ML18031A227

Enclosurenewed License SNM-2507 Technical Specifications (Letter to D. G. Stoddard Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station ISFSI)

ML18031A227
Person / Time
Site:	North Anna
Issue date:	02/06/2018
From:	Hipolito Gonzalez Renewals and Materials Branch
To:	Stoddard D Virginia Electric & Power Co (VEPCO)
Banovac K
Shared Package
ML18031A221	List: ML18031A222 ML18031A224 ML18031A225 ML18031A227 ML18031A228 ML18031A231
References
CAC 001028, CAC 00993, EPID L-2017-LNE-0008, EPID L-2017-RNW-0010
Download: ML18031A227 (48)

Text

TECHNICAL SPECIFICATIONS FOR NORTH ANNA INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

Renewed License February 6, 2018

TABLE OF CONTENTS 1.0 USE AND APPLICATION . . . . . . . . . . . . . . . . . . . 1.1-1 1.1 Definitions . . . . . . . . . . . . . . . . . . . . . 1.1-1 1.2 Logical Connectors. . . . . . . . . . . . . . . . . . 1.2-1 1.3 Completion Times. . . . . . . . . . . . . . . . . . . 1.3-1 1.4 Frequency . . . . . . . . . . . . . . . . . . . . . . 1.4-1 2.0 FUNCTIONAL AND OPERATING LIMITS . . . . . . . . . . . . . 2.0-1 2.1 Functional and Operating Limits . . . . . . . . . . . 2.0-1 2.2 Functional and Operating Limits Violations. . . . . . 2.0-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY. . . 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY . . . . . . . 3.0-2 3.1 SSSC INTEGRITY. . . . . . . . . . . . . . . . . . . . 3.1.1-1 3.1.1 SSSC Cavity Vacuum Drying Pressure. . . . . . . . 3.1.1-1 3.1.2 SSSC Helium Backfill Pressure . . . . . . . . . . 3.1.2-1 3.1.3 SSSC Combined Helium Leak Rate. . . . . . . . . . 3.1.3-1 3.1.4 SSSC Interseal Pressure . . . . . . . . . . . . . 3.1.4-1 3.1.5 SSSC Maximum Lifting Height . . . . . . . . . . . 3.1.5-1 3.2 SSSC CRITICALITY CONTROL. . . . . . . . . . . . . . . 3.2.1-1 3.2.1 Dissolved Boron Concentration . . . . . . . . . . 3.2.1-1 3.3 SSSC RADIATION PROTECTION . . . . . . . . . . . . . . 3.3.1-1 3.3.1 SSSC Average Surface Dose Rates for TN-32 Casks . 3.3.1-1 3.3.2 SSSC Average Surface Dose Rates for TN-32B HBU Cask 3.3.2-1 3.3.3 SSSC Surface Contamination. . . . . . . . . . . . 3.3.3-1 Table 3-1 SSSC Model-Dependent Limits . . . . . . . . . . . . . 3.4-1 4.0 DESIGN FEATURES . . . . . . . . . . . . . . . . . . . . . 4.0-1 4.1 Site. . . . . . . . . . . . . . . . . . . . . . . . . 4.0-1 4.1.1 Site Location . . . . . . . . . . . . . . . . . . 4.0-1 4.2 Storage Features. . . . . . . . . . . . . . . . . . . 4.0-1 4.2.1 Storage Cask. . . . . . . . . . . . . . . . . . . 4.0-1 4.2.2 Storage Capacity. . . . . . . . . . . . . . . . . 4.0-1 4.2.3 Storage Pad . . . . . . . . . . . . . . . . . . . 4.0-1 4.2.4 Criticality . . . . . . . . . . . . . . . . . . . 4.0-1 4.2.5 Helium Purity . . . . . . . . . . . . . . . . . . 4.0-2 4.2.6 Special Requirements for TN Thermal Testing. 4.0-2 5.0 ADMINISTRATIVE CONTROLS . . . . . . . . . . . . . . . . . 5.1-1 5.1 Responsibility. . . . . . . . . . . . . . . . . . . . 5.1-1 5.2 Organization. . . . . . . . . . . . . . . . . . . . . 5.2-1 5.3 Facility Staff Qualifications . . . . . . . . . . . . 5.3-1 5.4 Procedures. . . . . . . . . . . . . . . . . . . . . . 5.4-1 5.5 Programs. . . . . . . . . . . . . . . . . . . . . . . 5.5-1 North Anna ISFSI i Renewed License February 6, 2018

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions NOTE The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

INDEPENDENT SPENT FUEL The facility within the perimeter fence licensed STORAGE INSTALLATION for storage of spent fuel within SSSCs.

