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Enclosure 2.1: Appendix a: Technical Specification (Letter to W. Fowler Amendment No. 6 to Certificate of Compliance No. 1015 for the NAC-UMS Storage System)
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Issue date:	12/04/2018
From:	John Mckirgan; Spent Fuel Licensing Branch
To:	; NAC International
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APPENDIX A TECHNICAL SPECIFICATIONS FOR THE NAC-UMS SYSTEM AMENDMENT 6 Certificate of Compliance No. 1015 A-1 Amendment No. 6

LIST OF EFFECTIVE PAGES Appendix A A-1 ........................ Amendment No. 6 A3-11 ..................... Amendment No. 6 A-2 ........................ Amendment No. 6 A3-12 ..................... Amendment No. 6 A-3 ........................ Amendment No. 6 A3-13 ..................... Amendment No. 6 A-4 ........................ Amendment No. 6 A3-14 ..................... Amendment No. 6 A3-15 ..................... Amendment No. 6 A1-1 ....................... Amendment No. 6 A3-16 ..................... Amendment No. 6 A1-2 ....................... Amendment No. 6 A3-17 ..................... Amendment No. 6 A1-3 ....................... Amendment No. 6 A3-18 ..................... Amendment No. 6 A1-4 ....................... Amendment No. 6 A3-19 ..................... Amendment No. 6 A1-5 ....................... Amendment No. 6 A3-20 ..................... Amendment No. 6 A1-6 ....................... Amendment No. 6 A3-21 ..................... Amendment No. 6 A1-7 ....................... Amendment No. 6 A3-22 ..................... Amendment No. 6 A1-8 ....................... Amendment No. 6 A1-9 ....................... Amendment No. 6 A4-1 ....................... Amendment No. 6 A1-10 ..................... Amendment No. 6 A1-11 ..................... Amendment No. 6 A5-1 ....................... Amendment No. 6 A1-12 ..................... Amendment No. 6 A5-2 ....................... Amendment No. 6 A1-13 ..................... Amendment No. 6 A5-3 ....................... Amendment No. 6 A1-14 ..................... Amendment No. 6 A5-4 ....................... Amendment No. 6 A1-15 ..................... Amendment No. 6 A5-5 ....................... Amendment No. 6 A1-16 ..................... Amendment No. 6 A1-17 ..................... Amendment No. 6 A1-18 ..................... Amendment No. 6 A1-19 ..................... Amendment No. 6 A2-1 ....................... Amendment No. 6 A3-1 ....................... Amendment No. 6 A3-2 ....................... Amendment No. 6 A3-3 ....................... Amendment No. 6 A3-4 ....................... Amendment No. 6 A3-5 ....................... Amendment No. 6 A3-6 ....................... Amendment No. 6 A3-7 ....................... Amendment No. 6 A3-8 ....................... Amendment No. 6 A3-9 ....................... Amendment No. 6 A3-10 ..................... Amendment No. 6 Certificate of Compliance No. 1015 A-2 Amendment No. 6

Table of Contents A 1.0 USE AND APPLICATION ........................................................................................... A1-1 A 1.1 Definitions........................................................................................................... A1-1 A 1.2 Logical Connectors ............................................................................................. A1-9 A 1.3 Completion Times ............................................................................................ A1-12 A 1.4 Frequency ........................................................................................................ A1-17 A 2.0 [Reserved] ................................................................................................................... A2-1 A 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ........................... A3-1 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY .......................................... A3-2 A 3.1 NAC-UMS SYSTEM Integrity ........................................................................... A3-4 A 3.1.1 CANISTER Maximum Time in Vacuum Drying ................................. A3-4 A 3.1.2 CANISTER Vacuum Drying Pressure ............................................... A3-7 A 3.1.3 CANISTER Helium Backfill Pressure ................................................ A3-8 A 3.1.4 CANISTER Maximum Time in TRANSFER CASK ........................... A3-9 A 3.1.5 CANISTER Helium Leak Rate ........................................................ A3-12 A 3.1.6 CONCRETE CASK Heat Removal System .................................... A3-13 A 3.1.7 Deleted ........................................................................................... A3-15 A 3.2 NAC-UMS SYSTEM Radiation Protection ...................................................... A3-16 A 3.2.1 CANISTER Surface Contamination ................................................ A3-16 A 3.2.2 CONCRETE CASK Average Surface Dose Rates ......................... A3-18 A 3.3 NAC-UMS SYSTEM Criticality Control ........................................................... A3-21 A 3.3.1 Dissolved Boron Concentration ...................................................... A3-21 Figure A3-1 CONCRETE CASK Surface Dose Rate Measurement ................................ A-3-20 A 4.0 [Reserved] ................................................................................................................... A4-1 A 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS................................................... A5-1 A 5.1 Training Program................................................................................................ A5-1 A 5.2 Pre-Operational Testing and Training Exercises ................................................ A5-1 A 5.3 Special Requirements for the First System Placed in Service ........................... A5-2 A 5.4 [Deleted] ............................................................................................................. A5-2 A 5.5 Radioactive Effluent Control Program ................................................................ A5-3 Certificate of Compliance No. 1015 A-3 Amendment No. 6

Table of Contents (Continued)

A 5.6 NAC-UMS SYSTEM Transport Evaluation Program ........................................ A5-3 A 5.7 Deleted ............................................................................................................... A5-4 Table A5-1 TRANSFER CASK and CONCRETE CASK Lifting Requirements .............. A5-5 Certificate of Compliance No. 1015 A-4 Amendment No. 6

Definitions A 1.1 A 1.0 USE AND APPLICATION A 1.1 Definitions

NOTE------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout this section.

