)

2. Uranium oxide BWR DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS , with or w ithout channels, placed in DAMAGED FUEL CONTAINERS . Uranium oxide BWR DAMAGED FUEL ASSEMBLIES and FUEL DEBRIS shall meet the criteria specified in Table 2.1-3, and meet the following specifications:

a. Cladding Type: ZR

b. Maximum PLANAR-AVERAGE As specified in Table 2.1-3 for the INITIAL ENRICHMENT: applicable fuel assembly array/class.

c. Initial Maximum Rod Enrichment As specified in Table 2.1-3 for the applicable fuel assembly array/class.

d. Post-irradiation Cooling Time and Average Burnup Per Assembly:

i. Array/Class 8x8F Cooling time ~ 10 years and an average burnup :5 27, 500 MW D/MTU .

ii . All Other Array/Classes Cooling time 2: 2 years, average burnup s 65 ,000 MWD/MTU, and decay heat as specified in Section 2.4 .2.

Certificate of Compliance No. 1014 Amendment No. 10 Appendix B 2-33

Approved Contents 2.0 2.4 .2 Reg ionalized Fuel Load ing Decay Heat Limits for ZR-Clad Fuel (Intact or Undamaged Fuel only)

The maximum allowable decay heat per fuel storage location for intact fuel assemblies in reg ionalized loading is determined using the following equations:

Q(X) =2 x Q 0 I (1 + XY) y = 0.23 I X0 1 qz = Q(X) I (n1 x X +n2) q1 = qz x X Where :

Oo = 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 .

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

An optional regionalized loading pattern for MPC-68M is shown in Figure 2.4-1.

The actual heat load value for each assembly is calculated utilizing SCALE 4 .3, based on the assembly burnup , enrichment, and cooling time , the operating parameters in Section 5.2 of the FSAR, and the fuel parameters from Table 2.1-1 . For calculating the heat load, it is acceptable use a higher burnup, and/or a lower enrichment, and/or a shorter cooling time than the actual values . This calculated heat load is compared to the maximum allowable decay heat for the assembly storage location that was determined by using one of the two options above (utilizing Table 2.4-2 or Figure 2.4-1) .

Table 2.4-2 Fuel Storage Regions per MPC MPC Model Number of Storage Locations Number of Storage in Inner Region (Region 1) Locations in Outer Region (Region 2)

MPC-24 and MPC-24E/EF 12 12 MPC- 32/32F 12 20 MPC-68/68FF/68MNote 1 32 36 Note 1: for an optional regionalized loading pattern for MPC-68M , see Figure 2.4-1 .

Certificate of Compliance No. 1014 Amendment No. 10 Appendix B 2-49

1 2 0.5* 0.5*

3 4 5 6 7 8 0.5* 0.5 1.2 1.2 0.5 0.5*

9 10 11 12 13 14 15 16 0.5* 0.5 1.2 0.4 0.4 1.2 0.5 0.5*

17 18 19 20 21 22 23 24 0.5 1.2 0.4 0.4 0.4 0.4 1.2 0.5 25 26 27 28 29 30 31 32 33 34 0.5* 1.2 0.4 0.4 0.4 0.4 0.4 0.4 1.2 0.5*

35 36 37 38 39 40 41 42 43 44 0.5* 1.2 0.4 0.4 0.4 0.4 0.4 0.4 1.2 0.5*

45 46 47 48 49 50 51 52 0.5 1.2 0.4 0.4 0.4 0.4 1.2 0.5 53 54 55 56 57 58 59 60 0.5* 0.5 1.2 0.4 0.4 1.2 0.5 0.5*

61 62 63 64 65 66 0.5* 0.5 1.2 1.2 0.5 0.5*

Cell ID 67 68 Heat Load 0.5* 0.5*

(kW)

When DAMAGED FUEL or FUEL DEBRIS is stored in this location (in a DFC),

the allowable heat load of the cell is limited to 0.35 kW Figure 2.4-1 Per Cell Allowable Heat Loads (kW) - MPC-68M