(ISFSI)

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on an SSSC while it is being loaded with fuel assemblies. LOADING OPERATIONS begin when the first fuel assembly is placed in the SSSC and end when the SSSC is suspended from the transporter.

SEALED SURFACE STORAGE SSSCs are storage containers for spent fuel CASKS (SSSCs) approved for use at the ISFSI.

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI while an SSSC containing spent fuel is sitting on a storage pad within the ISFSI perimeter.

TRANSPORT OPERATIONS TRANSPORT OPERATIONS include all licensed activities performed on an SSSC loaded with one or more fuel assemblies when it is being moved to and from the ISFSI. TRANSPORT OPERATIONS begin when the SSSC is first suspended from the transporter and end when the SSSC is at its destination and no longer suspended from the transporter.

UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on an SSSC to be unloaded of the contained fuel assemblies. UNLOADING OPERATIONS begin when the SSSC is no longer suspended by the transporter and end when the last fuel assembly is removed from the SSSC.

North Anna ISFSI 1.1-1 Renewed License February 6, 2018

Logical Connectors 1.2 1.0 USE AND APPLICATION 1.2 Logical Connectors PURPOSE The purpose of this section is to explain the meaning of logical connectors.

Logical connectors are used in Technical Specifications (TS) to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances, and Frequencies. The only logical connectors that appear in TS are AND and OR. The physical arrangement of these connectors constitutes logical conventions with specific meanings.

BACKGROUND Several levels of logic may be used to state Required Actions. These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action. The first level of logic is identified by the first digit of the number assigned to a Required Action and the placement of the logical connector in the first level of nesting (i.e., left justified with the number of the Required Action). The successive levels of logic are identified by additional digits of the Required Action number and by successive indentions of the logical connectors.

When logical connectors are used to state a Condition, Completion Time, Surveillance, or Frequency, only the first level of logic is used, and the logical connector is left justified with the statement of the Condition, Completion Time, Surveillance, or Frequency.

EXAMPLES The following examples illustrate the use of logical connectors.

North Anna ISFSI 1.2-1 Renewed License February 6, 2018

Logical Connectors 1.2 1.2 Logical Connectors EXAMPLES EXAMPLE 1.2-1 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 Verify ...

AND A.2 Restore ...

In this example the logical connector AND is used to indicate that when in Condition A, both Required Actions A.1 and A.2 must be completed.

North Anna ISFSI 1.2-2 Renewed License February 6, 2018

Logical Connectors 1.2 1.2 Logical Connectors EXAMPLES EXAMPLE 1.2-2 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 Stop ...

OR A.2.1 Verify ...

AND A.2.2.1 Reduce ...

OR A.2.2.2 Perform ...

OR A.3 Remove ...

This example represents a more complicated use of logical connectors. Required Actions A.1, A.2, and A.3 are alternative choices, only one of which must be performed as indicated by the use of the logical connector OR and the left justified placement. Any one of these three Actions may be chosen. If A.2 is chosen, then both A.2.1 and A.2.2 must be performed as indicated by the logical connector AND.

Required Action A.2.2 is met by performing A.2.2.1 or A.2.2.2. The indented position of the logical connector OR indicates that A.2.2.1 and A.2.2.2 are alternative choices, only one of which must be performed.

North Anna ISFSI 1.2-3 Renewed License February 6, 2018

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the facility is in a specified condition stated in the Applicability of the LCO.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the facility is not within the LCO Applicability.

Once a Condition has been entered, subsequent subsystems, components, or variables expressed in the Condition, discovered to be not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.

North Anna ISFSI 1.3-1 Renewed License February 6, 2018

Completion Times 1.3 1.3 Completion Times EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required B.1 Perform Action 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and B.1.

associated Completion AND Time not met.

B.2 Perform Action 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> B.2.

Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition B are to complete action B.1 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND complete action B.2 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

A total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed for completing action B.1 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) is allowed for completing action B.2 from the time that Condition B was entered. If action B.1 is completed within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the time allowed for completing action B.2 is the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> because the total time allowed for completing action B.2 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

North Anna ISFSI 1.3-2 Renewed License February 6, 2018

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-2 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One system A.1 Restore system to 7 days not within within limit.

limit.

B. Required B.1 Complete action 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and B.1 associated Completion AND Time not met.

B.2 Complete action 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> B.2 When a system is determined to not meet the LCO, Condition A is entered. If the system is not restored within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the system is restored after Condition B is entered, Conditions A and B are exited, and therefore, the Required Actions of Condition B may be terminated.

North Anna ISFSI 1.3-3 Renewed License February 6, 2018

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS NOTE Separate Condition entry is allowed for each component.

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 Restore compliance 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> with LCO.

B. Required B.1 Complete action 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and B.1 associated Completion AND Time not met.