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.

ASSEMBLY DEFECT Any change in the physical as-built condition of the assembly, with the exception of normal in-reactor changes such as elongation from irradiation growth or assembly bow. Examples of ASSEMBLY DEFECTS include: (a) missing rods, (b) broken or missing grids or grid straps (spacer), and (c) missing or broken grid springs, etc. An assembly with a defect is damaged only if it cannot meet its fuel-specific and system-related functions.

BREACHED SPENT FUEL ROD Spent fuel with cladding defects that permit the release of gas from the interior of the fuel rod. A fuel rod breach may be a minor defect (i.e., hairline crack or pinhole), allowing the rod to be classified as undamaged, or be a gross breach requiring a damaged fuel classification.

CANISTER See TRANSPORTABLE STORAGE CANISTER (continued)

Certificate of Compliance No. 1015 A1-1 Amendment No. 6

Definitions A 1.1 CANISTER HANDLING FACILITY The CANISTER HANDLING FACILITY includes the following components and equipment: (1) a canister transfer station that allows the staging of the TRANSFER CASK with the CONCRETE CASK or transport cask to facilitate CANISTER lifts involving spent fuel handling not covered by 10 CFR 50; and (2) either a stationary lift device or mobile lifting device used to lift the TRANSFER CASK and CANISTER.

CONCRETE CASK See VERTICAL CONCRETE CASK CONSOLIDATED FUEL A nonstandard fuel configuration in which the undamaged individual fuel rods from one or more fuel assemblies are placed in a single container or a lattice structure that is similar to a fuel assembly.

CONSOLIDATED FUEL is stored in a MAINE YANKEE FUEL CAN.

DAMAGED FUEL Spent nuclear fuel (SNF) that cannot fulfill its fuel-specific or system-related function. DAMAGED FUEL must be placed in a MAINE YANKEE FUEL CAN unless otherwise noted. Spent fuel is classified as damaged under the following conditions.

1. There is visible deformation of the rods in the SNF assembly.

Note: This is not referring to the uniform bowing that occurs in the reactor; this refers to bowing that significantly opens up the lattice spacing.

2. Individual fuel rods are missing from the assembly and the missing rods are not replaced by solid dummy/filler rods that displace a volume equal to, or greater than, the original fuel rods.

Note: Maine Yankee fuel assemblies with missing rods, not replaced by solid dummy/filler rods, are an exception based upon the criticality analysis done for these assemblies. They are, therefore, considered to be undamaged.

However, these Maine Yankee assemblies must be preferentially loaded per Tables B2-6 and B2-7.

(continued)

Certificate of Compliance No. 1015 A1-2 Amendment No. 6

Definitions A 1.1 DAMAGED FUEL (contd) 3. The SNF assembly has missing, displaced or damaged structural components such that either:

Radiological and/or criticality safety is adversely affected (e.g., significantly changed rod pitch); or

The assembly cannot be handled by normal means (i.e., crane and grapple).

Note: PWR assemblies with the following structural defects meet UMS system-related functional requirements and are, therefore, classified as undamaged.

Grid, grid strap, and/or grid strap spring damage in PWR assemblies such that the unsupported length of the fuel rod does not exceed 60 inches.

4. Any SNF assembly that contains fuel rods for which reactor operating records (or other records or tests) cannot support the conclusion that they do not contain gross breaches.

Note: Breached fuel rods with minor cladding defects (i.e, pinhole leaks or hairline cracks that will not permit significant release of particulate matter from the spent fuel rod) meet UMS system-related functional requirements and are, therefore, classified as undamaged.

5. The SNF assembly is no longer in the form of an intact fuel bundle (e.g., consists of or contains debris such as loose fuel pellets or rod segments).

FUEL DEBRIS An intact or a partial fuel rod or an individual intact or partial fuel pellet not contained in a fuel rod. Fuel debris is inserted into a 9 x 9 array of tubes in a lattice that has approximately the same dimensions as a standard fuel assembly. FUEL DEBRIS is stored in a MAINE YANKEE FUEL CAN.

(continued)

Certificate of Compliance No. 1015 A1-3 Amendment No. 6

Definitions A 1.1 GROSSLY BREACHED SPENT FUEL A breach in the spent fuel cladding that is larger than ROD a pinhole or hairline crack. A gross cladding breach may be established by visual examination with the capability to determine if the fuel pellet can be seen through the cladding, or through a review of reactor operating records indicating the presence of heavy metal isotopes.

HIGH BURNUP FUEL A fuel assembly meeting the definition of a standard fuel assembly with an assembly average burnup between 45,000 and 60,000 MWd/MTU. Maximum peak average rod burnup is limited to 62,500 MWd/MTU.

INDEPENDENT SPENT FUEL The facility within the perimeter fence licensed for STORAGE INSTALLATION (ISFSI) storage of spent fuel within NAC-UMS SYSTEMs (see also 10 CFR 72.3).

