ML18124A169

From kanterella
Jump to navigation Jump to search
Tn Americas, LLC - Enclosure 7, Assess TS-Tbls and Figs
ML18124A169
Person / Time
Site: 07201004
Issue date: 04/26/2018
From:
TN Americas LLC
To:
Office of Nuclear Material Safety and Safeguards
References
E-51306
Download: ML18124A169 (48)


Text

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 1 of 48 CoC Condition/TS Identifier:

(Form #77) Revision 4 TS Table 1-1a, PWR Fuel Specifications for Fuel to be Stored in the Standardized NUHOMS-24P DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Table 1-1a, PWR Fuel Specifications for Fuel to be Stored in the Standardized NUHOMS-24P DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 The following items in Table 1-1a are required per Criterion A1 and shall be retained:

Fuel (type of spent fuel)

Number of assemblies per DSC (condition of spent fuel)

Maximum planar average initial fuel enrichment Assembly average burnup Decay heat (maximum heat designed to be dissipated)

Fuel cladding (type of spent fuel)

Maximum assembly and BPRA weight (type of spent fuel)

A2 The following items in Table 1-1a are required per Criterion A2 and shall be retained:

Neutron fuel source (shielding function)

Gamma source (shielding function)

BPRA Cooling time - Minimum (shielding function)

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 2 of 48 Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes (for A1 and A2 items)

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes (for A1 and A2 items)

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes (for A1 and A2 items)

Evaluation Summary The A1 and A2 items to be maintained are summarized above.

The fuel qualification tables (Table 1-2a, Table 1-2c) will be deleted from the Technical Specifications and placed in the UFSAR, although key parameters (e.g., minimum fuel assembly cooling time, maximum burnup) will be retained as global parameters in the fuel specification table. An exhaustive fuel qualification is performed to determine bounding source terms as documented in the UFSAR. Fuel assembly decay heat is determined by the Licensee, transfer cask dose rates are verified at loading, and HSM dose rates are verified by a one-time measurement as a part of the CoC Appendix A ITE.

The following characteristics have been removed from the Technical Specifications but remain in the UFSAR Table 3.1-1:

Maximum assembly and BPRA length Nominal Cross-Sectional Envelope To avoid duplication, items currently in Table 3.1-1 that remain in the Technical Specifications are deleted from Table 3.1-1 with a reference added to the Technical Specifications.

If the Licensee has fuel that does not meet the maximum assembly length limits or cross-sectional envelope, acceptability will be determined per 10 CFR 72.48.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 3 of 48 CoC Condition/TS Identifier:

(Form #78) Revision 4 TS Table 1-1b, BWR Fuel Specifications for Fuel to be Stored in the Standardized NUHOMS-52B DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Table 1-1b, BWR Fuel Specifications for Fuel to be Stored in the Standardized NUHOMS-52B DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 The following items in Table 1-1b are required per Criterion A1 and shall be retained:

Fuel (type of spent fuel)

Number of assemblies per DSC (condition of spent fuel)

Maximum lattice average initial fuel enrichment Assembly average burnup Decay heat (maximum heat designed to be dissipated)

Fuel cladding (type of spent fuel)

Maximum assembly weight (type of spent fuel)

A2 The following items in Table 1-1b are required per Criterion A2 and shall be retained:

Neutron source (shielding function)

Gamma source (shielding function)

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 4 of 48 Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes (for A1 and A2 items)

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes (for A1 and A2 items)

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes (for A1 and A2 items)

Evaluation Summary The A1 and A2 items to be maintained are summarized above.

The fuel qualification table (Table 1-2b) will be deleted from the Technical Specifications and placed in the UFSAR, although key parameters (e.g., minimum fuel assembly cooling time, maximum burnup) will be retained as global parameters in the fuel specification table. An exhaustive fuel qualification is performed to determine bounding source terms as documented in the UFSAR. Fuel assembly decay heat is determined by the Licensee, transfer cask dose rates are verified at loading, and HSM dose rates are verified by a one-time measurement as a part of the CoC Appendix A ITE.

The following characteristics have been removed from the Technical Specifications but remain in the UFSAR Table 3.1-2:

Maximum assembly length Nominal Cross-Sectional Envelope To avoid duplication, items currently in Table 3.1-2 that remain in the Technical Specifications are deleted from Table 3.1-2 with a reference added to the Technical Specifications.

If the Licensee has fuel that does not meet the maximum assembly length limits or cross-sectional envelope, acceptability will be determined per 10 CFR 72.48.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 5 of 48 CoC Condition/TS Identifier:

(Form #79) Revision 4 TS Table 1-1c, BWR Fuel Specification for Fuel to be Stored in the Standardized NUHOMS-61BT DSC TS Table 1-1j, BWR Fuel Specification for Damaged Fuel to be Stored in the Standardized NUHOMS-61BT DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Table 1-1c and Table 1-1j, BWR Fuel Specifications for Fuel (Intact and Damaged) to be Stored in the Standardized NUHOMS -61BT DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 The following items in Table 1-1c and Table 1-1j are required per Criterion A1 and shall be retained:

Fuel design (type of spent fuel)

Fuel damage (condition of the spent fuel)

Channels (type of spent fuel)

Maximum burnup by group Minimum cooling time by group Maximum lattice average initial enrichment Minimum initial assembly average enrichment Maximum decay heat Fuel cladding (type of spent fuel)

Maximum assembly weight (type of spent fuel)

A2 The following item in Table 1-1c is required per Criterion A2 and shall be retained:

Minimum B-10 content in poison plates (criticality function)

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 6 of 48 Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes (for A1 and A2 items)

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes (for A1 and A2 items)

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes (for A1 and A2 items)

Evaluation Summary The A1 and A2 items to be maintained are summarized above.

