Text

Enclosurenewed License SNM-2509 Technical Specifications (Letter to B. Nicholson Issuance of Renewed Materials License No. SNM-2509 for the Trojan Independent Spent Fuel Storage Installation)
	ML19221B650
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/09/2019
From:	Meraj Rahimi; Renewals and Materials Branch
To:	Nicholson B; Portland General Electric Co
	Markley C
Shared Package
ML19221B646	List: ML19221B647; ML19221B648; ML19221B649; ML19221B650; ML19221B651; ML19221B652; ML19296B636; ML19296B637;
References
	EPID L-2017-LNE-0009, EPID L-2017-RNW-0011
	Download: ML19221B650 (84)
	v • d • e

TECHNICAL SPECIFICATIONS FOR TROJAN INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

Amendment 7 l

TABLE OF CONTENTS 1.0 USE AND APPLICATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.1-1 1.1 Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.1-1 1.2 Logical Connectors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.2-1 1.3 Completion Times . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.3-1 1.4 Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.4-1 2.0 APPROVED CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1-1 2.1 Approved Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1-1 2.1.1 Fuel Stored at the ISFSI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1-1 2.1.2 Fuel Storage Configuration Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1-1 2.2 Approved Contents Violations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.2-1 2.2.1 Fuel Stored at the ISFSI and Fuel Storage Configuration Limits . . . . . . . . . . . 2.2-1 Table 2-1 Spent Fuel Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.2-2 Table 2-2 Fuel Assembly Inserts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.2-3 3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY . . . . . . . . . 3.0-1 3.0 SURVEILLANCE REQUIREMENTS (SR) APPLICABILITY . . . . . . . . . . . . . . . . . 3.0-2 3.1 DELETED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.1-1 l 3.2 TRANSFER CASK Integrity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.2-1 3.2.1 TRANSFER CASK Ambient Air Temperature Limit . . . . . . . . . . . . . . . . 3.2-1 3.3 AIR PADS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.3-1 3.3.1 AIR PAD Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.3-1 4.0 DESIGN FEATURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.1-1 4.1 Site Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.1-1 4.2 Storage Features . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.2-1 4.2.1 Storage System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.2-1 4.2.2 Storage Capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.2-1 4.2.2a Design Features Important for Criticality Control . . . . . . . . . . . . . . . . . . . 4.2-1 4.2.3 Storage Pad and TRANSFER STATION . . . . . . . . . . . . . . . . . . . . . . . . . . 4.2-1 4.3 Codes and Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.3-1 4.3.1 MPC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.3-1 4.3.2 NOT USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.3-1 Trojan ISFSI i Amendment 4 l

TABLE OF CONTENTS 5.0 ADMINISTRATIVE CONTROLS .................................................................................. 5.1-1 5.1 Responsibility .................................................................................................................. 5.1-1 5.2 Organization ..................................................................................................................... 5.2-1 5.3 ISFSI Staff Qualifications ................................................................................................ 5.3-1 5.4 Procedures ........................................................................................................................ 5.4-1 5.5 Programs .......................................................................................................................... 5.5-1 5.5.1 Technical Specifications (TS) Bases Control Program ....................................... 5.5-1 5.5.2 Radioactive Effluent Control Program ............................................................... 5.5-1 5.5.3 CONCRETE CASK Thermal Monitoring Program ........................................... 5.5-2 5.5.4 Radiation Protection Program ............................................................................. 5.5-3 5.5.5 Aging Management Program ............................................................................... 5.5-3 5.6 High Radiation Areas ....................................................................................................... 5.6-1 Trojan ISFSI 11 Amendment 7 l

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

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

The defined terms of this section appear in capitalized type and are applicable throughout these Trojan Independent Spent Fuel Storage Installation (ISFSI)Technical Specifications and Bases.

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

AIR PADS The AIR PADS are commercially available lifting devices that are used to move the CONCRETE CASKS. The AIR PADS consist of four air bladders that are inserted into the CONCRETE CASK air inlets and are inflated to lift a CONCRETE CASK up to four inches off the surface which then allows it to be moved.

CONCRETE CASK The CONCRETE CASK is the structure in which a MULTI-PURPOSE CANISTER (MPC) is stored.

DAMAGED FUEL DAMAGED FUEL ASSEMBLIES are fuel assemblies which can ASSEMBLY be handled by normal means: (1) with known or suspected cladding defects greater than pinhole leaks or hairline cracks; or (2) with missing fuel rods that are not replaced with dummy fuel rods.

Fuel assemblies which cannot be handled by normal means due to fuel cladding damage are considered to be FUEL DEBRIS.

DAMAGED FUEL ASSEMBLIES are stored in FAILED FUEL CANS or DAMAGED FUEL CONTAINERS.

DAMAGED FUEL DAMAGED FUEL CONTAINERS are specially designed CONTAINER enclosures for DAMAGED FUEL ASSEMBLIES and FUEL DEBRIS. DAMAGED FUEL CONTAINERS are stored in an MPC.

FAILED FUEL CAN FAILED FUEL CANS are specially designed enclosures for DAMAGED FUEL ASSEMBLIES, FUEL DEBRIS, and Trojan ISFSI 1.1-1 Amendment 4 l

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions PROCESS CAN CAPSULES. FAILED FUEL CANS are stored in an MPC.

FUEL DEBRIS FUEL DEBRIS is fuel with known or suspected defects, such as ruptured fuel rods, severed rods, or loose fuel pellets and fuel pellet fragments. FUEL DEBRIS includes fuel assembly metal fragments such as portions of fuel rods and grid assemblies. Fuel assemblies which cannot be handled by normal means due to fuel cladding damage are considered to be FUEL DEBRIS. FUEL DEBRIS is stored in PROCESS CAN CAPSULES, which are stored in FAILED FUEL CANS, or directly in FAILED FUEL CANS or DAMAGED FUEL CONTAINERS depending upon the extent of damage.

INTACT FUEL INTACT FUEL ASSEMBLIES are fuel assemblies which can be ASSEMBLY handled by normal means: (1) without known or suspected cladding defects greater than pinhole leaks or hairline cracks; or (2) with missing fuel rods which are replaced by dummy rods. Fuel assemblies from which fuel rods are missing shall not be classified as INTACT FUEL ASSEMBLIES unless dummy fuel rods are used to displace an amount of water equal to or greater than that displaced by the original fuel rod(s).

l MULTI-PURPOSE The MPC is the stainless steel welded container that is designed for CANISTER (MPC) storage and transportation of INTACT FUEL ASSEMBLIES and FAILED FUEL CANS and DAMAGED FUEL CONTAINERS that contain DAMAGED FUEL ASSEMBLIES and FUEL DEBRIS.

PROCESS CAN PROCESS CAN CAPSULES are sealed, inerted canisters CAPSULE containing FUEL DEBRIS. PROCESS CAN CAPSULES are stored in FAILED FUEL CANS.

Trojan ISFSI 1.1-2 Amendment 4 l

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI while a CONCRETE CASK containing an MPC with INTACT FUEL ASSEMBLIES, DAMAGED FUEL ASSEMBLIES, or FUEL DEBRIS, is located within the ISFSI perimeter including movement of and use of the TRANSFER CASK or a Transport Cask.

TRANSFER CASK The TRANSFER CASK is used to support an MPC at the l TRANSFER STATION.

TRANSFER STATION The TRANSFER STATION is a steel structure, located on the Transfer Pad, to the west of the Storage Pad, designed to safely facilitate loading the MPC into a Transport Cask.

l TROJAN STORAGE The TROJAN STORAGE SYSTEM is defined as the TranStor' SYSTEM CONCRETE CASK containing a Holtec MPC-24E or MPC-24EF.

The Holtec MPC-24E and MPC-24EF used at Trojan are modified to fit within the TranStor' CONCRETE CASKS, as described in the Trojan ISFSI Safety Analysis Report.

l Trojan ISFSI 1.1-3 Amendment 4 l

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions UNLOADING UNLOADING OPERATIONS include activities performed OPERATIONS on an MPC to be unloaded of the contained INTACT FUEL ASSEMBLIES, DAMAGED FUEL ASSEMBLIES, or FUEL DEBRIS. UNLOADING OPERATIONS begin when actions have commenced to relocate the MPC to the Cask Loading Pit and end when the last INTACT FUEL ASSEMBLY, DAMAGED FUEL ASSEMBLY, or FUEL DEBRIS has been removed from the MPC. l Trojan ISFSI 1.1-4 Amendment 3 l

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

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

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

EXAMPLES The following example illustrates the use of logical connectors. The only l logical connector remaining in these TS is AND. l Trojan ISFSI 1.2-1 Amendment 4 l

Logical Connectors 1.2 1.0 USE AND APPLICATION 1.2 Logical Connectors EXAMPLES EXAMPLE 1.2-1 (continued)

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

AND A.2 Restore...