INITIAL PEAK PLANAR-AVERAGE THE INITIAL PEAK PLANAR-AVERAGE ENRICH-ENRICHMENT MENT is the maximum planar-average enrichment at any height along the axis of the fuel assembly. The 4.7 wt % 235U enrichment limit for BWR fuel applies along the full axial extent of the assembly. The INITIAL PEAK PLANAR-AVERAGE ENRICHMENT may be higher than the bundle (assembly) average enrichment.

INTACT FUEL Any fuel that can fulfill all fuel-specific and system-(ASSEMBLY OR ROD) related functions and that is not breached.

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on a NAC-UMS SYSTEM while it is being loaded with fuel assemblies. LOADING OPERATIONS begin when the first fuel assembly is placed in the CANISTER and end when the NAC-UMS SYSTEM is secured on the transporter.

LOADING OPERATIONS does not include post-storage operations, i.e., CANISTER transfer operations between the TRANSFER CASK and the CONCRETE CASK or transport cask after STORAGE OPERATIONS.

(continued)

Certificate of Compliance No. 1015 A1-4 Amendment No. 6

Definitions A 1.1 MAINE YANKEE FUEL CAN A specially designed stainless steel screened can sized to hold UNDAMAGED FUEL, CONSOLIDATED FUEL, DAMAGED FUEL or FUEL DEBRIS. The screens preclude the release of gross particulate from the can into the canister cavity. The MAINE YANKEE FUEL CAN may only be loaded in a Class 1 canister.

NAC-UMS SYSTEM NAC-UMS SYSTEM includes the components approved for loading and storage of spent fuel assemblies at the ISFSI. The NAC-UMS SYSTEM consists of a CONCRETE CASK, a TRANSFER CASK, and a CANISTER.

OPERABLE An OPERABLE CONCRETE CASK heat removal system transfers sufficient heat away from the fuel assemblies such that the fuel cladding and CANISTER component temperatures do not exceed applicable limits. The CONCRETE CASK heat removal system is considered OPERABLE if the difference between the ISFSI ambient temperature and the average outlet air temperature is <102ºF for the PWR canister or <92ºF for the BWR canister, or if all four air inlet and outlet screens are visually verified to be unobstructed. Failing this, a CONCRETE CASK heat removal system may be declared OPERABLE if an engineering evaluation determines the CONCRETE CASK has adequate heat transfer capabilities to assure continued spent fuel and CANISTER integrity.

(continued)

Certificate of Compliance No. 1015 A1-5 Amendment No. 6

Definitions A 1.1 SITE SPECIFIC FUEL Spent fuel configurations that are unique to a site or reactor due to the addition of other components or reconfiguration of the fuel assembly at the site. It includes fuel assemblies, which hold nonfuel-bearing components, such as a control element assembly, a burnable poison rod insert, a solid stainless steel rod insert, an in-core instrument thimble or a flow mixer, or which are modified as required by expediency in reactor operations, research and development or testing. Modification may consist of individual fuel rod removal, fuel rod replacement of similar or dissimilar material or enrichment, the installation, removal or replacement of burnable poison rods or solid stainless steel rods, or containerizing damaged fuel.

Site specific fuel includes irradiated fuel assemblies designed with variable enrichments and/or axial blankets, fuel that is consolidated and fuel that exceeds design basis fuel parameters.

STANDARD FUEL Irradiated fuel assemblies having the same configuration as when originally fabricated consisting generally of the end fittings, fuel rods, guide tubes, and integral hardware. For PWR fuel, a flow mixer, an in-core instrument thimble or a burnable poison rod insert is considered to be a component of standard fuel. For BWR fuel, the channel is considered to be integral hardware. The design basis fuel characteristics and analysis are based on the STANDARD FUEL configuration.

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI, while an NAC-UMS SYSTEM containing spent fuel is located on the storage pad within the ISFSI perimeter.

TRANSFER CASK TRANSFER CASK is a shielded lifting device that holds the CANISTER during LOADING and UNLOADING OPERATIONS and during closure welding, vacuum drying, leak testing, and non-destructive examination of the CANISTER closure welds. The TRANSFER CASK is also used to transfer the CANISTER into and from the CONCRETE CASK and into the transport cask.

TRANSFER CASK refers to either the standard or advanced transfer cask.

Certificate of Compliance No. 1015 A1-6 Amendment No. 6

Definitions A 1.1 TRANSFER OPERATIONS TRANSFER OPERATIONS include all licensed activities involved in transferring a loaded CANISTER from a CONCRETE CASK to another CONCRETE CASK or to a TRANSPORT CASK.

TRANSPORT OPERATIONS TRANSPORT OPERATIONS include all licensed activities involved in moving a loaded NAC-UMS CONCRETE CASK and CANISTER to and from the ISFSI. TRANSPORT OPERATIONS begin when the NAC-UMS SYSTEM is first secured on the transporter and end when the NAC-UMS SYSTEM is at its destination and no longer secured on the transporter.

TRANSPORTABLE STORAGE TRANSPORTABLE STORAGE CANISTER is the CANISTER (CANISTER) sealed container that consists of a tube and disk fuel basket in a cylindrical canister shell that is welded to a baseplate, shield lid with welded port covers, and structural lid. The CANISTER provides the confinement boundary for the confined spent fuel.