The fuel qualification table (Table 1-2q) will be deleted from the Technical Specifications and placed in the UFSAR, although key parameters (e.g., minimum fuel assembly cooling time, maximum burnup) will be retained as global parameters in the fuel specification table. An exhaustive fuel qualification is performed to determine bounding source terms as documented in the UFSAR. Fuel assembly decay heat is determined by the Licensee, transfer cask dose rates are verified at loading, and HSM dose rates are verified by a one-time measurement as a part of the CoC Appendix A ITE.

The following characteristics have been removed from the Technical Specifications but remain in the UFSAR Tables K.2-1 and K.2-2:

Maximum assembly length Maximum assembly width (excluding channels)

Maximum initial uranium content To avoid duplication, items currently in Tables K.2-1 and K.2-2 that remain in the Technical Specifications are deleted from Tables K.2-1 and K.2-2 with a reference added to the Technical Specifications.

If the Licensee has fuel that does not meet the maximum uranium content or dimensional requirements, acceptability will be determined per 10 CFR 72.48.

NOTE: The cooling time for group 3 is correct based on a review of historical documentation.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 7 of 48 CoC Condition/TS Identifier:

(Form #80) Revision 4 TS Table 1-1d, BWR Fuel Assembly Design Characteristics for the NUHOMS -61BT DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Table 1-1d, BWR Fuel Assembly Design Characteristics for the NUHOMS -61BT DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 8 of 48 Evaluation Summary Table 1-1d has been deleted from the Technical Specifications. This information is in the SAR as Table K.2-3 and contains the following parameters:

GE Designations (e.g., GE1, GE2, GE3)

Maximum unirradiated length Nominal width (excluding channels)

Fissile material type Number of fuel rods Number of water holes If the Licensee has fuel that does not meet the conditions listed above, acceptability will be determined per 10 CFR 72.48.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 9 of 48 CoC Condition/TS Identifier:

(Form #81) Revision 4 TS Table 1-1e, PWR Fuel Specifications for Fuel to be Stored in the NUHOMS-32PT DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Table 1-1e, PWR Fuel Specifications for Fuel to be Stored in the NUHOMS-32PT DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 The following items in Table 1-1e are required per Criterion A1 and shall be retained:

Fuel assembly class (type of spent fuel)

Reconstituted fuel assemblies (condition of the spent fuel)

Fuel damage (condition of the spent fuel)

Failed fuel (condition of spent fuel)

Control Components (type of spent fuel)

Number of intact assemblies (condition of spent fuel)

Number and location of damaged assemblies (condition of spent fuel)

Number and location of failed assemblies (condition of spent fuel)

Maximum planar average enrichment Allowable heat load zoning configurations (maximum heat designed to be dissipated)

Maximum assembly plus CC weight (type of spent fuel)

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 10 of 48 Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes (for A1 items)

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes (for A1 items)

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes (for A1 items)

Evaluation Summary The A1 items to be maintained are summarized above.

The fuel qualification tables will be deleted from the Technical Specifications and placed in the UFSAR, although key parameters (e.g., minimum fuel assembly cooling time, maximum burnup) will be retained as global parameters in the fuel specification table. An exhaustive fuel qualification is performed to determine bounding source terms as documented in the UFSAR. Fuel assembly decay heat is determined by the Licensee, transfer cask dose rates are verified at loading, and HSM dose rates are verified by a one-time measurement as a part of the CoC Appendix A ITE.

In Amendment 15 (currently under NRC review), the fuel qualification tables (FQTs) for the 24PTH, 32PT, 32PTH1, and 37PTH DSC were consolidated into a single set of FQTs based solely on heat load and are applicable to all four systems. These FQTs are documented in Section M.5.2.6 of the FSAR. Design basis sources were developed for each system based on the bounding heat load zone configuration, and the FSAR dose rates were updated as needed. For example, for the 24PTH DSC, the updated source terms are documented in Section P.5.2.6 of the FSAR.

Details and instructions to Licensees for performing Fuel Qualification for burnup/enrichment combinations not considered in the UFSAR will be included in the BASES.

The notes associated with the FQTs will be included in the instructions to Licensees, as needed.