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

Trojan ISFSI 1.2-2 Amendment 4 l

Logical Connectors 1.2 1.0 USE AND APPLICATION 1.2 Logical Connectors EXAMPLES EXAMPLE 1.2-2 (continued)

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

OR A.2.1 Verify...

AND A.2.2.1 Reduce...

OR A.2.2.2 Perform...

OR A.3 Remove...

This example represents a more complicated use of logical connectors.

Required Actions A.1, A.2, and A.3 are alternative choices, only one of which must be performed as indicated by the use of the logical connector OR and the left justified placement. Any one of these three Actions may be chosen. If A.2 is chosen, then both A.2.1 and A.2.2 must be performed as indicated by the logical connector AND. Required Action A.2.2 is met by performing A.2.2.1 or A.2.2.2. The indented position of the logical connector OR indicates that A.2.2.1 and A.2.2.2 are alternative choices, only one of which must be performed.

Trojan ISFSI 1.2-3 Amendment 3 l

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

BACKGROUND Limiting Conditions for Operations (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion 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, providing the facility is in a specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the facility is not within the LCO Applicability.

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

l EXAMPLES The following example illustrates the use of Completion Times. l The only Completion Time remaining in the LCOs is l Immediately. l Trojan ISFSI 1.3-1 Amendment 4 l

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times EXAMPLES EXAMPLE 1.3-1 l (continued) l ACTIONS l ll CONDITION REQUIRED ACTION COMPLETION l TIME l l

A. LCO not met. A.1 Restore compliance Immediately l with LCO. l l

l When Immediately is used as a Completion Time, the Required Action l should be pursued without delay and in a controlled manner. l Trojan ISFSI 1.3-2 Amendment 4 l

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times EXAMPLES EXAMPLE 1.3-2 (continued)

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

limits.

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 to not meet the LCO, Condition A is entered. If the system is not restored within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the system is restored after Condition B is entered, Conditions A and B are exited, and therefore, the Required Actions of Condition B may be terminated.

Trojan ISFSI 1.3-3 Amendment 3 l

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS

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

Separate Condition entry is allowed for each component.

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

B. Required B.1 Complete action B.1 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated AND Completion Time not met. B.2 Complete action B.2 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months The Note above the ACTIONS Table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table.

The Note allows Condition A to be entered separately for each component, and Completion Times tracked on a per component basis. When a component is determined to not meet the LCO, Condition A is entered and its Completion Time starts. If subsequent components are determined to Trojan ISFSI 1.3-4 Amendment 3 l

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times not meet the LCO, Condition A is entered for each component and separate Completion Times start and are tracked for each component.

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

Trojan ISFSI 1.3-5 Amendment 3 l

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

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

The "specified Frequency" is referred to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR)

Applicability. The "specified Frequency" consists of the requirements stated in the Frequency column of each SR. l 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 a SR satisfied, SR 3.0.4 imposes no restriction.

Trojan ISFSI 1.4-1 Amendment 4 l

Frequency 1.4 1.0 USE AND APPLICATION 1.4 Frequency EXAMPLES The following examples illustrate the various ways that Frequencies are specified.

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify ambient air temperature within limit. Every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months l Example 1.4-1 contains the type of SR most often encountered in the TS.

The Frequency specifies an interval (every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) during which the l associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , an extension of the time interval to l 1.25 times the stated Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when a variable is outside specified limits, or the facility is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the facility is in a condition specified in the Applicability of the LCO, the LCO is not met in accordance with SR 3.0.1.

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

Trojan ISFSI 1.4-2 Amendment 4 l

Frequency 1.4 1.0 USE AND APPLICATION 1.4 Frequency EXAMPLES EXAMPLE 1.4-2 (continued)

SURVEILLANCE REQUIREMENTS l SURVEILLANCE FREQUENCY Verify ambient air temperature is within Once within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to l limits. starting activity AND 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months thereafter l 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 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to starting the activity. l 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.

Trojan ISFSI 1.4-3 Amendment 4 l

Frequency 1.4 1.0 USE AND APPLICATION 1.4 Frequency EXAMPLES EXAMPLE 1.4-3 (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

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

Not required to be met until 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months after verifying the helium leak rate is within limit.

Verify MPC cavity dryness is Once after verifying the helium within limit. leak rate is within limit.

As the Note modifies the required performance of the Surveillance, it is construed to be part of the specified Frequency. Should the cavity dryness not be met immediately following verification of the MPC lid weld helium leak rate while in LOADING OPERATIONS, this Note allows 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months to perform the Surveillance. The Surveillance is still considered to be performed within the specified Frequency.

Once the MPC lid weld helium leak rate has been verified to be acceptable, 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months , plus the extension allowed by SR 3.0.2, would be allowed for completing the Surveillance for the cavity dryness. If the Surveillance was not performed within this 96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months interval, there would then be a failure to perform the Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.

Trojan ISFSI 1.4-4 Amendment 3 l

Approved Contents l 2.0 2.0 APPROVED CONTENTS l 2.1 Approved Contents l 2.1.1 Fuel Stored at the ISFSI l The spent nuclear fuel to be stored in CONCRETE CASKS at the Trojan ISFSI shall consist of the following:

a. INTACT FUEL ASSEMBLIES as characterized in Table 2-1,

b. DAMAGED FUEL ASSEMBLIES, l

c. FUEL DEBRIS in a PROCESS CAN CAPSULE, which shall not exceed l 7.5 kg of fissile material per MPC and 20 Curies of Plutonium per MPC, l and other FUEL DEBRIS, which shall not exceed the fissile material of an l INTACT FUEL ASSEMBLY, and l

d. Fuel assembly inserts as characterized in Table 2-2. l 2.1.2 Fuel Storage Configuration Limits l l

The spent nuclear fuel to be stored in the MPC shall be limited as follows: l l

a. Up to 24 INTACT FUEL ASSEMBLIES may be stored in either the MPC- l 24E or the MPC-24EF. l l

b. DAMAGED FUEL ASSEMBLIES must be stored in FAILED FUEL l CANS or DAMAGED FUEL CONTAINERS and may be stored in either l the MPC-24E or the MPC-24EF. DAMAGED FUEL ASSEMBLIES are l limited to four per MPC in the oversized corner fuel cell locations. l l

c. FUEL DEBRIS must be stored in FAILED FUEL CANS or DAMAGED l FUEL CONTAINERS in an MPC-24EF. Up to four FAILED FUEL l CANS and/or DAMAGED FUEL CONTAINERS containing FUEL l DEBRIS or DAMAGED FUEL ASSEMBLIES may be stored in the l MPC-24EF in the oversized corner fuel cell locations. l l

d. Contents of an MPC must not exceed 1,680 lbs in any cell, and the dry l loaded MPC weight must not exceed 78,700 lbs. l Trojan ISFSI 2.0-1 Amendment 2 l

Approved Contents l 2.0 2.0 APPROVED CONTENTS l 2.2 Approved Contents Violations l 2.2.1 Fuel Stored at the ISFSI and Fuel Storage Configuration Limits: l If the Approved Contents of 2.1 are violated, the following actions shall be l completed:

a. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , notify the NRC Operations Center, and

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

Trojan ISFSI 2.0-2 Amendment 2 l

Approved Contents l 2.0 Table 2-1 Spent Fuel Limits CHARACTERISTIC LIMIT l Clad Zircaloy-4 l Cooling Time After Discharge $9 years l Fuel Enrichment # 3.7 weight % U235 l Decay Heat per MPC # 17.4 kWt l Fuel Design B&W 17x17 (Mark-BW-17) and Westinghouse 17x17 Burnup # 42,000 Mwd/MTU l No. of Fuel Rod Locations 264 l l

Fuel Rod Clad O.D. $ 0.372 in. l l

Fuel Rod Clad I.D. # 0.331 in. l l

Fuel Pellet Diameter # 0.3232 in. l l

Fuel Rod Pitch # 0.496 in. l l

Active Fuel Length # 150 in. l l

No. of Guide and/or Instrument Tubes 25 l l

Guide/Instrument Tube thickness $ 0.014 in. (Nominal design) l l

Weight of MPC Cell Contents # 1,680 lbs (including non-fuel hardware and l FAILED FUEL CAN or DAMAGED FUEL l CONTAINER) l Trojan ISFSI 2.0-3 Amendment 2 l