B.2 Complete action 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> B.2 The Note above the ACTIONS Table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table.

The Note allows Condition A to be entered separately for each component, and Completion Times tracked on a per component basis. When a component is determined to not meet the LCO, Condition A is entered and its Completion Time starts. If subsequent components are determined to not meet the LCO, Condition A is entered for each component and separate Completion Times start and are tracked for each component.

North Anna ISFSI 1.3-4 Renewed License February 6, 2018

Completion Times 1.3 1.3 Completion Times IMMEDIATE When Immediately is used as a Completion Time, the COMPLETION Required Action should be pursued without delay and in a TIME controlled manner.

North Anna ISFSI 1.3-5 Renewed License February 6, 2018

Frequency 1.4 1.0 USE AND APPLICATION 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements.

DESCRIPTION Each Surveillance Requirement (SR) has a specified Frequency in which the Surveillance must be met in order to meet the associated Limiting Condition for Operation (LCO). An understanding of the correct application of the specified Frequency is necessary for compliance with the SR.

The specified Frequency is referred to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR) Applicability. The specified Frequency consists of the requirements of the Frequency column of each SR.

Situations where a Surveillance could be required (i.e., its Frequency could expire), but where it is not possible or not desired that it be performed until sometime after the associated LCO is within its Applicability, represent potential SR 3.0.4 conflicts. To avoid these conflicts, the SR (i.e., the Surveillance or the Frequency) is stated such that it is only required when it can be and should be performed. With an SR satisfied, SR 3.0.4 imposes no restriction.

North Anna ISFSI 1.4-1 Renewed License February 6, 2018

Frequency 1.4 1.4 Frequency EXAMPLES The following examples illustrate the various ways that Frequencies are specified.

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify pressure within limit. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) during which the associated Surveillance must be performed at least one time.

Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment or a variable is outside specified limits, or the facility is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the facility is in a condition specified in the Applicability of the LCO, the LCO is not met in accordance with SR 3.0.1.

If the interval as specified by SR 3.0.2 is exceeded while the facility is not in a condition specified in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the specified condition. Failure to do so would result in a violation of SR 3.0.4.

North Anna ISFSI 1.4-2 Renewed License February 6, 2018

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-2 (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limits. Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to starting activity AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter Example 1.4-2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector AND indicates that both Frequency requirements must be met. Each time the example activity is to be performed, the Surveillance must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to starting the activity.

The use of once indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by AND). This type of Frequency does not qualify for the 25% extension allowed by SR 3.0.2.

Thereafter indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the once performance in this example). If the specified activity is canceled or not performed, the measurement of both intervals stops. New intervals start upon preparing to restart the specified activity.

North Anna ISFSI 1.4-3 Renewed License February 6, 2018

Functional and Operating Limits 2.0 2.0 FUNCTIONAL AND OPERATING LIMITS 2.1 Functional and Operating Limits 2.1.1 Fuel To Be Stored At The ISFSI The spent nuclear fuel to be stored in SSSCs at the North Anna ISFSI shall meet the following requirements:

a. Only fuel irradiated at the North Anna Power Station Unit Nos. 1 and 2 may be used.

b. Fuel assemblies shall be intact. Partial fuel assemblies, that is, fuel assemblies from which fuel rods are missing must not be loaded in SSSCs unless dummy fuel rods are used to displace an amount of water equal to that displaced by the original fuel rods.

c. Fuel assemblies known or suspected to have structural defects sufficiently severe to adversely affect fuel handling and transfer capability shall not be loaded into SSSCs for storage.

d. Fuel assemblies known or suspected to have cladding defects in excess of those approved for the SSSC design shall not be loaded into SSSCs for storage.

e. Fuel assemblies shall meet the limits for initial enrichment, average burnup, cooling time after reactor discharge, decay heat, fuel assembly design, fuel assembly initial uranium content, fuel assembly weight, and fuel assembly inserts as specified in Table 2.1-1.

2.1 Functional and Operating Limits Violations If any Functional and Operating Limits of 2.1.1 are violated, the following actions shall be completed:

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

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

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

North Anna ISFSI 2.0-1 Renewed License February 6, 2018

Functional and Operating Limits 2.0 Table 2.1-1 (page 1 of 2)

Fuel Assembly Limits SSSC MODEL LIMIT

1. TN-32

a. Initial Enrichment < 4.30 wt. %

b. Average Burnup < 45,000 MWD/MTU

c. Cooling Time After Discharge See Figure 2.1-1

d. Decay Heat Including BPRA/TPD < 1.02 kw/assembly

e. Fuel Assembly Design Westinghouse 17 x 17 Standard Westinghouse 17 x 17 Vantage 5H

f. Fuel Assembly Inserts Fuel assemblies may contain burnable poison rod assemblies (BPRAs) and/or thimble plugging devices (TPDs).