Lastly, reference to thermal characteristics in Table 1-1ee, in the "Control Components (CCs) row of this table, is deleted since those characteristics are being moved from Table 1-1ee to the FSAR.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 11 of 48 CoC Condition/TS Identifier:

(Form #82) Revision 4 TS Table 1-1f, PWR Fuel Assembly Design Characteristics for the NUHOMS-32PT DSC TS Table 1-1m, PWR Fuel Assembly Design Characteristics for the NUHOMS-24PTH DSC TS Table 1-1bb, PWR Fuel Assembly Design Characteristics for the NUHOMS-32PTH1 DSC TS Table 1-1nn, PWR Fuel Assembly Design Characteristics for the 37PTH DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Tables for PWR Fuel Assembly Design Characteristics for NUHOMS DSCs CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No (except for 24PTH-S-LC content restriction)

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 12 of 48 Evaluation Summary The information in these tables have been moved from the Technical Specifications to the UFSAR:

32PT, 24PTH, and 32PTH1:

Maximum unirradiated assembly + CC length Fissile material type Maximum uranium content (MTU/assembly)

Maximum number of fuel rods 37PTH:

Maximum unirradiated length Maximum number of fuel rods The associated UFSAR tables are Table M.2-2 (32PT),

Table P.2-3 (24PTH), Table U.2-3 (32PTH1), and Table Z.2-3 (37PTH).

If the Licensee has fuel that does not meet the conditions in the applicable table, acceptability will be determined per 10 CFR 72.48.

Table 1-1m, footnote 3, restricting the 24PTH-S-LC to B&W 15x15 fuel will be placed in Section 2, Approved Content.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 13 of 48 CoC Condition/TS Identifier:

(Form #83) Revision 0 TS Table 1-1g, Table 1-1g1, Table 1-1g2 and Table 1-1g3, Maximum Planar Average Enrichment, Number of PRAs and Minimum Soluble Boron Loading for the NUHOMS-32PT DSC TS Table 1-1p, Table 1-1q and Table 1-1q1, Maximum Planar Average Initial Enrichment v/s Neutron Poison Requirements for the NUHOMS-24PTH DSC TS Table 1-1v through 1-1x, Maximum Fuel Assembly Lattice Average Enrichment v/s Minimum B-10 Requirements for the 61BTH DSC TS Table 1-1cc, Table 1-1dd, and Table 1-1dd1, Maximum Planar Average Initial Enrichment v/s Neutron Poison Requirements for 32PTH1 DSC TS Table 1-1jj and 1-1kk, BWR Fuel Assembly Lattice Average Initial Enrichment vs Minimum B-10 Requirements for the NUHOMS -69BTH DSC Poison Plates (Intact and Damaged Fuel)

TS Table 1-1oo and Table 1-1pp, Maximum Planar Average Enrichment for the 37PTH DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Tables for

  • Maximum Planar Average Enrichment, Number of PRAs and Minimum Soluble Boron Loading, or
  • Maximum Planar Average Initial Enrichment v/s Neutron Poison Requirements, or
  • Maximum Fuel Assembly Lattice Average Enrichment v/s Minimum B-10 Requirements, or
  • Lattice Average Initial Enrichment vs Minimum B-10 Requirements, or
  • Maximum Planar Average Enrichment for NUHOMS DSCs CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance L1 No L2 No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 14 of 48 Requirements (SRs)

(Selection Criteria)

L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes Evaluation Summary All of these fuel assembly parameters are required per Criterion A1 and shall be retained.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 15 of 48 CoC Condition/TS Identifier:

(Form #84) Revision 0 TS Table 1-1h, Specification for the NUHOMS-32PT Poison Plates and PRAs TS Table 1-1k, B10 Specification for the NUHOMS-61BT Poison Plates TS Table 1-1r, B10 Specification for the NUHOMS-24PTH Poison Plates TS Table 1-1ff, B10 Specification for the NUHOMS-32PTH1 Poison Plates TS Table 1-1rr, B10 Specification for the NUHOMS-37PTH Poison Plates TS Table 1-1ss, B-10 Specification for the NUHOMS-37PTH PRAs

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Tables for Specification for the NUHOMS DSC Poison Plates and/or PRAs CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 Yes The B-10 areal density and/or the number of PRAs in each DSC are key parameters required to provide reasonable assurance that the cask safety function of sub-criticality will be maintained.

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 16 of 48 The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes The margin of safety would be reduced or eliminated if the B-10 areal density were reduced lower than the minimum requirements used in the criticality analyses.

Evaluation Summary The B-10 areal density and the number of PRAs in each DSC are required per Criterion A2 and shall be retained.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 17 of 48 CoC Condition/TS Identifier:

(Form #85) Revision 4 TS Table 1-1i, PWR Fuel Specifications for Fuel to be Stored in the Standardized NUHOMS-24PHB DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Table 1-1i, PWR Fuel Specifications for Fuel to be Stored in the Standardized NUHOMS-24PHB DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 The following items in Table 1-1i are required per Criterion A1 and shall be retained:

Fuel class (type of spent fuel)

Maximum Number of Irradiated Stainless Steel Rods in Reconstituted Assemblies per DSC (type and condition of the spent fuel)

Maximum Number of Irradiated Stainless Steel Rods per Reconstituted Assembly (type and condition of the spent fuel)

Maximum Number of Reconstituted Assemblies per DSC with Low Enriched Uranium Oxide Rods (type and condition of the spent fuel)

Fuel damage (condition of the spent fuel)

Control Components (type of spent fuel)

Number of intact assemblies (condition of spent fuel)

Number and location of damaged assemblies (condition of spent fuel)

Maximum planar average enrichment Allowable heat load zoning configurations (maximum heat designed to be dissipated)

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 18 of 48 Total Decay heat per DSC (maximum heat designed to be dissipated)

Decay heat Limits by zone (maximum heat designed to be dissipated)

Fuel cladding (type of spent fuel)

Maximum assembly plus CC weight (type of spent fuel)

A2 The following items in Table 1-1i are required per Criterion A2 and shall be retained:

  • Minimum boron loading (criticality function)
  • Minimum Cooling Time for CCs (shielding function)

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes (for A1 and A2 items)

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes (for A1 and A2 items)

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes (for A1 and A2 items)

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 19 of 48 Evaluation Summary The A1 and A2 items to be maintained are summarized above.