Approved Contents l 2.0 Table 2-2 Fuel Assembly Inserts CHARACTERISTIC LIMIT l Rod Cluster Control Assemblies (RCCAs)

Number of Assemblies 61 Neutron Absorber Ag-In-Cd Cladding Material 304 SS Number of Rods per Assembly 24 Burnup # 125,515 MWd/MTU l Cooling Time $ 9 years l Burnable Poison Rod Assemblies (BPRAs)

Number of Assemblies 92 Poison Material Borosilicate Glass Tubes Cladding Material 304 SS Burnup # 15,998 MWd/MTU l Cooling Time $ 24 years l Thimble Plugs Number of Thimble Plugs 140 Material 304 SS Burnup # 118,674 MWd/MTU l Cooling Time $ 11 years l Sources Number of Source Assemblies 6 Secondary Sources/Material 4/Sb-Be Burnup # 88,547 MWd/MTU l Cooling Time $ 9 years l Primary Sources/Material 2/Californium Burnup # 15,998 MWd/MTU l Cooling Time $ 24 years l Cladding Material 304 SS Trojan ISFSI 2.0-4 Amendment 2 l

Approved Contents 2.0 2.0 APPROVED CONTENTS 2.1 Approved Contents 2.1.1 Fuel Stored at the ISFSI The spent nuclear fuel stored in CONCRETE CASKS at the Trojan ISFSI consists l of the following:

a. INTACT FUEL ASSEMBLIES as characterized in Table 2-1,

b. DAMAGED FUEL ASSEMBLIES,

c. FUEL DEBRIS in a PROCESS CAN CAPSULE, which shall not exceed 7.5 kg of fissile material per MPC and 20 Curies of Plutonium per MPC, and other FUEL DEBRIS, which shall not exceed the fissile material of an INTACT FUEL ASSEMBLY, and

d. Fuel assembly inserts as characterized in Table 2-2.

2.1.2 Fuel Storage Configuration Limits The spent nuclear fuel stored in the MPC is limited as follows: l

a. Up to 24 INTACT FUEL ASSEMBLIES are stored in either the MPC-24E l or the MPC-24EF.

b. DAMAGED FUEL ASSEMBLIES are stored in FAILED FUEL CANS or l DAMAGED FUEL CONTAINERS and are stored in either the MPC-24E l or the MPC-24EF. DAMAGED FUEL ASSEMBLIES are limited to four per MPC in the oversized corner fuel cell locations.

c. FUEL DEBRIS is stored in FAILED FUEL CANS or DAMAGED FUEL l CONTAINERS in an MPC-24EF. Up to four FAILED FUEL CANS and/or DAMAGED FUEL CONTAINERS containing FUEL DEBRIS or DAMAGED FUEL ASSEMBLIES are stored in the MPC-24EF in the l oversized corner fuel cell locations.

d. Contents of an MPC do not exceed 1,680 lbs in any cell, and the dry l loaded MPC weight does not exceed 78,700 lbs. l Trojan ISFSI 2.1-1 Amendment 4 l

Approved Contents 2.0 2.0 APPROVED CONTENTS 2.2 Approved Contents Violations 2.2.1 Fuel Stored at the ISFSI and Fuel Storage Configuration Limits:

If the Approved Contents of 2.1 are violated, the following actions shall be completed:

a. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , notify the NRC Operations Center, and

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

Trojan ISFSI 2.2-1 Amendment 4 l

Approved Contents 2.0 Table 2-1 Spent Fuel Limits CHARACTERISTIC LIMIT Clad Zircaloy-4 Cooling Time After Discharge $9 years Fuel Enrichment # 3.7 weight % U235 Decay Heat per MPC # 17.4 kWt Fuel Design B&W 17x17 (Mark-BW-17) and Westinghouse 17x17 Burnup # 42,000 MWd/MTU No. of Fuel Rod Locations 264 Fuel Rod Clad O.D. $ 0.372 in.

Fuel Rod Clad I.D. # 0.331 in.

Fuel Pellet Diameter # 0.3232 in.

Fuel Rod Pitch # 0.496 in.

Active Fuel Length # 150 in.

No. of Guide and/or Instrument Tubes 25 Guide/Instrument Tube thickness $ 0.014 in. (Nominal design)

Weight of MPC Cell Contents # 1,680 lbs (including non-fuel hardware and FAILED FUEL CAN or DAMAGED FUEL CONTAINER)

Trojan ISFSI 2.2-2 Amendment 4 l

Approved Contents 2.0 Table 2-2 Fuel Assembly Inserts CHARACTERISTIC LIMIT Rod Cluster Control Assemblies (RCCAs)

Number of Assemblies 61 Neutron Absorber Ag-In-Cd Cladding Material 304 SS Number of Rods per Assembly 24 Burnup # 125,515 MWd/MTU Cooling Time $ 9 years Burnable Poison Rod Assemblies (BPRAs)

Number of Assemblies 92 Poison Material Borosilicate Glass Tubes Cladding Material 304 SS Burnup # 15,998 MWd/MTU Cooling Time $ 24 years Thimble Plugs Number of Thimble Plugs 140 Material 304 SS Burnup # 118,674 MWd/MTU Cooling Time $ 11 years Sources Number of Source Assemblies 6 Secondary Sources/Material 4/Sb-Be Burnup # 88,547 MWd/MTU Cooling Time $ 9 years Primary Sources/Material 2/Californium Burnup # 15,998 MWd/MTU Cooling Time $ 24 years Cladding Material 304 SS Trojan ISFSI 2.2-3 Amendment 4 l

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

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

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Actions(s) is not required, unless otherwise stated.

LCO 3.0.3 Not applicable to an ISFSI.

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

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

LCO 3.0.6 Not applicable to an ISFSI.

LCO 3.0.7 Not applicable to an ISFSI.

Trojan ISFSI 3.0-1 Amendment 4 l

LCO and Surveillance Requirements Applicability 3.0 3.0 SURVEILLANCE REQUIREMENTS (SR) APPLICABILITY SR 3.0.1 SRs shall be met during specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a SR, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable 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 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.

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

Trojan ISFSI 3.0-2 Amendment 4 l

LCO and Surveillance Requirements Applicability 3.0 3.0 SURVEILLANCE REQUIREMENTS (SR) APPLICABILITY SR 3.0.4 Entry into a specified condition in the Applicability of an LCO shall not be made unless the LCOs SRs 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 establishing an inert atmosphere in the MPC.

Trojan ISFSI 3.0-3 Amendment 4 l

MPC Lid Weld Helium Leak Rate 3.1.1 3.1 MPC INTEGRITY 3.1.1 MPC Lid Weld Helium Leak Rate LCO 3.1.1 The MPC Lid weld helium leak rate shall be # 5x10-6 atm-cc/sec.

APPLICABILITY: LOADING OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each MPC.

CONDITION REQUIRED ACTION COMPLETION TIME A. MPC lid weld helium A.1 Establish MPC lid weld 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months leak rate limit not helium leak rate within met. limit.

B. Required Action A.1 B.1 Establish cooling to the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and Associated MPC, Completion Time not met. AND B.2 Unload the MPC. 30 days Trojan ISFSI 3.1-1 Amendment 3 l

l 3.1 DELETED l Trojan ISFSI 3.1-1 Amendment 4 l

TRANSFER CASK Ambient Air Temperature Limit 3.2.1 3.2 TRANSFER CASK INTEGRITY 3.2.1 TRANSFER CASK Ambient Air Temperature Limit LCO 3.2.1 The TRANSFER CASK shall not be used to support a loaded MPC when l the ambient air temperature is # 0EF.

APPLICABILITY: STORAGE OPERATIONS. l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. TRANSFER CASK A.1 Place the TRANSFER Immediately ambient air CASK in a safe condition.

temperature is # 0EF.

AND A.2 Suspend all activities Immediately involving use of TRANSFER CASK until ambient air temperature has returned to > 0EF.

Trojan ISFSI 3.2-1 Amendment 4 l

TRANSFER CASK Ambient Air Temperature Limit 3.2.1 3.2 TRANSFER CASK INTEGRITY 3.2.1 TRANSFER CASK Ambient Air Temperature Limit SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify ambient air temperature does not Within one hour prior to use exceed the specified limit. of the TRANSFER CASK with a loaded MPC.