g. Fuel Assembly Weight Including 1,533 pounds BPRA/TPD

h. Cooling Time After Shutdown for See Figure 2.1-2 BPRAs in TN-32 Dry Storage Casks

i. Cooling Time After Shutdown for See Figure 2.1-3 TPDs in TN-32 Dry Storage Casks

j. Fuel Assembly Initial Uranium 467.1 KgU/assembly Content

2. TN-32B HBU

a. Initial Enrichment < 4.60 wt. % (Areva Advanced Mark BW)

< 3.64 wt. % (Westinghouse Standard)

< 4.50 wt. % (Westinghouse Vantage 5H)

b. Average Burnup < 60 GWd/MTU

c. Zone Heat Load Limits See Figure 2.1-4

d. Decay Heat < 32.934 kW

e. Fuel Assembly Design Areva Advanced Mark BW (AMBW)

Westinghouse Standard (LOPAR)

Westinghouse Vantage 5H (NAIF)

North Anna ISFSI 2.0-2 Renewed License February 6, 2018

Functional and Operating Limits 2.0 Table 2.1-1 (page 2 of 2)

Fuel Assembly Limits SSSC MODEL LIMIT

f. Fuel Assembly Inserts Poison Rod Assemblies (unirradiated)

g. Fuel Assembly Weight Including 1551 pounds PRA

h. Fuel Assembly Initial Uranium 469.0 KgU/assembly Content North Anna ISFSI 2.0-3 Renewed License February 6, 2018

Functional and Operating Limits 2.0 Table 2.2-1 (page 1 of 1)

Decay Heat Load Methodology for Fuel Stored in TN-32B HBU Cask The ORIGEN-ARP code of the SCALE 6.0 computer code package, or later, is to be used to determine the individual fuel assembly decay heat load for the zone loading represented in Figure 2.1-4.

North Anna ISFSI 2.0-4 Renewed License February 6, 2018

Functional and Operating Limits 2.0 Figure 2.1-1 Minimum Acceptable Cooling Time in Years As a Function of Burnup and Initial Enrichment (For TN-32 Casks)

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North Anna ISFSI 2.0-5 Renewed License February 6, 2018

Functional and Operating Limits 2.0 Figure 2.1-2 Cooling Time After Shutdown for Burnable Poison Rod Assemblies In TN-32 Dry Storage Casks F IG U R E 2 .1 -1 C o o lin g T im e A ft e r S h u td o w n fo r B P R A s In T N - 3 2 D r y S to r a g e C a s k s 2500 2415 Days 60 GWD/MTU 2000 1965 Days 50 GWD/MTU Acceptable 1500 1415 Days 40 GWD/MTU 1000 Unacceptable 365 Days 500 0 GWD/MTU 365 Days 30 GWD/MTU 0

0 10 20 30 40 50 60 70 C u m u la tiv e B P R A Ir r a d ia tio n T im e , G W D /M T U (The cumulative irradiation is taken to be the sum of the individual fuel assembly burnup values in which the BPRA was resident during in-core operation.)

North Anna ISFSI 2.0-6 Renewed License February 6, 2018

Functional and Operating Limits 2.0 Figure 2.1-3 Cooling Time After Shutdown for Thimble Plug Devices In TN-32 Dry Storage Casks Figure 2.1-2 Cooling T im e After Shutdow n for T PD s In T N-32 D ry S torage C asks 8000 7350 days 210 GWD/MTU 6800 days 135 GWD/MTU 7000 7200 days 180 GWD/MTU 6000 5500 days Acceptable 90 GWD/MTU Minimum Cooling Time, days 5000 4000 3000 days 3000 45 GWD/MTU Unacceptable 2000 1000 365 days 5.475 GWD/MTU 0

0 25 50 75 100 125 150 175 200 225 C umulative TPD Irradiation Tim e, GW D /MTU (The cumulative irradiation is taken to be the sum of the individual fuel assembly burnup values in which the TPD was resident during in-core operation.)