The fuel qualification tables (Table 1-2n, Table 1-2o, Table 1-2p) will be deleted from the Technical Specifications, although key parameters (e.g., minimum fuel assembly cooling time, maximum burnup) will be retained as global parameters in the fuel specification table. An exhaustive fuel qualification is performed to determine bounding source terms as documented in the UFSAR. Fuel assembly decay heat is determined by the Licensee, transfer cask dose rates are verified at loading, and HSM dose rates are verified by a one-time measurement as a part of the CoC Appendix A ITE.

The following characteristics have been moved from the Technical Specifications to the UFSAR Table N.2-1:

Maximum Assembly Length (with and without CCs)

Nominal Cross-Sectional Envelope Maximum Initial Uranium Loading per assembly To avoid duplication, parameters listed in Table N.2-1 that remain in the Technical Specifications are cross referenced to the Technical Specifications.

If the Licensee has fuel that does not meet the maximum assembly length or uranium loading limits, acceptability will be determined per 10 CFR 72.48.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 20 of 48 CoC Condition/TS Identifier:

(Form #86) Revision 4 TS Table 1-1l, PWR Fuel Specifications for the Fuel to be Stored in the NUHOMS-24PTH DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Table 1-1l, PWR Fuel Specifications for the Fuel to be Stored in the NUHOMS-24PTH DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 The following items in Table 1-1l are required per Criterion A1 and shall be retained:

Fuel class (type of spent fuel)

Fuel damage (condition of the spent fuel)

Failed fuel (condition of the spent fuel)

Partial Length Shield Assembles - maximum burnup and decay heat and minimum cooling time (type of spent fuel)

Maximum Number of Irradiated Stainless Steel Rods in Reconstituted Assemblies per DSC (type and condition of the spent fuel)

Maximum Number of Irradiated Stainless Steel Rods per Reconstituted Assembly (type and condition of the spent fuel)

Maximum Number of Reconstituted Assemblies per DSC with Unlimited Number of Low Enriched UO2 Rods and/or Unirradiated Stainless Steel Rods and/or Zr Rods or Zr Pellets (type and condition of the spent fuel)

Control Components (type of spent fuel)

Number of intact assemblies (condition of spent fuel)

Number and location of damaged assemblies (condition of spent fuel)

Number and location of failed assemblies (condition of spent fuel)

Allowable heat load zoning configurations (maximum heat designed to be dissipated)

Maximum planar average enrichment Decay heat (maximum heat designed to be dissipated)

Maximum fuel assembly weight (type of spent fuel)

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 21 of 48 A2 The following items in Table 1-1l are required per Criterion A2 and shall be retained:

  • Minimum boron loading (criticality function)

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes (for A1 and A2 items)

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes (for A1 and A2 items)

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes (for A1 and A2 items)

Evaluation Summary The A1 and A2 items to be maintained are summarized above.

The fuel qualification tables will be deleted from the Technical Specifications and placed in the UFSAR, although key parameters (e.g., minimum fuel assembly cooling time, maximum burnup, minimum assembly average enrichment) will be retained as global parameters, which will appear in the respective fuel specification table. An exhaustive fuel qualification is performed to determine bounding source terms, as documented in the UFSAR. Fuel assembly decay heat is determined by the Licensee, transfer cask dose rates are verified at loading, and HSM dose rates are verified by a one-time measurement as a part of the CoC Appendix A ITE.

In Amendment 15 (currently under NRC review), the fuel qualification tables (FQTs) for the 24PTH, 32PT, 32PTH1, and 37PTH DSC were consolidated into a single set of FQTs based solely on heat load and are applicable to all four systems.

These FQTs are documented in Section M.5.2.6 of the FSAR.

Design basis sources were developed for each system based on the bounding heat load zone configuration, and the FSAR dose rates were updated as needed. For example, for the 24PTH DSC, the updated source terms are documented in Section P.5.2.6 of the FSAR.

Details and instructions to Licensees for performing Fuel Qualification for burnup/enrichment combinations not considered in the UFSAR will be included in the BASES. The notes associated with the FQTs will be included in the

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 22 of 48 instructions to Licensees, as needed.

The following characteristic have been moved from the Technical Specifications to the UFSAR Table P.2-1:

Nominal Assembly Width for Intact and Damaged Fuel Only To avoid duplication, parameters listed in Table P.2-1 that remain in the Technical Specifications are cross referenced to the Technical Specifications.