SR 3.2.1.2 Verify ambient air temperature does not Every four hours during use exceed the specified limit. of the TRANSFER CASK with a loaded MPC when ambient air temperature is

< 5EF.

Trojan ISFSI 3.2-2 Amendment 4 l

AIR PAD Limits 3.3.1 3.3 AIR PADS 3.3.1 AIR PAD Limits LCO 3.3.1 The AIR PADS shall not be installed under a CONCRETE CASK containing a loaded MPC:

a. For more than 20 consecutive hours, or

b. When the ambient air temperature is > 100EF.

APPLICABILITY: STORAGE OPERATIONS. l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. AIR PADS installed for A.1 Remove the AIR PADS. Immediately more than 20 consecutive hours.

B. AIR PADS installed and B.1 Remove the AIR PADS. Immediately ambient air temperature

> 100EF.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.1 Verify the AIR PADS are not installed for more Every 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months when the AIR than 20 consecutive hours. PADS are installed.

SR 3.3.1.2 Verify ambient air temperature is # 100EF. Within one hour before installation and hourly when ambient air temperature is >

90EF and the AIR PADS are installed.

Trojan ISFSI 3.3-1 Amendment 4 l

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location The Trojan INDEPENDENT SPENT FUEL STORAGE INSTALLATION l (ISFSI) facility is located at the Portland General Electric (PGE) Company site in l Columbia County, Oregon, approximately 42 miles north of Portland, Oregon, and approximately 4-1/2 miles southeast of Rainier, Oregon, on the west bank of the Columbia River. The site is approximately 3 miles northwest of Kalama, Washington, and 6 miles southeast of Longview, Washington, which are across the Columbia River. l 4.2 Storage Features 4.2.1 Storage System Portland General Electric Company is licensed to store spent fuel in the TROJAN l STORAGE SYSTEM in a maximum of 34 CONCRETE CASKS at the Trojan l ISFSI. Each CONCRETE CASK can contain one MPC. The MPC can l accommodate up to 24 INTACT FUEL ASSEMBLIES with associated inserts.

Up to four FAILED FUEL CANS and/or DAMAGED FUEL CONTAINERS may l also be stored in each MPC as defined in Technical Specification 2.1.2, with the l balance being INTACT FUEL ASSEMBLIES, up to a total of 24 assemblies per l MPC. The MPC will be backfilled with helium and pressurized between 29.3 and l 33.3 psig. l 4.2.2 Storage Capacity The total storage capacity of the Trojan ISFSI is limited to 344.5 MTU as UO2.

This total capacity of UO2 is categorized into the following Byproduct, Source, and/or Special Nuclear Material:

INTACT FUEL ASSEMBLIES (Clad with Zircaloy-4)

DAMAGED FUEL ASSEMBLIES (Clad with Zircaloy-4) l FUEL DEBRIS 4.2.2.a Design Features Important for Criticality Control l Flux trap size for oversized corner cells $ 0.526 in. l Flux trap size for other cells $ 1.076 in. l 10 B loading in Boral absorbers: $ 0.0372 g/cm2 l Trojan ISFSI 4.0-1 Amendment 2 l

Design Features 4.0 4.0 DESIGN FEATURES 4.2.3 Storage Pad and TRANSFER STATION l C Loaded CONCRETE CASKS must have a nominal center-to-center 15 l feet spacing with a tolerance of +/- 4 inches when stored in their assigned l location on the ISFSI Storage Pad except for the 30 foot +/- 4 inch center- l to-center gap in the center of the ISFSI Storage Pad l l

C Operations at the TRANSFER STATION which involve lifts of a loaded l MPC must be performed using a mobile crane, which shall meet the l guidance of Section 5.1.1 of NUREG-0612, Control of Heavy Loads at l Nuclear Power Plants, dated 1980, except that to assure defense in depth: l

1. The mobile crane in its lifting configuration (reeving, placement, l boom length, angle, counterweight, etc.) shall have a rated capacity l of at least two times the weight to be lifted (loaded MPC plus l lifting hardware) in accordance with the guidance of NUREG- l 0612. l

2. In accordance with the guidance of NUREG-0612, the mobile l crane must have the ability to safely stop and hold the MPC in the l event of the Seismic Margin Earthquake (SME) applicable to the l Trojan ISFSI. l

3. The mobile crane shall meet the requirements of ANSI B30.5, l Mobile and Locomotive Cranes, or equivalent, in lieu of the l requirements of ANSI B30.2, Overhead and Gantry Cranes. l

4. The MPC will be restricted to a lift height not to exceed 249 inches l (bottom of raised MPC in the TRANSFER CASK to bottom of l Transport Cask) when being lifted by the mobile crane in the l TRANSFER STATION by the physical limitation of the bottom of l the lid of the TRANSFER CASK. A load cell, or equivalent, on l the mobile crane will indicate contact with the bottom of the lid of l the TRANSFER CASK to limit the lift height of the MPC. l Trojan ISFSI 4.0-2 Amendment 2 l

Design Features 4.0 4.0 DESIGN FEATURES

5. Special Lifting Devices as defined in ANSI N14.6-1993 shall have l two times the design safety factors of Section 4.2.1.1 in accordance l with Section 7.2. These special lifting devices shall include the l lifting cleats. l

6. Lifting Devices that are not specifically designed and that are used l for handling heavy loads shall meet the requirements of ANSI l B30.9, Slings, except that the load to be used in selecting the l slings is to be twice that specified in NUREG-0612, Section l 5.1.1(5). l C Movements of a CONCRETE CASK are performed using an AIR PAD System that restricts the lifting height of the CONCRETE CASK to four l inches or less.

Trojan ISFSI 4.0-3 Amendment 2 l

Design Features 4.0 4.0 DESIGN FEATURES 4.3 Codes and Standards 4.3.1 MPC l The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section III, 1995 Edition with Addenda through 1997, is the l governing Code for the MPC Storage System used at Trojan. l 4.3.1.1 Design Alternatives to Codes, Standards, and Criteria l Trojan ISFSI SAR Table 4.2-1a lists approved alternatives to codes, l standards, and criteria governing the design of the MPC. l 4.3.2 NOT USED l l

4.3.3 Construction/Fabrication Alternatives to Design Codes, Standards, and Criteria l Proposed construction/fabrication alternatives to the MPC design codes and l standards, including alternatives of Specification 4.3.1, may be used when l authorized by the Director of the Office of Nuclear Material Safety and Safeguards or designee. The licensee should demonstrate that:

1. The proposed alternatives would provide an acceptable level of quality and safety, or

2. Compliance with the specified requirements of ASME Code Section III, 1995 Edition with Addenda through 1997, would result in hardship or l unusual difficulty without a compensating increase in the level of quality and safety.

Requests for relief in accordance with this section shall be submitted in accordance with 10 CFR 72.4.

Trojan ISFSI 4.0-4 Amendment 2 l

Table 4-1 ASME Code Deviations Section Requirement Exception Subsection Miscellaneous administrative No Design Specification or Design Report will be required. Manufacturer will not be required to have a NCA requirements. Certificate of Authorization or an NCA-4000 Quality Assurance Program. Material Organizations will not be required to have an NCA-3800 Quality Assurance Program. Authorized Inspection will not be required. Code Data Reports and Code Symbol/Stamps will not be required.

NC-3211.1 Welding configuration Structural attachment welds are permitted to be attached by welds that are not continuous on all sides.

NC-3254 requirements allowed in vessels These attachments do not serve a pressure retaining function, and, when fuel is loaded, are subject only NC-4267 designed per the reql)irements of to accident loads. Cyclic loading, stress *ratchet, and fatigue are not credible events. Detailed drop NC-3200. analysis includes actual weld configuration and potential load transfer to the pressure retaining boundary.

NC-3252 Category C welded joints for Subsection NC requires Category C full-penetration corner welded joints to be examined by the NC-5253 vessels designed to NC-3200 radiographic or ultrasonic method. The Category C structural lid closure weld will not be nondestructively examined in accordance with NC-2553. This weld will be examined by the liquid penetrant method (multi-layer procedure that includes the root and final layers and sufficient intermediate layers to detect critical flaws). In addition, the partial penetration weld between the shield lid and the shell will be examined by the liquid penetrant method (as required by NC-5260) and will be helium leak tested, ensuring a leak-tight boundary.