BVY 17-006 Docket Nos. 50-271 , 72-59, and 72-1014 Attachment 4 Vermont Yankee Nuclear Power Station Cost Avoidance Analysis of Dry Fuel Storage Completion in 2018 vs. 2020

BVY 17-006 I Attachment 4 I Page 1of5 Cost Avoidance Analysis of Dry Fuel Storage Completion in 2018 vs. 2020 As discussed in Section V of Attachment 1 to this letter, the requested exemptions are authorized by law and will not endanger life or property or the common defense and security, and are otherwise in the public interest. While 10 CFR 72.7 Specific exemptions does not specify a requirement for "special circumstances" similar to 10 CFR 50.12, compliance with the regulations that would require Entergy Nuclear Operations, Inc. (ENO) to adhere to certain requirements of Amendment 1Oto Holtec HI-STORM 100 Certificate of Compliance (CoC) No. 72-1014 would result in an undue hardship or other costs that are significant and could be avoided by the granting and implementation of this exemption request. Specifically, the avoided costs result from allowing the Vermont Yankee Nuclear Power Station (VY) dry fuel storage loading campaign to continue uninterrupted and be completed in 2018. This is shown by a comparison of changes in cash flows as discussed below and presented in the following tables.

Table 1 shows the annual cash flow analysis for completing the transfer to dry storage in 2020. The information in Table 1 reflects information previously submitted for VY pursuant to 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) in Reference 1, which was also based on completing the transfer in 2020. For the years 2017-2020, differences between Table 1 and Reference 1 for license termination expenses (Column 1) are due to adjustments in cash flows using updated cost projections based on recent experience during the current phase of decommissioning. There are no significant differences between spent fuel management costs (Column 2) and the transfer to dry storage (Column 3).

Table 2 shows the annual cash flow analysis for completing the transfer to dry storage in 2018. The information in Table 2 reflects information previously submitted for VY pursuant to 10 CFR 50.75(f)(1) and 10 CFR 50.82(a)(8)(v) in Reference 2, and pursuant to 10 CFR 50.54(bb) in Reference 3. References 2 and 3 included certain assumptions related to completing the transfer in 2018 as discussed further below. For years 2017-2018 in Table 2 and References 2 and 3, cash flows for license termination expenses (Column 1) have been adjusted to reflect updated cost projections based on recent experience during the current phase of decommissioning , similar to as described for Table 1 above. In this manner, other costs not directly related to completion of the dry fuel storage campaign were not significantly changed, in order to isolate and show the impact of the schedule change for the purpose of this analysis.

In the tables , the dry fuel storage loading campaign is shown as "Dry Fuel Spent Fuel Management Costs "(Column 3). This cost category is being funded by external cred it facilities, and is not significantly impacted by the change in schedule.

In order to demonstrate the avoided costs due to completing the transfer to dry fuel storage in 2018, a comparison between Table 1 and Table 2 shows that the largest differences in cash flows are in years 2017-2020. Using the sub-total figures at the bottom of the tables, the difference between Table 1 and Table 2 under "License Termination Cost plus Spent

BVY 17-006 I Attachment 4 I Page 2 of 5 Fuel Management Cost less Dry Fuel Cost" (Column 4) shows a reduction in cash flows (avoided costs) of $64M. Included in this number is the difference of $42M between Table 1 and Table 2 under "License Termination Cost" (Column 1). These differences reflect the avoided costs , primarily due to earlier implementation of staffing reductions to a level commensurate with dry fuel storage only operations.

The NRC previously granted ENO an exemption (Reference 4) from 10 CFR 50.82(a)(8)(i)(A) that permits the use of the DTF to manage spent fuel costs in accordance with the updated Irradiated Fuel Management Program (Reference 5) and the post-shutdown decommissioning activities report (PSDAR) (Reference 6). As such, the difference in Column 4 also includes $22M in avoided costs associated with spent fuel management expenses, also primarily due to staffing reductions , that would otherwise be incurred and allowed to be reimbursed from VY's Decommissioning Trust Fund (DTF) in accordance with Reference 4. Thus, completion of the transfer to dry storage in 2018 would result in significant avoided costs related to certain spent fuel management expenses that may be reimbursed from the DTF, in addition to the License Termination expenses.