If the Licensee has fuel that does not meet the nominal assembly width, acceptability will be determined per 10 CFR 72.48.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 23 of 48 CoC Condition/TS Identifier:

(Form #87) Revision 4 TS Table 1-1n, Thermal and Radiological Characteristics for Control Components Stored in the NUHOMS-24PTH DSC and 24PHB DSCs TS Table 1-1ee, Thermal and Radiological Characteristics for Control Components Stored in the NUHOMS-32PT and NUHOMS-32PTH1 DSCs TS Table 1-1qq, Characteristics of Control Components for the 37PTH DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Tables for Thermal and Radiological Characteristics for Control Components Stored in the NUHOMS DSCs CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 Yes The following item is required per Criterion A2 and shall be retained:

  • Maximum gamma source (shielding function)

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes (for A2 item)

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 24 of 48 The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes (for A2 item)

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes (for A2 item)

Evaluation Summary The control component maximum gamma source is required per Criterion A2 (shielding function) and shall be retained.

The control component decay heat is low compared to the fuel and shall be deleted from each table. This approach is also consistent with deleting the fuel qualification tables from the technical specifications.

This information has been moved to the UFSAR in the following tables: Table P.2-2 (24PTH), Table N.2-2a (24PHB), Table M.2-2a (32PT), Table U.2-2 (32PTH1), and Table Z.2-2 (37PTH).

To avoid duplication, parameters listed in the UFSAR tables that remain in the Technical Specifications are cross referenced to the Technical Specifications.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 25 of 48 CoC Condition/TS Identifier:

(Form #88) Revision 4 TS Table 1-1t, BWR Fuel Specification for the 61BTH DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Table 1-1t, BWR Fuel Specification for the 61BTH DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 The following items in Table 1-1t are required per Criterion A1 and shall be retained:

Fuel class (type of spent fuel)

Fuel damage (condition of the spent fuel)

Failed fuel (condition of the spent fuel)

Requirements for reconstituted fuel (type of spent fuel)

Number of intact assemblies (condition of spent fuel)

Number and location of damaged and failed fuel assemblies (condition of spent fuel)

Channels (type of spent fuel)

Heat load zoning requirements (maximum heat designed to be dissipated)

Maximum lattice average initial enrichment Maximum pellet enrichment Decay heat per canister (maximum heat designed to be dissipated)

Maximum assembly weight (type of spent fuel)

A2 The following item in Table 1-1t is required per Criterion A2 and shall be retained:

Minimum B-10 content in poison plates (criticality function)

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 26 of 48 Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes (for A1 and A2 items)

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes (for A1 and A2 items)

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes (for A1 and A2 items)

Evaluation Summary The A1 and A2 items to be maintained are summarized above.

The fuel qualification tables will be deleted from the Technical Specifications and placed in the UFSAR, although key parameters (e.g., minimum fuel assembly cooling time, maximum burnup) will be retained as global parameters in the fuel specification table. An exhaustive fuel qualification is performed to determine bounding source terms as documented in the UFSAR. Fuel assembly decay heat is determined by the Licensee, transfer cask dose rates are verified at loading, and HSM dose rates are verified by a one-time measurement as a part of the CoC Appendix A ITE.

The following characteristic will be moved from the Technical Specifications to the UFSAR Table T.2-1:

Maximum uranium content To avoid duplication, parameters listed in the UFSAR Table T.2-1 that remain in the Technical Specifications are cross referenced to the Technical Specifications.

If the Licensee has fuel that does not meet the maximum uranium content limit, acceptability will be determined per 10 CFR 72.48.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 27 of 48 CoC Condition/TS Identifier:

(Form #89) Revision 4 TS Table 1-1u, BWR Fuel Assembly Design Characteristics for the 61BTH DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Table 1-1u, BWR Fuel Assembly Design Characteristics for the 61BTH DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 28 of 48 Evaluation Summary Table 1-1u has been removed from the Technical Specifications. This information is provided in the UFSAR Table T.2-2:

Detailed Fuel Design (e.g., GE1, GE2, GE3)

Maximum unirradiated length Fissile material type Maximum number of fuel rods If the Licensee has fuel that does not meet the conditions listed above, acceptability will be determined per 10 CFR 72.48.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 29 of 48 CoC Condition/TS Identifier:

(Form #90) Revision 3 TS Table 1-1aa, PWR Fuel Specification for the Fuel to be Stored in the NUHOMS-32PTH1 DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Table 1-1aa, PWR Fuel Specification for the Fuel to be Stored in the NUHOMS-32PTH1 DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 The following items in Table 1-1aa are required per Criterion A1 and shall be retained:

Fuel class (type of spent fuel)

Reconstituted fuel assemblies (condition of the spent fuel)

Fuel damage (condition of the spent fuel)

Failed fuel (condition of spent fuel)

Control Components (type of spent fuel)

Number of intact assemblies (condition of spent fuel)

Number and location of damaged assemblies (condition of spent fuel)

Number and location of failed assemblies (condition of spent fuel)

Maximum planar average enrichment Allowable heat load zoning configurations (maximum heat designed to be dissipated)

Decay heat per DSC (maximum heat designed to be dissipated)

Maximum assembly plus CC weight (type of spent fuel)

A2 The following items in Table 1-1aa are required per Criterion A2 and shall be retained:

  • Minimum boron loading (criticality function)

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance L1 No L2 No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 30 of 48 Requirements (SRs)

(Selection Criteria)

L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes (for A1 and A2 items)

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes (for A1 and A2 items)

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes (for A1 and A2 items)

Evaluation Summary The A1 and A2 items to be maintained are summarized above.