NC-3258 Design of head attachments using When the head-to-shell weld is a corner joint, NC-3258.3 requires the through-thickness dimension of corner joints the weld to exceed the thinner of the head or shell thickness by an amount that varies with the specific joint design. Due to the geometry of the internals and due to lack of access to the inside surface of the structural lid closure weld, the shell-to-bottom-plate weld and the structural-lid-to-shell closure weld do not have the required ~ in. fillet weld or other weld reinforcement on the ID surface.

Trojan ISFSI 4.0-5 March 1999

Table 4-1 ASME Code Deviations Section Requirement Exception NC-6000 Hydrostatic pressure test The vessel shell will not be hydrostatically tested in accordance with the code since vessel side walls and bottom are not accessible for inspection. Structural welds will be volumetrically examined, except the structural lid weld, which will be examined by the liquid penetrant method. The partial penetration shield lid weld will be hydrostatically tested, helium leak-tested and liquid penetrant tested.

NG-2121 Material utilized in fabrication* shall Not all Basket materials will be selected from materials permitted for use in Section III core support conform to the requirements of the structures. Appropriate material properties will be determined from available technical literature. The specification for material given in primary function is structural, and appropriate structural materials will be selected.

Tables 2A, 2B, and 4 of Section II, Part D, Subpart 1 and all special requirements of NG.

Trojan ISFSI 4.0-6 March 1999

Table 4-2 CONCRETE CASK Code Deviations' I Code Section Requirement Exception/Justification No.

1.2 Specifies how drawings and The loads used in the design are covered in calculations must be handled the calculations rather than the drawings and specifications.

A.4 The limits for bulk, (150'F) & local A long term temperature limitation of area (2000) concrete temperature. 225 0 F is used. This increased limit is based on test data from several research efforts which show that concrete of similar composition to that used in the casks does not suffer loss of strength when exposed to I temperatures up to 350 0F.

'Deviations are from ACI-349.

Trojan ISFSI 4.0-7 Amendment 1

Site Location 4.1 4.0 DESIGN FEATURES 4.1 Site Location 4.1 Site Location The Trojan INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) facility is located at the Portland General Electric (PGE) Company site in Columbia County, Oregon, approximately 42 miles north of Portland, Oregon, and approximately 4-1/2 miles southeast of Rainier, Oregon, on the west bank of the Columbia River. The site is approximately 3 miles northwest of Kalama, Washington, and 6 miles southeast of Longview, Washington, which are across the Columbia River.

Trojan ISFSI 4.1-1 Amendment 4 l

Storage Features 4.2 4.0 DESIGN FEATURES 4.2 Storage Features 4.2 Storage Features 4.2.1 Storage System Portland General Electric Company is licensed to store spent fuel in the TROJAN STORAGE SYSTEM in a maximum of 34 CONCRETE CASKS at the Trojan ISFSI. Each CONCRETE CASK contains one MPC. The MPC accommodates l up to 24 INTACT FUEL ASSEMBLIES with associated inserts. Up to four FAILED FUEL CANS and/or DAMAGED FUEL CONTAINERS may also be stored in each MPC as defined in Technical Specification 2.1.2, with the balance being INTACT FUEL ASSEMBLIES, up to a total of 24 assemblies per MPC.

The MPC is backfilled with helium and pressurized between 29.3 and 39.3 psig at l a reference temperature of 70EF.

4.2.2 Storage Capacity The total storage capacity of the Trojan ISFSI is limited to 344.5 MTU as UO2.

This total capacity of UO2 is categorized into the following Byproduct, Source, and/or Special Nuclear Material:

INTACT FUEL ASSEMBLIES (Clad with Zircaloy-4)

DAMAGED FUEL ASSEMBLIES (Clad with Zircaloy-4)

FUEL DEBRIS 4.2.2.a Design Features Important for Criticality Control Flux trap size for oversized corner cells $ 0.526 in.

Flux trap size for other cells $ 1.076 in.

10 B loading in Boral absorbers: $ 0.0372 g/cm2 4.2.3 Storage Pad and TRANSFER STATION C Loaded CONCRETE CASKS must have a nominal center-to-center 15 feet spacing with a tolerance of +/- 4 inches when stored in their assigned location on the ISFSI Storage Pad except for the 30 foot +/- 4 inch center-to-center gap in the center of the ISFSI Storage Pad Trojan ISFSI 4.2-1 Amendment 4 l

Storage Features 4.2 4.0 DESIGN FEATURES 4.2 Storage Features C Operations at the TRANSFER STATION which involve lifts of a loaded MPC must be performed using a mobile crane, which shall meet the guidance of Section 5.1.1 of NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, dated 1980, except that to assure defense in depth:

1. The mobile crane in its lifting configuration (reeving, placement, boom length, angle, counterweight, etc.) shall have a rated capacity of at least two times the weight to be lifted (loaded MPC plus lifting hardware) in accordance with the guidance of NUREG-0612.

2. In accordance with the guidance of NUREG-0612, the mobile crane must have the ability to safely stop and hold the MPC in the event of the Seismic Margin Earthquake (SME) applicable to the Trojan ISFSI.

3. The mobile crane shall meet the requirements of ANSI B30.5, Mobile and Locomotive Cranes, or equivalent, in lieu of the requirements of ANSI B30.2, Overhead and Gantry Cranes.

4. The MPC will be restricted to a lift height not to exceed 249 inches (bottom of raised MPC in the TRANSFER CASK to bottom of Transport Cask) when being lifted by the mobile crane in the TRANSFER STATION by the physical limitation of the bottom of the lid of the TRANSFER CASK. A load cell, or equivalent, on the mobile crane will indicate contact with the bottom of the lid of the TRANSFER CASK to limit the lift height of the MPC.

5. Special Lifting Devices as defined in ANSI N14.6-1993 shall have two times the design safety factors of Section 4.2.1.1 in accordance with Section 7.2. These special lifting devices shall include the lifting cleats.

6. Lifting Devices that are not specifically designed and that are used for handling heavy loads shall meet the requirements of ANSI B30.9, Slings, except that the load to be used in selecting the slings is to be twice that specified in NUREG-0612, Section 5.1.1(5).

Trojan ISFSI 4.2-2 Amendment 4 l

Storage Features 4.2 4.0 DESIGN FEATURES 4.2 Storage Features C Movements of a CONCRETE CASK are performed using an AIR PAD System that restricts the lifting height of the CONCRETE CASK to four inches or less.

Trojan ISFSI 4.2-3 Amendment 4 l

Codes and Standards 4.3 4.0 DESIGN FEATURES 4.3 Codes and Standards 4.3 Codes and Standards 4.3.1 MPC The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section III, 1995 Edition with Addenda through 1997, is the governing Code for the MPC Storage System used at Trojan.

4.3.1.1 Design Alternatives to Codes, Standards, and Criteria Trojan ISFSI SAR Table 4.2-1a lists approved alternatives to codes, standards, and criteria governing the design of the MPC.

4.3.2 NOT USED 4.3.3 Construction/Fabrication Alternatives to Design Codes, Standards, and Criteria Proposed construction/fabrication alternatives to the MPC design codes and standards, including alternatives of Specification 4.3.1, may be used when authorized by the Director of the Office of Nuclear Material Safety and Safeguards or designee. The licensee should demonstrate that:

1. The proposed alternatives would provide an acceptable level of quality and safety, or

2. Compliance with the specified requirements of ASME Code Section III, 1995 Edition with Addenda through 1997, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Requests for relief in accordance with this section shall be submitted in accordance with 10 CFR 72.4.

Trojan ISFSI 4.3-1 Amendment 4 l

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

The ISFSI Manager, or his designee, shall approve prior to implementation, each proposed test, experiment, or modification to systems or equipment that are important to safety as defined in 10 CFR 72.3.

Trojan ISFSI 5.1-1 Amendment 4 l

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and offsite organizations shall be established for facility operation and corporate l management, respectively, as described in the ISFSI Safety Analysis Report or the Trojan Nuclear Quality Assurance Program Topical Report (PGE-8010).

Trojan ISFSI 5.2-1 Amendment 4 l

ISFSI Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 ISFSI Staff Qualifications 5.3.1 Each member of the ISFSI Staff shall meet or exceed the minimum qualifications described in the ISFSI Safety Analysis Report.

Trojan ISFSI 5.3-1 Amendment 4 l

Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and maintained covering the important to safety activities related to STORAGE OPERATIONS described in the ISFSI Safety Analysis Report.