The projected ending Trust Fund Balance for Year 2075 (Column 9) shows $60.4M for Table 1 and $257.0M for Table 2, representing an increase of $196.6M as a result of the schedule change. This increase demonstrates that the avoided costs which would be realized by approval of the requested exemptions provide significant additional assurance that adequate funds will be available in the DTF to complete all activities associated with decommissioning and irradiated fuel management activities based on the decommissioning approach described in the PSDAR (Reference 6).

In Reference 6, ENO submitted the VY PSDAR which included the schedule for the decommissioning period with spent fuel in wet storage. This period includes completion of preparations for the ISFSI and the transfer of all spent fuel from the spent fuel pool to the ISFSI. By Reference 7, ENO submitted an update to schedule information provided in References 5 and 6 to reflect anticipated completion of the transfer by late 2018, provided the criteria for transfer are met, including certain regulatory approvals. This completion date is considered reasonable based on typical review schedules for the anticipated NRC approval of this exemption request by the requested date, or alternatively the Holtec proposed Amendments 11 and 12 to the HI-STORM 100 CoC. In the case that these regulatory approvals were not obtained to support the schedule described in Reference 7, the criteria for loading the remaining casks under the approved CoC Amendment 1O would be reasonably expected to be met to allow completion of the transfer to dry fuel storage by mid-2019, although the avoided costs would be significantly less than if the requested exemptions are granted.

This exemption request supports VY reaching the milestone of all spent fuel in dry fuel storage up to approximately two years earlier than previously projected, minimizing delay in reducing facility staffing to levels appropriate for dry fuel storage only configuration , and thereby avoiding significant unnecessary expenditures from the DTF. In this respect, the exemption request is considered to be consistent with a best practices approach for submission of other decommissioning transition licensing actions, such as described in

BVY 17-006 I Attachment 4 I Page 3 of 5 Reference 8. Furthermore, timely approval of the exemption request promotes predictability and efficiency in allowing VY to reach the dry fuel storage only milestone.

References

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Decommissioning Funding Status Report per 10 CFR §50.75(f)(1) and 10 CFR 50.82{a)(8)(v) - Entergy Nuclear Operations, Inc. ," CNR0-2016-0001 O, March 30, 2016 (ML16090A355)

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Decommissioning Funding Status Report per 10 CFR §50.75(f}{1) and 10 CFR 50.82{a)(8)(v) - Entergy Nuclear Operations, Inc.," CNR0-2017-00009, March 31 , 2017 (ML17093A926}

3. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Status of Funding for Managing Irradiated Fuel for Year Ending December 31, 2016 - 10 CFR 50.82(a)(8)(vii) ,"

ENOC-17-00006, March 30, 2017 (ML17089A717}

4. Letter, USNRC to Entergy Nuclear Operations, Inc., "Vermont Yankee Nuclear Power Station - Exemptions from the Requirements of 10 CFR Part 50, Sections 50.82(a)(8)(i)(A) and 50.75{h}{1}{iv) (TAC No. MF5575} ," June 17, 2015 (ML15128A219}

5. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Update to Irradiated Fuel Management Program Pursuant to 10 CFR 50.54{bb )," BVY 14-085, dated December 19, 2014{ML14358A251)

6. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Post Shutdown Decommissioning Activities Report," BVY 14-078, dated December 19, 2014 (ML14357A110)

7. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Schedule Change for Dry Fuel Loading Campaign ," BVY 17-013, dated April 12, 2017 (ML17104A050}

8. USNRC Report, "Power Reactor Transition from Operations to Decommissioning Lessons Learned Report," October 2016 (ML16085A029}