The fuel qualification tables will be deleted from the Technical Specifications and placed in the UFSAR, although key parameters (e.g., minimum fuel assembly cooling time, maximum burnup) will be retained as global parameters in the fuel specification table. An exhaustive fuel qualification is performed to determine bounding source terms as documented in the UFSAR. Fuel assembly decay heat is determined by the Licensee, transfer cask dose rates are verified at loading, and HSM dose rates are verified by a one-time measurement as a part of the CoC Appendix A ITE.

In Amendment 15 (currently under NRC review), the fuel qualification tables (FQTs) for the 24PTH, 32PT, 32PTH1, and 37PTH DSC were consolidated into a single set of FQTs based solely on heat load and are applicable to all four systems. These FQTs are documented in Section M.5.2.6 of the FSAR. Design basis sources were developed for each system based on the bounding heat load zone configuration, and the FSAR dose rates were updated as needed. For example, for the 24PTH DSC, the updated source terms are documented in Section P.5.2.6 of the FSAR.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 31 of 48 CoC Condition/TS Identifier:

(Form #91) Revision 4 TS Table 1-1gg, BWR Fuel Specification for the Fuel to be Stored in the NUHOMS -69BTH DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Table 1-1gg, BWR Fuel Specification for the Fuel to be Stored in the NUHOMS -69BTH DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 The following items in Table 1-1gg are required per Criterion A1 and shall be retained:

Fuel class (type of spent fuel)

Fuel damage (condition of the spent fuel)

Maximum Number of irradiated stainless steel rods in reconstituted assemblies per DSC (condition of spent fuel)

Maximum Number of irradiated stainless steel rods per reconstituted fuel assembly (condition of spent fuel)

Maximum Number of reconstituted assemblies per DSC with unlimited number of low enriched UO2 rods or Zr rods or Zr pellets or unirradiated stainless steel rods (condition of spent fuel)

Number of intact assemblies (condition of spent fuel)

Number and location of damaged assemblies (condition of spent fuel)

Channels (type of spent fuel)

Allowable heat load zoning configurations

/decay heat limits (maximum heat designed to be dissipated)

Maximum lattice average initial enrichment Maximum pellet enrichment Decay heat per DSC (maximum heat designed to be dissipated)

Maximum assembly weight (including channels)

(type of spent fuel)

A2 The following item in Table 1-1gg is required per Criterion A2 and shall be retained:

Minimum B-10 concentration in poison plates (criticality function)

A3 No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 32 of 48 Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes (for A1 and A2 items)

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes (for A1 and A2 items)

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes (for A1 and A2 items)

Evaluation Summary The A1 and A2 items to be maintained are summarized above.

The fuel qualification tables will be deleted from the Technical Specifications and placed in the UFSAR, although key parameters (e.g., minimum fuel assembly cooling time, maximum burnup) will be retained as global parameters in the fuel specification table. An exhaustive fuel qualification is performed to determine bounding source terms as documented in the UFSAR. Fuel assembly decay heat is determined by the Licensee, transfer cask dose rates are verified at loading, and HSM dose rates are verified by a one-time measurement as a part of the CoC Appendix A ITE.

The following characteristics will be moved from the Technical Specifications to the UFSAR Table Y.2-1:

Fissile material type Maximum uranium content To avoid duplication, parameters listed in the UFSAR Table Y.2-1 that remain in the Technical Specifications are cross referenced to the Technical Specifications.

If the Licensee has fuel that does not meet the maximum uranium content limit, acceptability will be determined per 10 CFR 72.48.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 33 of 48 CoC Condition/TS Identifier:

(Form #92) Revision 4 TS Table 1-1ii, BWR Fuel Assembly Design Characteristics for the NUHOMS -69BTH DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Table 1-1ii, BWR Fuel Assembly Design Characteristics for the NUHOMS -69BTH DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 34 of 48 Evaluation Summary Table 1-1ii has been deleted from the Technical Specifications. This information is in the UFSAR as Table Y.2-2 and contains the following parameters:

Initial Design or Reload Fuel Designation (e.g.,

GE1, GE2, GE3)

Maximum unirradiated length If the Licensee has fuel that does not meet the conditions listed above, acceptability will be determined per 10 CFR 72.48.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 35 of 48 CoC Condition/TS Identifier:

(Form #93) Revision 4 TS Table 1-1ll, PWR Fuel Specification for the 37PTH DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Table 1-1ll, PWR Fuel Specification for the 37PTH DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 The following items in Table 1-1ll are required per Criterion A1 and shall be retained:

Fuel class (type of spent fuel)

Fuel damage (condition of the spent fuel)

Requirements for reconstituted fuel (type of spent fuel)

Number of intact assemblies (condition of spent fuel)

Number and location of damaged assemblies (condition of spent fuel)

Heat load zoning requirements (maximum heat designed to be dissipated)

Maximum planar average enrichment Decay heat per canister (maximum heat designed to be dissipated)

Maximum assembly weight (type of spent fuel)

A2 The following items in Table 1-1ll are required per Criterion A2 and shall be retained:

Control component source (shielding function)

Minimum boron loading (criticality function)

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 36 of 48 Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes (for A1 and A2 items)

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes (for A1 and A2 items)

A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes (for A1 and A2 items)

Evaluation Summary The A1 and A2 items to be maintained are summarized above.