North Anna ISFSI 2.0-7 Renewed License February 6, 2018

Functional and Operating Limits 2.0 Figure 2.1-4 Zone Heat Load Limits for TN-32B HBU Cask Z1 Z2 Z3 Z4 Z5 Z6 Z7 Z8 Z9 Z10 Z11 Z12 Z13 Z14 Z15 Z16 Z17 Z18 Z19 Z20 Z21 Z22 Z23 Z24 Z25 Z26 Z27 Z28 Z29 Z30 Z31 Z32 Zone No. Heat Load Zone No. Heat Load Limit (W) (1) Limit (W)(1) 1 960 17 1045 2 1047 18 1276 3 962 19 968 4 853 20 664 5 858 21 1280 6 1111 22 1010 7 1287 23 982 8 1263 24 963 9 1043 25 1278 10 853 26 1277 11 834 27 1061 12 1279 28 965 13 581 29 970 14 1115 30 1035 15 1267 31 977 16 1009 32 861 Total Heat Load (kW) 32.934 (1) Refer to Table 2.2-1 for decay heat calculation method to be used when making comparisons to limits North Anna ISFSI 2.0-8 Renewed License February 6, 2018

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during specified conditions in the Applicability, except as provided in LCO 3.0.2.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s),

completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 Not applicable to an ISFSI LCO 3.0.4 When an LCO is not met, entry into a specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes in specified conditions in the Applicability that are required to comply with ACTIONS or that are related to the unloading of an SSSC.

LCO 3.0.5 Equipment removed from service or not in service in compliance with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate it meets the LCO or that other equipment meets the LCO. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing.

LCO 3.0.6 Not applicable to an ISFSI LCO 3.0.7 Not applicable to an ISFSI North Anna ISFSI 3.0-1 Renewed License February 6, 2018

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as once, the above interval extension does not apply. If a Completion Time requires periodic performance on a once per . . . basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is less. This delay period is permitted to allow performance of the Surveillance.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

North Anna ISFSI 3.0-2 Renewed License February 6, 2018

SR Applicability 3.0 3.0 SR APPLICABILITY SR 3.0.4 Entry into a specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. This provision shall not prevent entry into specified conditions in the Applicability that are required to comply with ACTIONS or that are related to the unloading of an SSSC.

North Anna ISFSI 3.0-3 Renewed License February 6, 2018

SSSC Cavity Vacuum Drying Pressure 3.1.1 3.1 SSSC INTEGRITY 3.1.1 SSSC Cavity Vacuum Drying Pressure LCO 3.1.1 The SSSC cavity vacuum drying pressure shall meet the limit specified in Table 3-1 for the applicable SSSC design after isolation from the pumping system.

APPLICABILITY: During LOADING OPERATIONS.

ACTIONS NOTE Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SSSC cavity vacuum A.1 ----------NOTE--------

drying pressure limit Action A.1 applies not met. until helium is removed for subsequent operations.

Achieve or maintain a 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> helium environment of greater than 0.1 atms abs in the SSSC cavity.

AND A.2 Establish SSSC cavity 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> vacuum drying pressure within limit.

B. Required Action A.1 B.1 Remove all fuel 7 days and Associated assemblies from the Completion Time not SSSC.

met.

North Anna ISFSI 3.1.1-1 Renewed License February 6, 2018

SSSC Cavity Vacuum Drying Pressure 3.1.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action A.2 C.1 Remove all fuel 30 days and Associated assemblies from the Completion Time not SSSC.

met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify SSSC cavity vacuum drying pressure ------NOTE------

is within limit. SR 3.0.2 is not applicable.

Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of completion of SSSC draining North Anna ISFSI 3.1.1-2 Renewed License February 6, 2018

SSSC Helium Backfill Pressure 3.1.2 3.1 SSSC INTEGRITY 3.1.2 SSSC Helium Backfill Pressure LCO 3.1.2 The SSSC helium backfill pressure shall meet the limit specified in Table 3-1 for the applicable SSSC design.

APPLICABILITY: During LOADING OPERATIONS.

ACTIONS NOTE Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SSSC helium backfill A.1 ---------NOTE---------

pressure limit not Action A.1 applies met. until helium is removed for subsequent operations.

Achieve or maintain a 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> helium environment of greater than 0.1 atms abs in the SSSC cavity.

AND A.2 Establish SSSC helium 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> backfill pressure within limit.

B. Required Action A.1 B.1 Remove all fuel 7 days and Associated assemblies from the Completion Time not SSSC.

met.

North Anna ISFSI 3.1.2-1 Renewed License February 6, 2018

SSSC Helium Backfill Pressure 3.1.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action A.2 C.1 Remove all fuel 30 days and Associated assemblies from the Completion Time not SSSC.

met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2.1 Verify SSSC helium backfill pressure is ------NOTE------

within limit. SR 3.0.2 is not applicable.

Within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after verifying SSSC cavity vacuum drying pressure is within limit AND Within every 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> thereafter until LCO 3.1.3 is met North Anna ISFSI 3.1.2-2 Renewed License February 6, 2018

SSSC Combined Helium Leak Rate 3.1.3 3.1 SSSC INTEGRITY 3.1.3 SSSC Combined Helium Leak Rate LCO 3.1.3 The SSSC combined helium leak rate for all closure seals and overpressure system shall not exceed the limit specified in Table 3-1 for the applicable SSSC design.