Trojan ISFSI 5.4-1 Amendment 4 l

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

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

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

b. The licensee may make changes to the Bases without prior NRC approval provided the changes do not require prior NRC approval pursuant to 10 CFR 72.48.

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

d. Proposed changes that do not meet the criteria of 5.5.1.b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 72.48.

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

a. The Trojan ISFSI does not create any radioactive materials or have any radioactive waste treatment systems. Therefore, specific operating procedures for the control of radioactive effluents are not required. The MPC Lid Weld Helium Leak Rate test that was conducted during cask loading provides assurance that there are essentially no measurable radioactive effluents from the ISFSI.

b. This program includes an environmental monitoring program. The environmental monitoring program ensures the annual dose equivalent to any real individual located outside the ISFSI Controlled Area does not exceed regulatory limits.

l Trojan ISFSI 5.5-1 Amendment 5 l

Programs 5.5 5.0 ADMINISTRATIVE CONTROLS l 5.5 Programs 5.5.3 CONCRETE CASK Thermal Monitoring Program This program provides guidance for temperature measurements that are used to monitor the thermal performance of each CONCRETE CASK.

a. The air outlet temperature and the ambient air temperature are measured daily.

The temperature difference between the air outlet temperature and the ambient air temperature will be calculated and recorded. The air inlet vents will be inspected and verified free of blockage weekly. In the event of an environmental phenomenon occurring, the frequency of visual inspection will be increased in accordance with the severity and consequences of the event.

b. If any air outlet temperature or temperature difference between air outlet and ambient temperatures show an unexplained reading, a comparison with predicted and/or baseline data will be performed and appropriate actions taken to determine the cause and return the temperature to an acceptable value. One of the immediate actions will be to increase the frequency of temperature monitoring.

c. If any air outlet temperature reaches or exceeds the program limit, the NRC will be notified in accordance with 10 CFR 72.75(b), (e), and (f), and actions will be taken to evaluate the effects and impact of the high temperature on the CONCRETE CASK. Taking actions when air outlet temperature reaches the program limit should preclude reaching the short term bulk concrete temperature limit which is 350EF. Concrete temperatures in excess of 350EF could potentially weaken the concrete strength and tests may have to be performed to evaluate the concrete and to justify continued use of the CONCRETE CASK.

Trojan ISFSI 5.5-2 Amendment 5 l

Programs 5.5 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs 5.5.4 Radiation Protection Program The Radiation Protection Program will establish administrative controls to limit personnel exposure to As Low As Reasonably Achievable (ALARA) levels in accordance with 10 CFR 20.

A monitoring program to ensure the annual dose equivalent to any real individual located outside the ISFSI Controlled Area does not exceed regulatory limits is incorporated as part of the environmental monitoring program in the Radioactive Effluent Control Program of Specification 5.5.2.

5.5.5 Aging Management Program The Aging Management Program will establish the processes and procedures to manage the aging of ISFSI components into extended storage periods. This program will be implemented consistent with ISFSI Safety Analysis Report Section 9.7.8. As part of this program, tollgate assessments will be performed in accordance with ISFSI Safety Analysis Report Section 9.7.10.

The Aging Management Program will be implemented on or before 20 years from the date of the first canister loading.

Trojan ISFSI 5.5-3 Amendment 7 l

High Radiation Areas 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 High Radiation Areas 5.6.1 High Radiation Areas, as defined in 10 CFR 20, will be identified and access controlled in accordance with 10 CFR 20.1601 except for the tops of designated CONCRETE CASKS. Pursuant to 10 CFR 20, paragraph 20.1601 (c), in lieu of the requirements of 10 CFR 20.1601 (a), a CONCRETE CASK where the top is designated a high radiation area, as defined in 10 CFR 20, in which the intensity of radiation is >100 mrem/hr but < 1000 mrem/hr, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto does not have to be locked but shall be controlled by the Radiation Protection Program of 5.5.4.

Trojan ISFSI 5.6-1 Amendment 4 l

TECHNICAL SPECIFICATIONS BASES FOR TROJAN INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

March 1999

Approved Contents l B 2.0 B 2.0 APPROVED CONTENTS l BASES B.2.1.1 and B2.1.2 Fuel Stored at the ISFSI and Fuel Storage Configuration Limits l BASES BACKGROUND The design of the MPC and CONCRETE CASK is based on specifications l of spent fuel and fuel related material that will be stored. These specifications include type and quantity of fuel and fuel inserts, condition of spent fuel, maximum initial enrichment, maximum burnup, and minimum cooling time prior to storage.

These specifications for spent fuel and fuel related material are included in the thermal, structural, radiological, criticality, and materials evaluations l performed for the TROJAN STORAGE SYSTEM components (e.g., the l CONCRETE CASK and MPC) described in the ISFSI SAR (Ref. 1). l The design of the TROJAN STORAGE SYSTEM is such that the MPC is l placed in the TRANSFER CASK and loaded with INTACT FUEL ASSEMBLIES, FAILED FUEL CANS, and DAMAGED FUEL l CONTAINERS in the spent fuel pool (i.e., Cask Loading Pit). l Administrative controls are used to ensure each MPC is loaded with l material meeting the specifications provided in Tables 2-1 and 2-2. Prior to removing the TRANSFER CASK and MPC from the spent fuel pool l (i.e., Cask Loading Pit), the loading of the MPC is verified. l After loading and placing the MPC lid on the MPC, the TRANSFER l CASK containing the MPC is removed from the spent fuel pool (i.e., Cask l Loading Pit) and transferred to the cask preparation area where closure, MPC cavity drying and helium backfilling are performed on the MPC. l After installation of the MPC vent and drain port cover plates and closure l ring, the MPC is transferred from the TRANSFER CASK to a l CONCRETE CASK in preparation for transportation to and storage at the ISFSI.

Trojan ISFSI B2.0-1 Amendment 2 l

Approved Contents l B 2.0 B 2.0 APPROVED CONTENTS l BASES After loading, contact surface dose rates and surface contamination of the CONCRETE CASK are measured in accordance with the Radiation Protection Program of Administrative Controls Section 5.5.4. In addition, l the CONCRETE CASK is monitored in accordance with the Thermal Monitoring Program of Administrative Controls Section 5.5.3 to verify that the thermal performance is in accordance with design limits.

APPLICABLE Administrative controls are established to ensure that misloading of an l SAFETY MPC will not occur. The administrative controls prevent exceeding the l ANALYSES design limits for thermal, structural, radiological, criticality, and material l parameters assumed in the SAR (Ref. 1). As a result of the permanent l cessation of power operations, the characteristics and inventory available l for loading into the MPCs are known and limited to those fuel assemblies l and fuel related material within the Trojan Nuclear Plant (TNP) spent fuel pool. The design of the MPC and CONCRETE CASK is based on a l maximum heat load of 17.4 kW, a maximum burnup of 42,000 l MWd/MTU, and a minimum cooling time of 9 years. Table 2-1 imposes l these limits. The MPC-24E/24EF design will not accommodate more than l 24 INTACT FUEL ASSEMBLIES and/or combination of 20-24 INTACT l FUEL ASSEMBLIES and up to four FAILED FUEL CANS and/or l DAMAGED FUEL CONTAINERS. l Based on the actual inventory of spent fuel available for storage, no combination of INTACT FUEL ASSEMBLIES could result in a decay heat load exceeding a limit of 17.4 kW. In addition, the actual inventory l of FUEL DEBRIS stored in Process Can Capsules is less than 7.5 kg of l fissile material and less than 20 Curies of plutonium. Similarly, no l combination of INTACT FUEL ASSEMBLIES, FAILED FUEL CANS, l and DAMAGED FUEL CONTAINERS would result in exceeding the l design limits for radiation dose, criticality, and materials. The l specifications limit the spent fuel to a minimum of nine years of cooling l prior to loading in a CONCRETE CASK to ensure radiation levels are less l than assumed design criteria. No loading combination would result in a l l

l l

l Trojan ISFSI B2.0-2 Amendment 2 l

Approved Contents l B 2.0 B 2.0 APPROVED CONTENTS l BASES l

critical configuration given the maximum enrichment of the fuel. The l geometry of and use of solid neutron absorbing material (Boral) in the l MPC is such that a critical mass cannot be achieved. The materials used l in the MPC, CONCRETE CASK, and TRANSFER CASK have been l evaluated and determined to not have an adverse effect on the safe transfer l and storage of spent fuel. The structural analysis of a loaded CONCRETE l CASK was performed assuming a weight of 300,000 lbs, which is greater l that the maximum weight of a loaded CONCRETE CASK with 24 l RCCAs. l APPROVED The following Approved Contents violation responses are applicable. l CONTENTS Administrative controls ensure that misloading of an MPC will not result l VIOLATIONS in exceeding any of the design limits specified in Table 2-1. The actions l specified in Section 2.2.1 reflect the reporting requirements of 10 CFR 72.75.