The fuel qualification tables will be deleted from the Technical Specifications and placed in the UFSAR, although key parameters (e.g., minimum fuel assembly cooling time, maximum burnup) will be retained as global parameters in the fuel specification table. An exhaustive fuel qualification is performed to determine bounding source terms as documented in the UFSAR. Fuel assembly decay heat is determined by the Licensee, transfer cask dose rates are verified at loading, and HSM dose rates are verified by a one-time measurement as a part of the CoC Appendix A ITE.

In Amendment 15 (currently under NRC review), the fuel qualification tables (FQTs) for the 24PTH, 32PT, 32PTH1, and 37PTH DSC were consolidated into a single set of FQTs based solely on heat load and are applicable to all four systems. These FQTs are documented in Section M.5.2.6 of the FSAR. Design basis sources were developed for each system based on the bounding heat load zone configuration, and the FSAR dose rates were updated as needed. For example, for the 24PTH DSC, the updated source terms are documented in Section P.5.2.6 of the FSAR.

The following characteristics have been moved from the Technical Specifications to the UFSAR Table Z.2-1:

Fissile material type Maximum uranium content To avoid duplication, parameters listed in the UFSAR Table Z.2-1 that remain in the Technical Specifications are cross referenced to the Technical Specifications.

If the Licensee has fuel that does not meet the maximum uranium content limit, acceptability will be determined per 10 CFR 72.48.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 37 of 48 CoC Condition/TS Identifier:

(Form #94) Revision 3 TS Table 1-2a and Table 1-2c, PWR Fuel Qualification Tables for the Standardized NUHOMS -

24P DSC TS Table 1-2b, BWR Fuel Qualification Table for the Standardized NUHOMS -52B DSC TS Table 1-2n, Table 1-2o and Table 1-2p, PWR Fuel Qualification Tables for the NUHOMS-24PHB DSC TS Table 1-2q, BWR Fuel Qualification Table for NUHOMS -61BT DSC TS Table 1-3a through 1-3p, PWR Fuel Qualification Tables TS Table 1-4a through Table 1-4i, Fuel Qualification Tables for the 61BTH DSC TS Table 1-6a and Table 1-6b, Fuel Qualification Tables for BWR FAs of a NUHOMS-61BT DSC Contained in an OS197L TC TS Table 1-6c and Table 1-6d, Fuel Qualification Tables for FAs of a NUHOMS-32PT DSC Contained in an OS197L TC TS Table 1-7a through Table 1-7m, BWR Fuel Qualification Tables for the NUHOMS -69BTH DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Fuel Qualification Tables for Standardized NUHOMS DSCs CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 38 of 48 The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No A Significant reduction in the margin of safety for ISFSI or cask operation?

No Evaluation Summary The fuel qualification tables will be deleted from the Technical Specifications and placed in the UFSAR, although key parameters (e.g, minimum fuel assembly cooling time, maximum burnup) will be retained as global parameters, which will appear in the respective fuel specification table. An exhaustive fuel qualification is performed to determine bounding source terms as documented in the UFSAR. Fuel assembly decay heat is determined by the Licensee, transfer cask dose rates are verified at loading, and HSM dose rates are verified by a one-time measurement as a part of the CoC Appendix A ITE.

Details and instructions to Licensees for performing Fuel Qualification for burnup/enrichment combinations not considered in the UFSAR will be included in the BASES.

The notes associated with the FQTs will be included in the instructions to Licensees, as needed.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 39 of 48 CoC Condition/TS Identifier:

(Form #95) Revision 0 TS Figure 1-1, PWR Fuel Criticality Acceptance Curve for the 24P DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Figure 1-1, PWR Fuel Criticality Acceptance Curve for the 24P DSC CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 Yes The PWR Fuel Criticality Acceptance curve for the 24P DSC is an important figure that provides reasonable assurance that the cask safety function of sub-criticality will be maintained if the fuel initial enrichment versus assembly burnup is kept in the acceptable region.

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes The probability of a criticality event significantly increases if the initial enrichment versus fuel assembly burnup curve falls in the unacceptable region.

The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 40 of 48 A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes The margin of safety would be reduced or eliminated if a fuel assembly loaded in the 24P DSC does not fall in the acceptable region of the initial enrichment versus burnup curve.