APPLICABILITY: During LOADING OPERATIONS.

ACTIONS NOTE Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SSSC helium leak rate A.1 Establish SSSC helium 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> limit not met. leak rate within limit.

B. Required Action and B.1 Remove all fuel 30 days Associated Completion assemblies from the Time not met. SSSC.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Verify SSSC combined helium leak rate is ------NOTE------

within limit. SR 3.0.2 is not applicable.

In accordance with Table 3-1, SSSC Model-Dependent Limits North Anna ISFSI 3.1.3-1 Renewed License February 6, 2018

SSSC Interseal Pressure 3.1.4 3.1 SSSC INTEGRITY 3.1.4 SSSC Interseal Pressure LCO 3.1.4 The SSSC interseal pressure shall be maintained as specified in Table 3-1.

APPLICABILITY: During STORAGE OPERATIONS.

ACTIONS NOTE Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SSSC interseal A.1 Restore SSSC interseal 7 days pressure not pressure.

maintained.

B. Required Action and B.1 Remove all fuel 30 days Associated Completion assemblies from the Time not met. SSSC.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify SSSC interseal pressure above limit 7 days specified in Table 3-1.

SR 3.1.4.2 Verify proper functioning of SSSC pressure 36 months monitoring device.

North Anna ISFSI 3.1.4-1 Renewed License February 6, 2018

SSSC Maximum Lifting Height 3.1.5 3.1 SSSC INTEGRITY 3.1.5 SSSC Maximum Lifting Height LCO 3.1.5 The SSSC lifting height shall not exceed the limit in Table 3-1.

APPLICABILITY: During TRANSPORT OPERATIONS.

ACTIONS NOTE Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SSSC lifting height A.1 Initiate action to Immediately higher than limit. restore SSSC lifting height within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify SSSC lifting height within limit. Prior to movement of SSSC with transporter North Anna ISFSI 3.1.5-1 Renewed License February 6, 2018

Dissolved Boron Concentration 3.2.1 3.2 SSSC CRITICALITY CONTROL 3.2.1 Dissolved Boron Concentration LCO 3.2.1 The dissolved boron concentration of the spent fuel pool and of the water added to the cavity of an SSSC shall be within limits specified in Table 3-1.

APPLICABILITY: During LOADING OPERATIONS, During UNLOADING OPERATIONS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Dissolved boron A.1 Suspend loading of Immediately concentration limit fuel assemblies into not met. SSSC.

AND A.2 Remove all fuel 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> assemblies from SSSC.

North Anna ISFSI 3.2.1-1 Renewed License February 6, 2018

Dissolved Boron Concentration 3.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify dissolved boron concentration limit Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in spent fuel pool water and water to be prior to added to the SSSC cavity is met using two commencing independent measurements. LOADING OPERATIONS AND 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> thereafter while the SSSC is in the spent fuel pool.

SR 3.2.1.2 Verify dissolved boron concentration limit Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in spent fuel pool water and water to be prior to added to the SSSC cavity is met using two flooding SSSC independent measurements. during UNLOADING OPERATIONS AND 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> thereafter while the SSSC is in the spent fuel pool.

North Anna ISFSI 3.2.1-2 Renewed License February 6, 2018

SSSC Average Surface Dose Rates for TN-32 Casks 3.3.1 3.3 SSSC RADIATION PROTECTION 3.3.1 SSSC Average Surface Dose Rates for TN-32 Casks LCO 3.3.1 The average surface dose rates of each SSSC shall not exceed:

b. 218 mrem/hour (neutron + gamma) on the side; and

b. 58 mrem/hour (neutron + gamma) on the top.

APPLICABILITY: During LOADING OPERATIONS.

ACTIONS NOTE Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SSSC average surface A.1 Administratively 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> dose rate limits not verify correct fuel met. loading.

AND A.2 Perform analysis to Prior to verify compliance with TRANSPORT the ISFSI offsite OPERATIONS radiation protection requirements of 10 CFR Part 20 and 10 CFR Part 72.

B. Required Action and B.1 Remove all fuel 7 days Associated Completion assemblies from the Time not met. SSSC.

North Anna ISFSI 3.3.1-1 Renewed License February 6, 2018

SSSC Average Surface Dose Rates for TN-32 Casks 3.3.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.1 Verify average surface dose rates of SSSC Prior to containing fuel assemblies are within TRANSPORT limits. OPERATIONS North Anna ISFSI 3.3.1-2 Renewed License February 6, 2018

SSSC Average Surface Dose Rates for TN-32B HBU Cask 3.3.2 3.3 SSSC RADIATION PROTECTION 3.3.2 SSSC Average Surface Dose Rates for TN-32B HBU Cask LCO 3.3.2 The average surface dose rates of each SSSC shall not exceed:

a. 218 mrem/hour (neutron + gamma) on the side; and

b. 96.1 mrem/hour (neutron + gamma) on the top.