BVY 17-006 I Attachm ent 4 /Page 4 of 5 Table 1: Transition to Dry Fuel Storage in 2020 Vermo nt Yankee Nuclear Power Station - SAFSTOR Methodology Annual Cash F l ow Anal ysi s - Total License Termination , Spen t Fuel Man agemen t less Dry F u e l Costs (In Thousands in 2016 Dollars)

Column4 License Column3 Termination Column 1 Column2 Exclude Cost plus Column5 50.75 50.54 (bb) Dry Fuel Spent Fuel Beginning Column9 License Spent Fuel Spent Fuel Management of Year Columns Year Ending Termination Management Management Cost less Dry Trust Fund Column6 Column7 Trust Fund Trust Fund Cost Cost Cost Fuel Cost Balance Withdraw Contribute Earnings Balance Year (thousands) (thousands) (thou sands) (thousands) (thousand s) (thousands) (thousands) (thou sands) (thousands) 2017 31,726 52,301 34,353 49,673 561,615 49,673 0 10,239 522,180 2018 30,279 36,645 19,752 47,172 522,180 47,172 0 9,500 484, 509 2019 31,647 36,929 17,022 51,554 484,509 51, 554 0 8,659 441,614 2020 20, 774 27,680 17,625 30,829 441,614 30,829 0 8, 216 419,001 2021 5,414 4,131 9,545 419,001 9,545 0 8,189 417,645 2022 5,362 4,131 9,492 417,645 9,492 0 8,163 416,315 2023 5,362 4,131 9,492 416,315 9,492 0 8,136 414,959 2024 3,741 4,142 7,883 414,959 7,883 0 8,142 415,217 2025 3, 680 4,131 7,811 415,217 7,811 0 8,148 415,555 2026 3,829 4,131 7,960 415,555 7,960 0 8,152 415,747 2027 3,882 4,131 8,012 415,747 8,012 0 8,155 415,890 2028 3,838 4,142 7,980 415,890 7,980 0 8,158 416,068 2029 3,829 4,131 7,960 416,068 7,960 0 8,162 416, 270 2030 3,882 4,131 8,012 416,270 8,012 0 8,165 416,423 2031 3,829 4,131 7,960 416,423 . 7,960 0 8,169 416,633 2032 3,838 4,142 7,980 416,633 7,980 0 8,173 416,826 2033 3,882 4,131 8,012 416,826 8,012 0 8,176 416,990 2034 3,829 4,131 7,960 416,990 7,960 0 8,181 417,211 2035 3,829 4, 131 7,960 417,211 7,960 0 8, 185 417,436 2036 3,891 4,142 8,033 417,436 8,033 0 8,188 417, 592 2037 3,829 4,131 7,960 417, 592 7,960 0 8,193 417,825 2038 3,829 4,131 7,960 417,825 7,960 0 8,197 418,062 2039 3,882 4,131 8,012 418,062 8,012 0 8,201 418, 251 2040 3,838 4, 142 7,980 418,251 7,980 0 8,205 418,476 2041 3,829 4,131 7,960 418,476 7,960 0 8, 210 418,727 2042 3,882 4,131 8,012 418, 727 8,012 0 8,214 418,929 2043 3,829 4,131 7,960 418,929 7,960 0 8,219 419,189 2044 3,838 4,142 7,980 419,189 7,980 0 8,224 419,433 2045 3,882 4,131 8,012 419,433 8,012 0 8,228 419,649 2046 3,829 4,131 7,960 419,649 7,960 0 8,234 419,923 2047 3,829 4,131 7,960 419,923 7,960 0 8,239 420,203 2048 3,891 4,142 8,033 420,203 8,033 0 8,243 420,414 2049 3,829 4,131 7,960 420,414 7,960 0 8,249 420,703 2050 3,829 4,_131 7,960 420,703 7,960 0 8,255 420,998 2051 3,882 4,131 8,012 420,998 8,012 0 8,260 421,246 2052 3,838 4,142 7,980 421,246 7,980 0 8,265 421,531 2053 3,671 3,671 421,531 3,671 0 8,357 426,217 2054 3,724 3,724 426,217 3,724 0 8,450 430,943 2055 3,671 3,671 430,943 3,671 0 8,545 435,817 2056 3,680 3,680 435,817 3,680 0 8,643 440,779 2057 3,724 3,724 440,779 3,724 0 8,741 445,796 2058 3,671 3,671 445,796 3,671 0 8,842 450,967 2059 3,671 3,671 450,967 3,671 0 8,946 456,242 2060 3, 733 3,733 456,242 3,733 0 9,050 461,559 2061 3,671 3,671 461,559 3,671 0 9,158 467,045 2062 3,671 3,671 467,045 3,671 0 9,267 472,641 2063 3,724 3,724 472,641 3,724 0 9,378 478, 296 2064 3,680 3,680 478,296 3,680 0 9,492 484,108 2065 3,671 3,671 484,108 3,671 0 9,609 490,045 2066 3,724 3,724 490,045 3,724 0 9,726 496,047 2067 3,671 3,671 496,047 3,671 0 9,848 502, 223 2068 44,223 44, 223 502, 223 44,223 0 9,160 467, 160 2069 94, 118 94, 118 467,160 94, 118 0 7,461 380, 502 2070 107,412 107,412 380,502 107,412 0 5,462 278,553 2071 87,194 87,194 278,553 87,194 0 3,827 195,186 2072 87,640 87,640 195,186 87,640 0 2, 151 109,696 2073 51,945 51,945 109,696 51,945 0 1, 155 58,906 2074 537 537 58,906 537 0 1, 167 59,536 2075 310 310 59,536 310 0 1,185 60,411 770,644 285,828 88,752 967, 720 561,615 967, 720 0 466, 516 60,411