UNDAMAGED FUEL Spent nuclear fuel that can meet all fuel specific and system-related functions. UNDAMAGED FUEL is spent nuclear fuel that is not DAMAGED FUEL and does not contain assembly structural defects that adversely affect radiological and/or criticality safety.

As such, UNDAMAGED FUEL may contain:

a) BREACHED SPENT FUEL RODS (i.e, rods with minor defects up to hairline cracks or pinholes) but can not contain grossly breached fuel rods; b) Grid, grid strap, and/or grid spring damage in PWR assemblies, provided that the unsupported length of the fuel rod does not exceed 60 inches.

(continued)

Certificate of Compliance No. 1015 A1-7 Amendment No. 6

Definitions A 1.1 UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on a NAC-UMS SYSTEM to be unloaded of the contained fuel assemblies. UNLOADING OPERATIONS begin when the NAC-UMS SYSTEM is no longer secured on the transporter and end when the last fuel assembly is removed from the NAC-UMS SYSTEM.

VERTICAL CONCRETE CASK VERTICAL CONCRETE CASK is the cask that (CONCRETE CASK) receives and holds the sealed CANISTER. It provides the gamma and neutron shielding and convective cooling of the spent fuel confined in the CANISTER.

Certificate of Compliance No. 1015 A1-8 Amendment No. 6

Logical Connectors A 1.2 A 1.0 USE AND APPLICATION A 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 Technical Specifications 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 indentations 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; the logical connector is left justified with the statement of the Condition, Completion Time, Surveillance, or Frequency.

(continued)

Certificate of Compliance No. 1015 A1-9 Amendment No. 6

Logical Connectors A 1.2 EXAMPLES The following examples illustrate the use of logical connectors.

EXAMPLES EXAMPLE 1.2-1 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.

(continued)

Certificate of Compliance No. 1015 A1-10 Amendment No. 6

Logical Connectors A 1.2 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 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 indicated that A.2.2.1 and A.2.2.2 are alternative choices, only one of which must be performed.

Certificate of Compliance No. 1015 A1-11 Amendment No. 6

Completion Times A 1.3 A 1.0 USE AND APPLICATION A 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 Operations (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the NAC-UMS SYSTEM. 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 Time(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, provided that the NAC-UMS SYSTEM is in a specified Condition stated in the Applicability of the LCO. Prior to the expiration of the specified Completion Time, Required Actions must be completed. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the NAC-UMS SYSTEM 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.

(continued)

Certificate of Compliance No. 1015 A1-12 Amendment No. 6

Completion Times A 1.3 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 Action B.1 Perform Action B.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and associated Completion AND Time not met B.2 Perform Action B.2 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Condition B has two Required Actions. Each Required Action has its own 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND complete action B.2 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A total of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed for completing action B.1 and a total of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (not 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ) is allowed for completing action B.2 from the time that Condition B was entered. If action B.1 is completed within six hours, the time allowed for completing action B.2 is the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months because the total time allowed for completing action B.2 is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

(continued)

Certificate of Compliance No. 1015 A1-13 Amendment No. 6

Completion Times A 1.3 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Action and B.1 associated Completion AND Time not met B.2 Complete action 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months B.2 When a System is determined not to meet the LCO, Condition A is entered. If the System is not restored within seven 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; therefore, the Required Actions of Condition B may be terminated.

(continued)

Certificate of Compliance No. 1015 A1-14 Amendment No. 6

Completion Times A 1.3 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 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months compliance with LCO B. Required B.1 Complete action 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and B.1 associated Completion AND Time not met B.2 Complete action 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 to be 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 are tracked for each component.

(continued)

Certificate of Compliance No. 1015 A1-15 Amendment No. 6

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

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

TIME Certificate of Compliance No. 1015 A1-16 Amendment No. 6

Frequency A 1.4 A 1.0 USE AND APPLICATION A 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.

Each 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 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.

The use of met or performed in these instances conveys specific meanings. A Surveillance is met only after the acceptance criteria are satisfied. Known failure of the requirements of a Surveillance, even without a Surveillance specifically being performed, constitutes a Surveillance not met.

(continued)

Certificate of Compliance No. 1015 A1-17 Amendment No. 6

Frequency A 1.4 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , SR 3.0.2 allows an extension of the time interval to 1.25 times the interval specified in the Frequency 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 variables are 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.

(continued)

Certificate of Compliance No. 1015 A1-18 Amendment No. 6

Frequency A 1.4 EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limits Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to starting activity AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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.

Certificate of Compliance No. 1015 A1-19 Amendment No. 6

A 2.0 A 2.0 [Reserved]

Certificate of Compliance No. 1015 A2-1 Amendment No. 6

LCO Applicability A 3.0 A 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 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 a NAC-UMS SYSTEM.

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 NAC-UMS SYSTEM.

Exceptions to this Condition are stated in the individual Specifications.

These exceptions allow entry into specified conditions in the Applicability where the associated ACTIONS to be entered allow operation in the specified conditions in the Applicability only for a limited period of time.

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 to return to service under administrative control to perform the testing.

Certificate of Compliance No. 1015 A3-1 Amendment No. 6

SR Applicability A 3.0 A 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 a failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be a 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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.

(continued)

Certificate of Compliance No. 1015 A3-2 Amendment No. 6

SR Applicability A 3.0 SR 3.0.3 (continued) 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.