Evaluation Summary The PWR Fuel Criticality Acceptance curve for the 24P DSC is an important figure that provides reasonable assurance that the cask safety function of sub-criticality will be maintained if the fuel initial enrichment versus assembly burnup is kept in the acceptable region. It is required per Criterion A2 and shall be retained.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 41 of 48 CoC Condition/TS Identifier:

(Form #96) Revision 0 TS Figure 1-2 through Figure 1-4a, Heat Load Zoning Configurations for the NUHOMS-32PT DSC TS Figure 1-8 and Figure 1-9, Heat Load Zoning Configuration for Fuel Assemblies Stored in the NUHOMS-24PHB DSC TS Figure 1-11 through Figure 1-15a, Heat Load Zoning Configurations for 24PTH DSCs TS Figure 1-17 through 1-24, Figure 1-25a, Figure 1-25b, Heat Load Zoning Configurations for the 61BTH DSC TS Figure 1-26 through Figure 1-28c, Heat Load Zoning Configurations for the NUHOMS-32PTH1-S, 32POTH1-M and 32PTH1-L DSCs TS Figure 1-29, Heat Load Zone Configuration for the 61BT DSC Contained in an OS197L TC TS Figure 1-30, Heat Load Zone Configuration for the 32PT DSC Contained in an OS197L TC TS Figures 1-31 through 1-36, and Figure 1-38, Heat Load Zoning Configurations for the 69BTH DSCs TS Figure 1-39 and Figure 1-40, Heat Load Zoning Configurations for the 37PTH DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Figures with Heat Load Zoning Configurations for NUHOMS DSCs CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 42 of 48 Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes Evaluation Summary The Heat Load Zone Configurations are required per Criterion A1 (maximum heat designed to be dissipated) and shall be retained.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 43 of 48 CoC Condition/TS Identifier:

(Form #97) Revision 0 TS Figure 1-4b, Location of Damaged and Failed Fuel Assemblies Inside the NUHOMS-32PT DSC TS Figure 1-16, Location of Failed or Damaged Fuel Inside 24PTH DSC TS Figure 1-25, Location of Damaged and Failed Fuel Assemblies for the 61BTH DSC TS Figure 1-37, Location of Damaged Fuel Assemblies Inside the 69BTH DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Figures for Location of Damaged and/or Failed Fuel Assemblies Inside NUHOMS DSCs CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 Yes The permitted locations of damaged and failed fuel assemblies inside DSCs is a key feature required to provide reasonable assurance that the cask safety functions of decay heat removal and shielding will be maintained.

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 44 of 48 The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes Evaluation Summary The permitted locations of damaged and failed fuel assemblies inside DSCs are required per Criterion A2 and shall be retained.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 45 of 48 CoC Condition/TS Identifier:

(Form #98) Revision 0 TS Figures 1-5, 1-6 and 1-7, Required PRA Locations for the NUHOMS-32PT DSC Configurations TS Figure 1-41 and Figure 1-42, PRA Locations for the 37PTH DSC

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Figures for Required PRA Locations for certain NUHOMS DSCs CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 No A2 Yes The required PRA locations in DSCs is a key feature required to provide reasonable assurance that the cask safety function of sub-criticality will be maintained.

A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 46 of 48 A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes Evaluation Summary The PRA locations are required per Criterion A2 (criticality function) and shall be retained.

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 47 of 48 CoC Condition/TS Identifier:

(Form #99) Revision 0 TS Figure 1-10, Soluble Boron Concentration vs. Fuel Initial U-235 Enrichment (Intact Fuel) for the NUHOMS 24PHB System TS Figure 1-10a, Soluble Boron Concentration vs. Fuel Initial U-235 Enrichment (Damaged Fuel) for the NUHOMS 24PHB System

  • All LCOs also require an Applicability, Condition(s), Required Action(s), Completion Time(s), Surveillance Requirement(s),

and Frequency(ies). Refer to NUREG-1745 for additional guidance.

    • In performing the risk insight evaluation above, the evaluator should think about subsequent changes to a relocated CoC requirement. Specifically, ask the question what is the likelihood and worst possible consequences of a future change to this requirement in the less-conservative direction?

Requirement TS Figure 1-10 and Figure 1-10a, Soluble Boron Concentration vs. Fuel Initial U-235 Enrichment for the NUHOMS 24PHB System CoC Body Certified Design Section I. Technology No Section II. Design Features No Appendix A - Inspections, Tests, and Evaluations No Appendix B.

Technical Specifications Section 1 Definitions, Use and Application No Section 2 Approved Contents (Selection Criteria)

A1 Yes Maximum Planar Average Initial Enrichment as defined in the embedded graph and table is one of the parameters defined in 10 CFR 72.236(a)

A2 No A3 No Section 3 Limiting Conditions for Operation (LCOs)*

and Surveillance Requirements (SRs)

(Selection Criteria)

L1 No L2 No L3 No Section 4 Administrative Controls No

E-51306 Enclosure 7 Evaluation Forms for CoC 1004 TS Tables and Figures Page 48 of 48 Risk Insight**:

Will removing this requirement from the CoC/TS result in A significant increase in the probability or consequences of an accident previously evaluated in the cask FSAR?

Yes The possibility of a new or different kind of accident being created compared to those previously evaluated in the FSAR?

Yes A Significant reduction in the margin of safety for ISFSI or cask operation?

Yes Evaluation Summary The maximum planar average enrichment is required per Criterion A1 and shall be retained.