APPLICABILITY: During LOADING OPERATIONS.

ACTIONS NOTE Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SSSC average surface A.1 Administratively 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> dose rate limits not verify correct fuel met. loading.

AND A.2 Perform analysis to Prior to verify compliance with TRANSPORT the ISFSI offsite OPERATIONS radiation protection requirements of 10 CFR Part 20 and 10 CFR Part 72.

B. Required Action and B.1 Remove all fuel 7 days Associated Completion assemblies from the Time not met. SSSC.

North Anna ISFSI 3.3.2-1 Renewed License February 6, 2018

SSSC Average Surface Dose Rates for TN-32B HBU Cask 3.3.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.2.1 Verify average surface dose rates of SSSC Prior to containing fuel assemblies are within TRANSPORT limits. OPERATIONS North Anna ISFSI 3.3.2-2 Renewed License February 6, 2018

SSSC Surface Contamination 3.3.3 3.3 SSSC RADIATION PROTECTION 3.3.3 SSSC Surface Contamination LCO 3.3.3 Removable contamination on the SSSC exterior surfaces shall not exceed:

a. 1000 dpm/100 cm2 from beta and gamma sources; and

b. 20 dpm/100 cm2 from alpha sources.

APPLICABILITY: During LOADING OPERATIONS.

ACTIONS NOTE Separate Condition entry is allowed for each SSSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SSSC removable surface A.1 Restore SSSC removable Prior to contamination limits surface contamination TRANSPORT not met. to within limits. OPERATIONS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.1 Verify that the removable contamination on Prior to exterior surfaces of SSSC containing fuel TRANSPORT assemblies is within limits. OPERATIONS North Anna ISFSI 3.3.3-1 Renewed License February 6, 2018

SSSC Model-Dependent Limits Table 3-1 Table 3-1 (page 1 of 1)

SSSC Model-Dependent Limits SSSC MODEL LIMITS

1. TN-32

a. Cavity Vacuum Drying Pressure < 4 mbar held for 30 minutes

b. Helium Backfill Pressure 2230 mbar + 100 mbar

c. Combined Helium Leak Rate < 1.0 X 10-5 mbar-liter/sec

d. SSSC Inter-seal Pressure > 3250 mbar

e. Dissolved Boron Concentration > 2500 ppm

f. Maximum Lifting Height eighteen inches

g. Low Pressure Alarm Setting of > 3250 mbar absolute SSSC Inter-Seal Pressure Monitoring Device

h. Frequency to Verify 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Surveillance Requirement 3.1.3.1 is Within Limit

2. TN-32B HBU

a. Cavity Vacuum Drying Pressure < 4 mbar held for 30 minutes

b. Helium Backfill Pressure 2230 mbar + 100 mbar

c. Combined Helium Leak Rate < 1.0 X 10-5 mbar-liter/sec

d. SSSC Inter-seal Pressure > 3250 mbar

e. Dissolved Boron Concentration > 2500 ppm

f. Maximum Lifting Height eighteen inches

g. Low Pressure Alarm Setting of > 3250 mbar absolute SSSC Inter-Seal Pressure Monitoring Device

h. Frequency to Verify 23 days Surveillance Requirement 3.1.3.1 is Within Limit North Anna ISFSI 3.4-1 Renewed License February 6, 2018

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site 4.1.1 Site Location The North Anna ISFSI is located approximately 2000 feet southwest of the North Anna Power Station Units 1 and 2 protected area and within the boundaries of the North Anna site. The North Anna site is located in the north-central portion of Virginia in Louisa County and is approximately 40 miles north-northwest of Richmond, 36 miles east of Charlottesville; 22 miles southwest of Fredericksburg; and 70 miles southwest of Washington, D.C. The site is on a peninsula on the southern shore of Lake Anna at the end of State Route 700.

4.2 Storage Features 4.2.1 Storage Cask The North Anna ISFSI is licensed to store spent fuel in the TN-32 dry storage cask and a single TN-32B HBU Dry Storage Cask.

4.2.2 Storage Capacity The total storage capacity of the North Anna ISFSI is limited to 839.04 metric tons uranium.

4.2.3 Storage Pad The North Anna ISFSI storage pad is reinforced concrete, with nominal dimensions of 224 feet x 32 feet x 2 feet thick with a 40-foot ramp on each end for vehicle access. The pad is designed to store 28 SSSCs arranged in two rows. The SSSCs in each row will be spaced a minimum of 14 feet apart center to center. Each row of SSSCs will be spaced a minimum of 14 feet apart center to center. For SSSCs whose heat load exceeds 27.1 KW the spacing shall be a minimum of 16 feet apart center to center. The facility will have up to three storage pads.