SR 3.0.4 Entry into a specified Condition in the Applicability of an LCO shall not be made, unless the LCOs 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 a NAC-UMS SYSTEM.

Certificate of Compliance No. 1015 A3-3 Amendment No. 6

CANISTER Maximum Time in Vacuum Drying A 3.1.1 A 3.1 NAC-UMS SYSTEM Integrity A 3.1.1 CANISTER Maximum Time in Vacuum Drying LCO 3.1.1 The following limits for vacuum drying time shall be met, as appropriate:

1. The time duration from completion of draining the CANISTER through completion of vacuum dryness testing and the completion of LCO A 3.1.3 shall not exceed the following time limits:

PWR Total Heat Time Limit Total Heat Time Limit Load (L) (kW) (Hours) Load (L) (kW) (Hours) 20 < L 23 27 11 < L 14 40 17.6 < L 20 30 8 < L 11 52 14 < L 17.6 33 L8 103 BWR Total Heat Time Limit Total Heat Time Limit Load (L) (kW) (Hours) Load (L) (kW) (Hours) 20 < L 23 25 11 < L 14 45 17 < L 20 27 8 < L 11 72 14 < L 17 33 L8 600 (continued)

Certificate of Compliance No. 1015 A3-4 Amendment No. 6

CANISTER Maximum Time in Vacuum Drying A 3.1.1

2. The time duration from the end of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of in-pool cooling or of forced air cooling of the CANISTER through completion of vacuum dryness testing and the completion of LCO A 3.1.3 shall not exceed the following limits:

PWR Forced Air PWR In-Pool Total Heat Time Limit Total Heat Time Limit Load (L) (kW) (Hours) Load (L) (kW) (Hours) 20 < L 23 3 20 < L 23 12 17.6 < L 20 6 17.6 < L 20 15 14 < L 17.6 9 14 < L 17.6 18 11 < L 14 16 11 < L 14 24 8 < L 11 27 8 < L 11 36 L 8 78 L 8 87 BWR Forced Air BWR In-Pool Total Heat Time Limit Total Heat Time Limit Load (L) (kW) (Hours) Load (L) (kW) (Hours) 20 < L 23 2 20 < L 23 10 17 < L 20 3 17 < L 20 11 14 < L 17 8 14 < L 17 17 11 < L 14 18 11 < L 14 26 L 11 41 L 11 52 Note: A CANISTER loaded with a fuel assembly having a burnup

>45 GWd/MTU is limited to a total of nine (9) cooling/vacuum drying cycles performed in accordance with LCO 3.1.1.2.

APPLICABILITY: During LOADING OPERATIONS (continued)

Certificate of Compliance No. 1015 A3-5 Amendment No. 6

CANISTER Maximum Time in Vacuum Drying A 3.1.1 ACTIONS

NOTE----------------------------------------------------------------------

Separate Condition entry is allowed for each NAC-UMS SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO time limits A.1 Fill CANISTER with helium 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months not met AND A.2.1.1 Place TRANSFER CASK with 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months helium filled loaded CANISTER in spent fuel pool.

AND A.2.1.2 Maintain TRANSFER CASK and 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months CANISTER in spent fuel pool for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR A.2.2.1 Commence supplying air to the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months TRANSFER CASK annulus fill/drain lines at a rate of 375 CFM and a maximum temperature of 76ºF AND A.2.2.2 Maintain airflow for a minimum 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Monitor elapsed time from completion of As required to meet the time CANISTER draining operations until limit completion of LCO A 3.1.3.

SR 3.1.1.2 Monitor elapsed time from the end of in- As required to meet the time pool cooling or of forced-air cooling until limit completion of LCO A 3.1.3.

Certificate of Compliance No. 1015 A3-6 Amendment No. 6

CANISTER Vacuum Drying Pressure A 3.1.2 A 3.1 NAC-UMS SYSTEM Integrity A 3.1.2 CANISTER Vacuum Drying Pressure LCO 3.1.2 The CANISTER vacuum drying pressure, 10 mm of mercury (Hg),

shall be held for a minimum of 10 minutes with the vacuum pump isolated and turned off, with the pressure remaining 10 mm of Hg during the 10-minute period.

APPLICABILITY: During LOADING OPERATIONS ACTIONS

NOTE----------------------------------------------------

Separate Condition entry is allowed for each NAC-UMS SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CANISTER vacuum drying A.1 Establish CANISTER 25 days pressure limit not met cavity vacuum drying pressure within limit B. Required Action and B.1 Remove all fuel 5 days associated Completion assemblies from the Time not met NAC-UMS SYSTEM SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2.1 Verify CANISTER cavity vacuum drying Prior to TRANSPORT pressure is within limits OPERATIONS.

Certificate of Compliance No. 1015 A3-7 Amendment No. 6

CANISTER Helium Backfill Pressure A 3.1.3 A 3.1 NAC-UMS SYSTEM Integrity A 3.1.3 CANISTER Helium Backfill Pressure LCO 3.1.3 The CANISTER helium backfill pressure shall be 0 (+1, -0) psig.

APPLICABILITY: During LOADING OPERATIONS ACTIONS

NOTE----------------------------------------------------

Separate Condition entry is allowed for each NAC-UMS SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CANISTER helium backfill A.1 Establish CANISTER 25 days pressure limit not met helium backfill pressure within limit B. Required Action and B.1 Remove all fuel 5 days associated Completion assemblies from the Time not met NAC-UMS SYSTEM SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Verify CANISTER helium backfill pressure Prior to TRANSPORT is within limit OPERATIONS.