References 1. SAR Section 4.2 Trojan ISFSI B2.0-3 Amendment 2 l

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1, 3.0.2, 3.0.4 and 3.0.5 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e.,

when the facility is in the specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to operable status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a cessation of operations may be required to place the system or component in a condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

Trojan ISFSI B3.0-1 Amendment 2 l

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.

The Completion Time of the Required Actions are also applicable when a system or component is removed from service intentionally. The reason for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience.

LCO 3.03 This specification is not applicable to an ISFSI. The placeholder is retained for consistency with the power reactor technical specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in specified conditions in the Applicability when an LCO is not met. It precludes placing the unit in a specified condition stated in that Applicability (e.g., Applicability desired to be entered) when the following exist:

a. Facility conditions are such that the requirements of the LCO would not be met in the Applicability desired to be entered; and

b. Continued noncompliance with the LCO requirements, if the Applicability were entered, would result in the facility being required to exit the Applicability desired to be entered to comply with the Required Actions.

Compliance with the Required Actions that permit continued operation of the facility for an unlimited period of time in a specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the facility. Therefore, in such cases, entry into a specified condition in the Applicability may be made in accordance with the provisions of the Required Actions. The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components before entering an associated specified condition in the Applicability.

Trojan ISFSI B3.0-2 Amendment 2 l

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES The provisions of LCO 3.0.4 shall not prevent changes in specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in specified conditions in the Applicability that are related to establishing and maintaining the spent fuel in an inert atmosphere.

Exceptions to LCO 3.0.4 are stated in the individual Specifications. These exceptions allow entry into specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time. Exceptions may apply to all the ACTIONS or to a specific Required Action of a Specification.

LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or determined to not meet the LCO to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of SRs to demonstrate:

a. The equipment being returned to service meets the LCO: or

b. Other equipment meets the applicable LCOs.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed surveillance. This Specification does not provide time to perform any other preventive or corrective maintenance.

LCO 3.0.6 This specification is not applicable to an ISFSI. The placeholder is retained for consistency with the power reactor technical specifications.

Trojan ISFSI B3.0-3 Amendment 2 l

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCO 3.0.7 This specification is not applicable to an ISFSI. The placeholder is retained for consistency with the power reactor technical specifications.

Trojan ISFSI B3.0-4 Amendment 2 l

Surveillance Requirement Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES SRs SR 3.0.1 through SR 3.0.4 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

SR 3.0.1 SR 3.0.1 establishes the requirement that SRs must be met during the specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify systems, components, and variables are within specified limits. Failure to meet a SR within the specified Frequency, in accordance with SR 3.0.2, constitutes a failure to meet an LCO.

Systems and components are assumed to meet the LCO when the associated SRs have been met. Nothing in this Specification, however, is to be construed as implying that systems or components meet the associated LCO when:

a. The systems or components are known to not meet the LCO, although still meeting the SRs; or

b. The requirements of the Surveillance(s) are known not to be met between required Surveillance performances.

Surveillances do not have to be performed when the facility is in a specified condition for which the requirements of the associated LCO are not applicable, unless otherwise specified.

Unplanned events may satisfy the requirements (including applicable acceptance criteria) for a given SR. In this case, the unplanned event may be credited as fulfilling the performance of the SR. This allowance includes those SRs whose performance is normally precluded in a specified condition.

Surveillances, including Surveillances invoked by Required Actions, do not have to be performed on equipment that has been determined to not meet the LCO because the ACTIONS define the remedial measures that apply.

Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to service.

Trojan ISFSI B3.0-5 Amendment 2 l

Surveillance Requirement Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES Upon completion of maintenance, appropriate post maintenance testing is required. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current specified conditions in the Applicability due to the necessary facility parameters not having been established. In these situations, the equipment may be considered to meet the LCO provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function. This will allow operation to proceed to a specified condition where other necessary post maintenance tests can be completed.

SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a once per... interval.

SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers facility conditions that may not be suitable for conducting the Surveillance (e.g., transient conditions or other ongoing Surveillance or maintenance activities).

The 25% extension does not significantly degrade the reliability that results from performing the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. The exceptions to SR 3.0.2 are those Surveillances for which the 25% extension of the interval specified in the Frequency does not apply. These exceptions are stated in the individual Specifications as a Note in the Frequency stating, SR 3.0.2 is not applicable.

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a once per... basis.

The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function Trojan ISFSI B3.0-6 Amendment 2 l

Surveillance Requirement Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as a convenience to extend Surveillance intervals or periodic Completion Time intervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment as not meeting the LCO or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of 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, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.

This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of facility conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements. When a Surveillance with a Frequency based not on time intervals, but upon specified facility conditions or operational situations, is discovered not to have been performed when specified, SR 3.0.3 allows the full delay period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform the Surveillance.

SR 3.0.3 also provides a time limit for completion of Surveillances that become applicable as a consequence of changes in the specified conditions in the Applicability imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a Trojan ISFSI B3.0-7 Amendment 2 l

Surveillance Requirement Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES flexibility which is not intended to be used as a convenience to extend Surveillance intervals.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered to not meet the LCO or the variable is considered outside the specified limits and the Completion Time of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment does not meet the LCO, or the variable is outside the specified limits and the Completion Time of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a specified condition in the Applicability.

This Specification ensures that system and component requirements and variable limits are met before entry into specified conditions in the Applicability for which these systems and components ensure safe operation of the facility.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components before entering an associated specified condition in the Applicability.

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a change in specified condition. When a system, subsystem, component, device, or variable is outside its specified limits, the associated SR(s) are not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on such equipment. When equipment does not meet the LCO, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillances(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing specified conditions of the Applicability. However, since Trojan ISFSI B3.0-8 Amendment 2 l

Surveillance Requirement Applicability B 3.0 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY BASES the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to specified condition changes.

The provisions of SR 3.0.4 shall not prevent changes in specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in specified conditions in the Applicability that are related to the establishment and maintenance of an inert atmosphere in the MPC. l The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO Applicability, would have its Frequency specified such that it is not due until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs annotation is found in Section 1.4, Frequency.

Trojan ISFSI B3.0-9 Amendment 2 l

MPC Lid Weld Helium Leak Rate l B 3.1.1 B 3.1 MPC INTEGRITY l B 3.1.1 MPC Lid Weld Helium Leak Rate l BASES BACKGROUND The TRANSFER CASK containing an MPC is placed in the spent fuel l pool (i.e., Cask Loading Pit) and loaded with spent fuel (i.e., INTACT FUEL ASSEMBLIES, DAMAGED FUEL ASSEMBLIES, and FUEL l DEBRIS) meeting the requirements specified in Table 2-1 and Fuel l Assembly Inserts meeting the requirements specified in Table 2-2. When MPC loading is complete, the MPC lid is placed onto the MPC prior to l lifting the TRANSFER CASK from the spent fuel pool (i.e., Cask Loading Pit). The TRANSFER CASK containing a loaded MPC is lifted from the l spent fuel pool (i.e., Cask Loading Pit), and moved to the cask preparation area for decontamination and assembly to prepare the MPC for STORAGE l OPERATIONS. The MPC lid is seal welded. To ensure the confinement l integrity of the MPC lid weld, the MPC is hydrotested and helium leak l rate tested. A helium leak detector is used to ensure a leak rate of l

5x10-6atm-cc/sec is not exceeded.

APPLICABLE The confinement of radioactivity during the storage of spent nuclear fuel SAFETY is ensured by the use of multiple confinement barriers and systems. The ANALYSES barriers relied upon are the uranium dioxide fuel pellet matrix, the metallic fuel clad tubes in which the fuel pellets are contained, and the MPC in l which the INTACT FUEL ASSEMBLIES are stored. Long term integrity of the fuel clad depends on storage in an inert atmosphere. This is l accomplished by removing water from the MPC and backfilling it with an l inert gas. The failure of all confinement barriers is considered an l incredible event in the accident analysis (Ref. 1). In addition, the thermal l analysis of the MPC and CONCRETE CASK assumes that the MPC is l filled with dry helium.