BVY 17-006 I Attachment 4 I Page 5 of 5 Table 2: Transition to Dry Fuel Storage in 2018 Vermont Yankee Nuclear Power Station - SAFSTORMethodology Annual Cash Flow Analysis - Total License Termination, Spent Fuel Management Jess Dry Fuel Costs (In Thousands in 2016 Dollar>)

Column 4 License Column3 Termination Column 1 Column2 Exclude Cost plus C olumn5 50.75 50.54 (bb) Dry Fuel Spent Fuel Beginning Column9 License Spent Fuel Spent Fuel Management of Year Column8 Y ear Ending T ermination Management Management Cost less Dry Trust Fund Column6 Column7 Trust Fund Trust Fund Cost Cost Cost Fuel Cost Balance Withdraw Contribute Earnings Balance Year (thousands) (thousands) (thousands) (thousand s) (thousands) (thousand s) (thousand s) ( thousands) (thousand s) 2017 31,683 64,082 46,134 49,630 561,615 49,630 o 10,240 522,224 2018 32,707 60,258 43,366 49,600 522,224 49,600 o 9,452 482,077 2019 5,414 4, 131 9,545 482,077 9,545 o 9,451 481,983 2020 5,362 4,131 9,492 481,983 9,492 o 9,450 481,940 2021 5,362 4,131 9,492 481,940 9,492 o 9,449 481,896 2022 3,741 4,131 7,8n 481,896 7,872 o 9,480 483,505 2023 3,741 4,131 7,872 483,505 7,872 o 9,513 485,145 2024 3,741 4,142 7,883 485,145 7,883 o 9,545 486,807 2025 3,680 4,131 7,811 486,807 7,811 o 9, 580 488,577 2026 3,829 4,131 7,960 488,577 7,960 o 9,612 490,229 2027 3,882 4,131 8,0ll 490,229 8,012 o 9,644 491,861 2028 3,838 4,142 7,980 491,861 7,980 o 9,678 493, 559 2029 3,829 4,131 7,960 493,559 7,960 o 9,712 495,311 2030 3,882 4,131 8,012 495,311 8,012 o 9,746 497,045 2031 3,829 4,131 7,960 497,045 7,960 o 9.782 498,867 2032 3,838 4,142 7,980 498,867 7,980 o 9,818 500,705 2033 3,882 4,131 8,012 500.705 8,012 o 9,854 502,546 2034 3,829 4,131 7,960 502,546 7,960 0 9,892 504,478 2035 3,829 4,131 7,960 504,478 7,960 0 9,930 506,449 2036 3,891 4,142 8,033 506,449 8,033 0 9,968 508,385 2037 3,829 4,131 7,960 508,385 7,960 0 10,009 510,434 2038 3,829 4,131 7,960 510,434 7,960 0 10,049 512,523 2039 3,882 4,131 8,012 512,523 8,012 o 10,090 514,601 2040 3,838 4,142 7,980 514,601 7,980 0 10, 132 516, 754 2041 3,829 4,131 7,960 516,754 7,960 0 10, 176 518,970 2042 3,882 4,131 8,012 518,970 8,012 0 10,219 521,177 2043 3,829 4,131 7,960 521,177 