Certificate of Compliance No. 1015 A3-8 Amendment No. 6

CANISTER Maximum Time in TRANSFER CASK A 3.1.4 A 3.1 NAC-UMS SYSTEM Integrity A 3.1.4 CANISTER Maximum Time in TRANSFER CASK LCO 3.1.4 The total cumulative time a loaded and helium filled CANISTER may remain in TRANSFER CASK is limited to 600 hours0.00694 days 0.167 hours 9.920635e-4 weeks 2.283e-4 months . The following intermediate time limits for loaded and helium filled CANISTER time in TRANSFER CASK, without forced air or in-pool cooling, shall apply between cooling cycles. Canisters with total heat loads below those with intermediate limits are only limited by the 600 cumulative hours.

Total PWR Heat Time Limit Load (L)(kW) (Hours) 20 < L 23 20 Total BWR Heat Time Limit Load (L)(kW) (Hours) 20 < L 23 16 17 < L 20 30 APPLICABILITY: During LOADING OPERATIONS, TRANSFER OPERATIONS, and UNLOADING OPERATIONS.

(continued)

Certificate of Compliance No. 1015 A3-9 Amendment No. 6

CANISTER Maximum Time in TRANSFER CASK A 3.1.4 ACTIONS

NOTE--------------------------------------------------------

Separate Condition entry is allowed for each NAC-UMS SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. ----NOTE ----- A.1.1 Place TRANSFER CASK with 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months All time spent in CANISTER in spent fuel pool Condition A is part of the 600 AND hour cumulative limit A.1.2 Maintain TRANSFER CASK and 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months

CANISTER in spent fuel pool for Intermediate a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time limit not OR met A.2.1 Commence supplying air to the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months TRANSFER CASK annulus fill/drain lines at a rate of 375 CFM and a maximum temperature of 76ºF AND A.2.2 Maintain airflow for a minimum 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B. 600 hour0.00694 days 0.167 hours 9.920635e-4 weeks 2.283e-4 months B.1 Load CANISTER into 5 days cumulative time CONCRETE CASK limit not met OR B.2 Load CANISTER into 5 days TRANSPORT CASK OR B.3 Remove all fuel assemblies from 5 days the NAC-UMS SYSTEM (continued)

Certificate of Compliance No. 1015 A3-10 Amendment No. 6

CANISTER Maximum Time in TRANSFER CASK A 3.1.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 Monitor elapsed time for compliance with As required to meet the time LCO 3.1.4 limit Certificate of Compliance No. 1015 A3-11 Amendment No. 6

CANISTER Helium Leak Rate A 3.1.5 A 3.1 NAC-UMS SYSTEM Integrity A 3.1.5 CANISTER Helium Leak Rate LCO 3.1.5 There shall be no indication of a helium leak at a test sensitivity of 1 x 10-7 cm3/sec (helium) through the CANISTER shield lid to CANISTER shell confinement weld to demonstrate a helium leak rate equal to or less than 2 x 10-7 cm3/sec (helium).

APPLICABILITY: During LOADING OPERATIONS ACTIONS

NOTE----------------------------------------------------

Separate Condition entry is allowed for each NAC-UMS SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CANISTER helium leak A.1 Establish CANISTER 25 days rate limit not met helium leak rate within limit B. Required Action and B.1 Remove all fuel 5 days associated Completion assemblies from the Time not met NAC-UMS SYSTEM SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify CANISTER helium leak rate is within Once prior to TRANSPORT limit OPERATIONS.

Certificate of Compliance No. 1015 A3-12 Amendment No. 6

CONCRETE CASK Heat Removal System A 3.1.6 A 3.1 NAC-UMS SYSTEM A 3.1.6 CONCRETE CASK Heat Removal System LCO 3.1.6 The CONCRETE CASK Heat Removal System shall be OPERABLE.

APPLICABILITY: During STORAGE OPERATIONS ACTIONS

NOTE---------------------------------------------------

Separate Condition entry is allowed for each NAC-UMS SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CONCRETE CASK heat A.1 Ensure adequate heat Immediately removal system inoperable removal to prevent exceeding short-term temperature limits AND A.2 Restore CONCRETE 25 days CASK Heat Removal System to OPERABLE status B. Required Actions A.1 or B.1 Perform an engineering 5 days A.2 and associated evaluation to determine Completion Times not met that the CONCRETE CASK Heat Removal System is OPERABLE OR B.2 Place the NAC-UMS 5 days SYSTEM in a safe condition (continued)

Certificate of Compliance No. 1015 A3-13 Amendment No. 6

CONCRETE CASK Heat Removal System A 3.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 Verify the difference between the ISFSI 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ambient temperature and the average outlet air temperature is < 102ºF for the PWR canister or < 92ºF for the BWR canister OR Visually verify all four air inlet and outlet screens are unobstructed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.1.6.2 Verify the difference between the ISFSI Once between 5 and 30 days ambient temperature and the average after STORAGE outlet air temperature is < 102ºF for the OPERATIONS begin PWR canister or < 92ºF for the BWR canister Certificate of Compliance No. 1015 A3-14 Amendment No. 6

CANISTER Removal from the CONCRETE CASK A 3.1.7

[DELETED]

Certificate of Compliance No. 1015 A3-15 Amendment No. 6

CANISTER Surface Contamination A 3.2.1 A 3.2 NAC-UMS SYSTEM Radiation Protection A 3.2.1 CANISTER Surface Contamination LCO 3.2.1 Removable contamination on the exterior surfaces of the CANISTER shall not exceed:

a. 10,000 dpm/100 cm2 from beta and gamma sources; and

b. 100 dpm/100 cm2 from alpha sources.