4.2.4 Criticality The boron content of the SSSC basket poison material shall have a minimum areal density of 10 mg boron-10/cm2. Fabrication testing to ensure the minimum areal density of the basket poison material is met is outlined in the North Anna ISFSI FSAR.

North Anna ISFSI 4.0-1 Renewed License February 6, 2018

Design Features 4.0 4.0 DESIGN FEATURES 4.2 Storage Features (continued) 4.2.5 Helium Purity The SSSC shall be filled with helium with a purity of at least 99.99%

4.2.6 Special Requirements for TN Thermal Testing Each contractor authorized by the licensee to complete final assembly of the TN-32 SSSC body shall verify the heat transfer performance of a single SSSC. This test shall be performed prior to the first loading of any SSSC assembled by that contractor with a heat load greater than 27.1 kilowatts. A letter report summarizing the test performed, measured temperature data, and the calculated results of the test shall be submitted to the NRC in accordance with 10 CFR 72.4 at least 30 days prior to the use of a SSSC loaded with a heat load greater than 27.1 kilowatts.

Proposed modifications to the fabrication process shall be evaluated for their potential to impact the heat transfer performance of the SSSC body. If the modification could result in adverse impact to the heat transfer performance of the SSSC body, the heat transfer performance of the modified SSSC shall be verified by an additional thermal test, prior to loading the first modified SSSC with a heat load greater than 27.1 kilowatts.

The results of additional thermal tests shall be retained in accordance with 10 CFR 72.80.

North Anna ISFSI 4.0-2 Renewed License February 6, 2018

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall ISFSI operation and shall delegate in writing the succession to this responsibility during his absence.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affects nuclear safety.

North Anna ISFSI 5.1-1 Renewed License February 6, 2018

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for facility operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the ISFSI.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the Quality Assurance Program.

The plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be maintained in appropriate administrative documents;

b. The plant manager shall be responsible for overall safe operation of the facility and shall have control over those onsite activities necessary for safe operation and maintenance of the facility;

c. The responsible corporate executive shall have corporate responsibility for overall facility nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the facility to ensure nuclear safety; and

d. The individuals who train the operating staff, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.

North Anna ISFSI 5.2-1 Renewed License February 6, 2018

Facility Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications 5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications as specified in the Quality Assurance Program.

North Anna ISFSI 5.3-1 Renewed License February 6, 2018

Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities:

a. Administrative controls;

b. Routine ISFSI operations;

c. Alarm and annunciator response;

d. Emergency operations;

e. Design control and facility change or modification;

f. Control of surveillances and tests;

g. Control of special processes;

h. Maintenance;

i. Health physics, including ALARA practices;

j. Special nuclear material accountability;

k. Quality assurance, inspection, and audits;

l. Physical security and safeguards;

m. Records management;

n. Reporting; and

o. All programs specified in Specification 5.5.

The above procedures may be common with the North Anna Power Station procedures provided that all ISFSI requirements are met.

North Anna ISFSI 5.4-1 Renewed License February 6, 2018

Programs 5.5 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs The following programs shall be established, implemented, and maintained.

5.5.1 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not involve either of the following:

1. A change in the TS incorporated in the license; or

2. A change to the SAR or Bases that involves an unreviewed safety question, a significant increase in occupational exposure, or a significant unreviewed environmental impact as defined in 10 CFR 72.48.

c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the SAR.

d. Proposed changes that meet the criteria of 5.5.1.b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 72.48(b)(2).

North Anna ISFSI 5.5-1 Renewed License February 6, 2018

Programs 5.5 5.5 Programs 5.5.2 Radioactive Effluent Control Program This program implements the requirements of 10 CFR 72.44(d).

a. The North Anna ISFSI does not create any radioactive materials or have any radioactive waste treatment systems. Therefore, specific operating procedures for the control of radioactive effluents are not required. Specifications 3.1.3, SSSC Helium Leak Rate, and 3.1.4, SSSC Seal Integrity, provide assurance that there are essentially no radioactive effluents from the ISFSI.

b. This program includes an environmental monitoring program. The North Anna ISFSI may be included in the environmental monitoring program for North Anna Power Station.

c. An annual report shall be submitted pursuant to 10 CFR 72.44(d)(3) specifying the quantity of each of the principal radionuclides released to the environment in liquid and in gaseous effluents during the previous calendar year of operation. A schedule exemption for submitting this report by May 1 of each year was granted in the license.

North Anna ISFSI 5.5-2 Renewed License February 6, 2018