7,960 0 10, 264 523,482 2044 3,838 4,142 7,980 523,482 7,980 0 10,310 525,812 2045 3,882 4,131 8,012 525,812 8,012 0 10, 356 528,155 2046 3,829 4,131 7,960 528,155 7,960 0 10,404 530,600 2047 3,829 4,131 7,960 530,600 7,960 0 10,453 533,093 2048 3,891 4,142 8,033 533,093 8,033 0 10,501 535,561 2049 3,829 4,131 7,960 535,561 7,960 0 10, 552 538,154 2050 3,829 4,131 7,960 538,154 7,960 0 10,604 540,798 2051 3,882 4,131 8,012 540,798 8,012 o 10,656 543,441 2052 3,838 4,142 7,980 543,441 7,980 0 10, 709 546,171 2053 3,671 0 3,671 546,171 3,671 0 10,850 553,349 2054 3,724 0 3,724 553,349 3,724 0 10,993 560,618 2055 3,671 0 3,671 560,618 3,671 0 11,139 568,085 2056 3,680 0 3,680 568,085 3,680 0 11,288 575, 693 2057 3,724 0 3,724 575,693 3,724 0 11,439 583,408 2058 3,671 0 3,671 583,408 3,671 o 11,595 591,332 2059 3,671 0 3,671 591,332 3,671 0 11,753 599,413 2060 3, 733 0 3,733 599,413 3,733 0 11,914 607,594 2061 3,671 0 3,671 607,594 3,671 0 12,078 616,001 2062 3,671 0 3,671 616,001 3,671 0 12,247 624,576 2063 3,724 0 3,724 624,576 3,724 0 12,417 633, 269 2064 3,680 0 3,680 633,269 3,680 0 12,592 642,181 2065 3,671 0 3,671 642,181 3,671 0 12, 770 651, 279 2066 3,724 o 3,724 651,279 3,724 0 12,951 660,506 2067 3,671 o 3,671 660,506 3,671 0 13,137 669,972 2068 44,223 o 44,223 669,972 44,223 o 12,515 638,263 2069 94,118 0 94, 118 638,263 94,118 o 10, 883 555,028 2070 107,412 0 107,412 555,028 107,412 0 8,952 456,568 2071 87,194 0 87,194 456,568 87,194 0 7, 387 376, 762 2072 87,640 0 87,640 376,762 87,640 0 5, 782 294,904 2073 51,945 0 51,945 294,904 51,945 0 4,859 247,818 2074 537 o 537 247,818 537 0 4,946 252,226 2075 310 o 310 252, 226 310 o 5,038 256,955 728,091 264,875 89,500 903,466 561,615 903,466 o 598,806 256,955

BVY 17-006 Docket Nos. 50-271 , 72-59, and 72-1014 Attachment 5 Vermont Yankee Nuclear Power Station Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure

U.S. Nuclear Regulatory Commission Document ID BVY-17-006 AFFIDAVIT PURSUANT TO 10 Cjj,R 2.390 I, Kimberly Manzione, being duly sworn, depose and state as follows:

(1) I have reviewed the information described in paragraph (2) which is sought to be with~eld, and am authorized to apply for its withholding.