APPLICABILITY: During LOADING OPERATIONS ACTIONS

NOTE-----------------------------------------------------

Separate Condition entry is allowed for each NAC-UMS SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CANISTER removable A.1 Restore CANISTER Prior to TRANSPORT surface contamination removable surface OPERATIONS limits not met contamination to within limits (continued)

Certificate of Compliance No. 1015 A3-16 Amendment No. 6

CANISTER Surface Contamination A 3.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify by either direct or indirect methods Once, prior to TRANSPORT that the removable contamination on the OPERATIONS exterior surfaces of the CANISTER is within limits Certificate of Compliance No. 1015 A3-17 Amendment No. 6

CONCRETE CASK Average Surface Dose Rate A 3.2.2 A 3.2 NAC-UMS SYSTEM Radiation Protection A 3.2.2 CONCRETE CASK Average Surface Dose Rates LCO 3.2.2 The average surface dose rates of each CONCRETE CASK shall not exceed the following limits unless required ACTIONS A.1 and A.2 are met.

a. 50 mrem/hour (neutron + gamma) on the side (on the concrete surfaces);

b. 50 mrem/hour (neutron + gamma) on the top;

c. 100 mrem/hour (neutron + gamma) at air inlets and outlets.

APPLICABILITY: Prior to STORAGE OPERATIONS ACTIONS

NOTE-------------------------------------------------

Separate Condition entry is allowed for each NAC-UMS SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CONCRETE CASK A.1 Administratively verify 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months average surface dose rate correct fuel loading limits not met AND (continued)

Certificate of Compliance No. 1015 A3-18 Amendment No. 6

CONCRETE CASK Average Surface Dose Rate A 3.2.2 CONDITION REQUIRED ACTION COMPLETION TIME A.2 Perform analysis to 7 days verify compliance with the ISFSI offsite radiation protection requirements of 10 CFR 20 and 10 CFR 72 B. Required Action and B.1 Remove all fuel 30 days associated Completion assemblies from the Time not met. NAC-UMS SYSTEM SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Verify average surface dose rates of Prior to STORAGE CONCRETE CASK loaded with a OPERATIONS CANISTER containing fuel assemblies are within limits. Dose rates shall be measured at the locations shown in Figure A3-1.

Certificate of Compliance No. 1015 A3-19 Amendment No. 6

CONCRETE CASK Average Surface Dose Rate A 3.2.2 Figure A3-1 CONCRETE CASK Surface Dose Rate Measurement Measure dose rates at target points shown Measure dose rates at eight target points (0, 45, 90, 135, 180, 225, 270 and 315 degrees) on each plane, at center of each inlet and outlet and at a point in between each inlet and outlet.

Certificate of Compliance No. 1015 A3-20 Amendment No. 6

Dissolved Boron Concentration A 3.3.1 A 3.3 NAC-UMS SYSTEM Criticality Control A 3.3.1 Dissolved Boron Concentration LCO 3.3.1 The dissolved boron concentration in the water in the CANISTER cavity shall be 1,000 ppm.

APPLICABILITY: During LOADING OPERATIONS and UNLOADING OPERATIONS with water and at least one fuel assembly in the CANISTER that exceeds the enrichment limits in Table B2-2 for fuel assemblies taking no boron credit.

ACTIONS

NOTE----------------------------------------------------

Separate Condition entry is allowed for each NAC-UMS SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. Dissolved boron A.1 Suspend loading of fuel Immediately concentration not assemblies into CANISTER met. and any other actions that increase reactivity AND A.2 Initiate action to restore Immediately boron concentration to within limit AND A.3.1 Restore boron 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months concentration to within limit OR A.3.2 Remove all fuel assemblies 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that exceed the enrichment limits of Table B2-2 for fuel assemblies taking no boron credit Certificate of Compliance No. 1015 A3-21 Amendment No. 6

Dissolved Boron Concentration A 3.3.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.1 Verify the dissolved boron concentration is Once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to met using two independent commencing LOADING or measurements. UNLOADING OPERATIONS.

AND Every 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter while the CANISTER is in the spent fuel pool or while water is in the CANISTER, except when no water is being introduced into the CANISTER cavity.

Certificate of Compliance No. 1015 A3-22 Amendment No. 6

A 4.0 A 4.0 [Reserved]

Certificate of Compliance No. 1015 A4-1 Amendment No. 6

Administrative Controls and Programs A 5.0 A 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS A 5.1 Training Program A training program for the NAC-UMS Universal Storage System shall be developed under the general licensees systematic approach to training (SAT). Training modules shall include comprehensive instructions for the operation and maintenance of the NAC-UMS Universal Storage System and the independent spent fuel storage installation (ISFSI).