(2) The information sought to be withheld is information provided in Attachment 6 to BVY-17-006, which includes Holtec Reports HI-2083980, Rev 4 and HI-2146076 Rev 4. These attachments contain Holtec Proprietary information.

(3) In making this application for withholding of proprietary information of which it is the owner, Holtec International relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4) and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10CFR Part 9.17(a)(4), 2.390(a)(4), and 2.390(b)(l) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information",

and some portions also qualify under the narrower definition of "trade secret", within the meanings assigned to those tenns for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2dl280 (DC Cir. 1983).

I of 5

U.S. Nuclear Regulatory Commission Document ID BVY-17-006 AFFIDAVIT PURSUANT TO 10 CFR 2.390 (4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by Holtec's competitors without license from Holtec International constitutes a competitive economic advantage over other companies; b~ Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

c. Information which reveals cost or price information, production, capacities, budget levels, or commercial strategies of Holtec International, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future Holtec International

customer-funded development plans and programs of potential commercial value to Holtec International;

e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs 4.a, 4.b and 4.e above.

(5) The information sought to be withheld is being submitted to the NRC in confidence. The information (including that compiled from many sources) is of a sort customarily held in confidence by Holtec International, and is in fact so held. The infonnation sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by Holtec International. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as 2 of 5

U.S. Nuclear Regulatory Commission Document ID BVY-17-006 AFFIDAVIT PURSUANT TO 10 CFR 2.390 proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within Holtec International is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his designee ), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside Holtec International are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information classified as proprietary was developed and compiled by Holtec International at a significant cost to Holtec International. This information is classified as proprietary because it contains detailed descriptions *of analytical approaches and methodologies not available elsewhere. This information would provide other parties, including competitors, with information from Holtec International's technical database and the results of evaluations performed by Holtec International. A substantial effort has been expended by Holtec International to develop this information. Release of this information would improve a competitor's position because it would enable Holtec's competitor to copy our technology and offer it for sale in competition with our company, causing us financial InJUry.

3of5

U.S. Nuclear Regulatory Commission Document ID BVY-17-006 AFFIDAVIT PURSUANT TO 10 CFR 2.390 (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to Holtec International's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of Holtec International's comprehensive spent fuel storage technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology, and includes development of the expertise to determine and apply the appropriate evaluation process.

The research, development, engineering, and analytical costs comprise a substantial investment of time and money by Holtec International.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

Holtec International's competitive advantage will be lost if its competitors are able to use the results of the Holtec International experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to Holtec International would be lost if the *.

information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive Holtec International of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

4of5

U.S. Nuclear Regulatory Commission Document ID BVY-17-006 AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF NEW JERSEY )

) ss:

COUNTY OF CAMDEN )

Kimberly Manzione, being duly sworn, deposes and says-:

That she has read the foregoing affidavit and the matters stated therein are true and correct to the best of her knowledge, information, and belief.

Executed at Marlton, New Jersey, this 15th day of May, 2017.

Kimberly Manzione Licensing Manager Holtec International

--

MARIA C.MAS$i

-~cAY PUBUC O~l\IEWJERsev wiy ommlss!Qn Eiqlli'o$Aprua, ao,ao 5of5

v t e Letter Sequence Other
CAC:L25219, (Open)
Initiation Request Acceptance... Administration Questions Answers 7 September 2017 Results Approval... Other: BVY 17-006, Exemption Request from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 to Support the Dry Fuel Loading Campaign, ML17219A047, ML17249A160
MONTHYEAR2017-05-16 [Table View]

BVY 17-006, Exemption Request from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 to Support the Dry Fuel Loading Campaign

Text

SUBJECT:

REFERENCES:

Dear Sir or Madam:

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