A 5.2 Pre-Operational Testing and Training Exercises A dry run training exercise on loading, closure, handling, unloading, and transfer of the NAC-UMS Storage System shall be conducted by the licensee prior to the first use of the system to load spent fuel assemblies. The training exercise shall not be conducted with spent fuel in the CANISTER. The dry run may be performed in an alternate step sequence from the actual procedures, but all steps must be performed. The dry run shall include, but is not limited to the following:

a. Moving the CONCRETE CASK into its designated loading area

b. Moving the TRANSFER CASK containing the empty CANISTER into the spent fuel pool

c. Loading one or more dummy fuel assemblies into the CANISTER, including independent verification

d. Selection and verification of fuel assemblies requiring preferential loading

e. Installing the shield lid

f. Removal of the TRANSFER CASK from the spent fuel pool

g. Closing and sealing of the CANISTER to demonstrate pressure testing, vacuum drying, helium backfilling, welding, weld inspection and documentation, and leak testing

h. TRANSFER CASK movement through the designated load path

i. TRANSFER CASK installation on the CONCRETE CASK

j. Transfer of the CANISTER to the CONCRETE CASK (continued)

Certificate of Compliance No. 1015 A5-1 Amendment No. 6

Administrative Controls and Programs A 5.0 A 5.2 Pre-Operational Testing and Training Exercises (continued)

k. CONCRETE CASK shield plug and lid installation

l. Transport of the CONCRETE CASK to the ISFSI

m. CANISTER unloading, including reflooding and weld removal or cutting

n. CANISTER removal from the CONCRETE CASK Appropriate mockup fixtures may be used to demonstrate and/or to qualify procedures, processes or personnel in welding, weld inspection, vacuum drying, helium backfilling, leak testing and weld removal or cutting.

A 5.3 Special Requirements for the First System Placed in Service The heat transfer characteristics and performance of the NAC-UMS SYSTEM will be recorded by air inlet and outlet temperature measurements of the first system placed in service with a heat load equal to or greater than 10 kW. A letter report summarizing the results of the measurements will be submitted to the NRC in accordance with 10 CFR 72.4 within 30 days of placing the loaded cask on the ISFSI pad. The report will include a comparison of the calculated temperatures of the NAC-UMS SYSTEM heat load to the measured temperatures. A report is not required to be submitted for the NAC-UMS SYSTEMs that are subsequently loaded, provided that the performance of the first system placed in service with a heat load 10 kW is demonstrated by the comparison of the calculated and measured temperatures.

A 5.4 [DELETED]

(continued)

Certificate of Compliance No. 1015 A5-2 Amendment No. 6

Administrative Controls and Programs A 5.0 A 5.5 Radioactive Effluent Control Program The program implements the requirements of 10 CFR 72.126.

a. The NAC-UMS SYSTEM 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. LCO 3.1.5, CANISTER Helium Leak Rate, provides assurance that there are no radioactive effluents from the NAC-UMS SYSTEM.

b. This program includes an environmental monitoring program. Each general license user may incorporate NAC-UMS SYSTEM operations into their environmental monitoring program for 10 CFR Part 50 operations.

A 5.6 NAC-UMS SYSTEM Transport Evaluation Program This program provides a means for evaluating various transport configurations and transport route conditions to ensure that the design basis drop limits are met. For lifting of the loaded TRANSFER CASK or CONCRETE CASK using devices that are integral to a structure governed by 10 CFR Part 50 regulations, 10 CFR 50 requirements apply.

This program is not applicable when the TRANSFER CASK or CONCRETE CASK is in the fuel building or is being handled by a device providing support from underneath (i.e.,

on a rail car, heavy haul trailer, air pads, etc.).

Pursuant to 10 CFR 72.212, this program shall evaluate the site specific transport route conditions.

a. The lift height above the transport surface shall not exceed the limits in Table A5-1.

(continued)

Certificate of Compliance No. 1015 A5-3 Amendment No. 6

Administrative Controls and Programs A 5.0 A 5.6 NAC-UMS SYSTEM Transport Evaluation Program (continued)

b. For site-specific transport conditions that are not bounded by Section 11.2.4 of the NAC-UMS Final Safety Analysis Report, the program may evaluate the site-specific conditions to ensure that the impact loading due to site-specific drop events does not exceed 60g. This alternative analysis shall be commensurate with the drop analyses described in the Final Safety Analysis Report for the NAC-UMS SYSTEM. The program shall ensure that these alternative analyses are documented and controlled.

c. The TRANSFER CASK and CONCRETE CASK may be lifted to those heights necessary to perform cask handling operations, including CANISTER transfer, provided the lifts are made with structures and components designed in accordance with the criteria specified in Section B3.5 of Appendix B to CoC No. 1015, as applicable.

A 5.7 [Deleted]

Certificate of Compliance No. 1015 A5-4 Amendment No. 6

Administrative Controls and Programs A 5.0 Table A5-1 TRANSFER CASK and CONCRETE CASK Lifting Requirements Loaded Cask Item Orientation Lifting Height Limit TRANSFER CASK Horizontal Not Permitted TRANSFER CASK Vertical None Established1 CONCRETE CASK Horizontal Not Permitted CONCRETE CASK Vertical < 24 inches Note:

1. See Technical Specification A5.6(c).

Certificate of Compliance No. 1015 A5-5 Amendment No. 6

ML18333A233

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