DAMAGED FUEL ASSEMBLIES have already released the fission l product gases so they do not have the same confinement requirements of l INTACT FUEL ASSEMBLIES. DAMAGED FUEL ASSEMBLIES and l FUEL DEBRIS have been placed in FAILED FUEL CANS or l DAMAGED FUEL CONTAINERS in designated MPCs. l Short term fuel clad temperatures less than 752EF limit do not result in l degradation of the clad. The maximum fuel clad temperature would occur l Trojan ISFSI B 3.1-1 Amendment 2 l

MPC Lid Weld Helium Leak Rate l B 3.1.1 B 3.1 MPC INTEGRITY l B 3.1.1 MPC Lid Weld Helium Leak Rate l BASES during the vacuum drying process and not during the MPC Lid Weld l Helium Leak Rate check. The maximum fuel clad temperature has been l calculated and found to not exceed the short term fuel clad temperature l limit for the 17.4 kW loaded basket (Ref. 2). l During STORAGE OPERATIONS, the helium atmosphere provides improved heat transfer characteristics which have been credited in the analysis of off-normal and accident conditions (Ref. 1).

LCO Verifying that the MPC is sealed by measuring the lid weld helium leak l rate will ensure that assumptions made in the accident analysis and radiological evaluations are maintained and that the inert gas cover is maintained for the duration of long term storage. The criterion of

5x10-6atm-cc/sec is consistent with the leak rate assumed in the l confinement analysis. As a practical matter, the MPC is leaktight and will l retain all of the helium injected into the MPC cavity during backfill l operations. The LCO does not have to be met until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after l removal of the loaded TRANSFER CASK from the spent fuel pool (i.e.,

Cask Loading Pit).

APPLICABILITY The maximum fuel clad temperature during LOADING OPERATIONS is l 659EF during vacuum drying operations (Ref. 2). Since this maximum l temperature is 93EF below the short term fuel clad temperature limit of l 752EF, no degradation of fuel clad is anticipated. l ACTIONS A Note has been added to the ACTIONS which states that, for this LCO, a separate Condition entry is allowed for each MPC. This is acceptable l since the Required Actions for each Condition provide appropriate compensatory measures for each MPC not meeting the LCO. Subsequent l MPCs that do not meet the LCO are governed by subsequent Condition l entry and application of the associated Required Actions.

Trojan ISFSI B 3.1-2 Amendment 2 l

MPC Lid Weld Helium Leak Rate l B 3.1.1 B 3.1 MPC INTEGRITY l B 3.1.1 MPC Lid Weld Helium Leak Rate l BASES A.1 If the helium leak rate limit is not met, actions must be taken to meet the LCO. A possible corrective action is weld repair. The Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months provides adequate time to correct conditions that would prevent satisfying the MPC lid weld helium leak rate requirements. l Specifying a maximum time for completion ensures that completing the MPC lid leak rate testing is expedited. l B.1 In the event the MPC lid helium leak rate cannot be satisfied within the l allowed Completion Time of ACTION A.1, a cooling flow path will be established to the MPC (Ref. 3). The MPC lid helium leak rate test will be l performed with the MPC filled with water except for approximately 20 l gallons that has been drained. Therefore, it is relatively easy to establish l cooling by recirculating helium or borated water through the MPC cavity. l Establishment of MPC cooling will maintain the fuel clad temperature less l than the 647EF long term storage limit (Ref.4), thereby allowing repair of l the MPC lid weld or helium leak detector as appropriate. The cooling l flow path shall remain available, however, flow may be interrupted to complete MPC lid weld repairs and perform the helium leak rate test. l B.2 In the event the MPC lid helium leak rate cannot be satisfied within the l allowed Completion Time of ACTION A.1, steps will also be taken to return the MPC to the spent fuel pool (i.e., Cask Loading Pit) for l unloading within 30 days. Since cooling of the MPC was reestablished by l ACTION B.1, there is no thermal limit or safety parameter that could be exceeded by not meeting the helium leak rate LCO. Thirty days was Trojan ISFSI B 3.1-3 Amendment 2 l

MPC Cavity Dryness l B 3.1.1 B 3.1 MPC INTEGRITY l B 3.1.1 MPC Lid Weld Helium Leak Rate BASES determined to be reasonable to make welding repairs or obtain replacement parts for the helium leak detector.

SURVEILLANCE SR 3.1.1.1 REQUIREMENTS A primary design consideration of the MPC is that it is leak tight. The l surveillance requirement to verify that the Confinement Boundary helium leak rate is # 5 X 10-6 atm-cc/sec ensures that the assumptions in the l confinement analysis are preserved. The measured leak rate will be a l function of the test pressure and the sensitivity of the instrumentation. The l results at test conditions are corrected for comparison with the 5 X 10-6 l atm-cc/sec LCO limit. l Measurement of the MPC lid weld helium leak rate must be performed l successfully on each MPC prior to performance of MPC cavity l drying. Subsequent to the completion of the MPC cavity drying, the vent l and drain port cover plates are welded in place and helium leak rate l tested. Finally, after the port covers are helium leak rate tested, a l redundant confinement boundary is provided by the closure ring seal l welds. l A Note has been added to the SR to indicate it is not required to be met l until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after the TRANSFER CASK loaded with the MPC has been l removed from the spent fuel pool (i.e., Cask Loading Pit). This allows sufficient time to complete the closure weld, perform the hydrostatic test, and prepare to perform the helium leak rate test.

REFERENCES 1. SAR Sections 8.1.4, 8.2.1, 8.2.2, 8.2.6, and 8.2.7 l

2. SAR Table 4.2-12

3. SAR Section 5.1.1.2

4. SAR Table 3.1-3 l

Trojan ISFSI B 3.1-4 Amendment 2 l

MPC Cavity Dryness l B 3.1.2 B 3.1 MPC INTEGRITY l B 3.1.2 MPC Cavity Dryness l BASES BACKGROUND The TRANSFER CASK containing a MPC is placed in the spent fuel pool l (i.e., the Cask Loading Pit). The MPC is loaded with spent fuel (i.e., l INTACT FUEL ASSEMBLIES, DAMAGED FUEL ASSEMBLIES, and l FUEL DEBRIS) meeting the requirements specified in Table 2-1 and Fuel l Assembly Inserts meeting the requirements specified in Table 2-2. When MPC loading is complete, the lid is placed onto the MPC prior to lifting l the TRANSFER CASK from the spent fuel pool (i.e., Cask Loading Pit).

The TRANSFER CASK containing a loaded MPC is lifted from the spent l fuel pool (i.e., Cask Loading Pit), and moved to the cask preparation area for decontamination and assembly to prepare the MPC for STORAGE l OPERATIONS. Prior to commencement of MPC cavity drying, the top of l the MPC is decontaminated, the lid is seal welded in place, and the helium l leak test is performed on the closure weld of the lid. Once the water is removed from the MPC cavity, drying operations can begin. l The required MPC cavity dryness is obtained by vacuum drying to a l specific pressure. The pressure chosen to ensure that any remaining water l vapor in the cavity is of such a small quantity that it is of no concern for l corrosion. l Vacuum drying is aided by a temperature increase in the MPC due to l heating from the fuel which removes residual moisture. In light of the fact that the helium leak rate test has been performed and the MPC lid is l welded in place, the integrity of the MPC has been demonstrated. l The purpose of the MPC cavity drying process is to remove moisture from l the MPC prior to backfilling it with helium for long-term storage. An l inert environment in the MPC cavity ensures that there will be no l significant corrosion of the fuel clad during STORAGE OPERATIONS at l the ISFSI. l Trojan ISFSI B 3.1-5 Amendment 2 l

MPC Cavity Dryness l B 3.1.2 B 3.1 MPC INTEGRITY l B 3.1.2 MPC Cavity Dryness l BASES APPLICABLE The confinement of radioactivity during the storage of spent nuclear fuel SAFETY is ensured by the use of multiple confinement barriers and systems.

ANALYSES The barriers relied upon are the uranium dioxide fuel pellet matrix, the metallic fuel clad tubes in which the fuel pellets are contained, and the l MPC in which the INTACT FUEL ASSEMBLIES are stored. Long term l integrity of the fuel clad depends on storage in an inert atmosphere. This l is accomplished by removing water from the MPC and backfilling it with l an inert gas. The failure of all confinement barriers is considered an incredible event and is discussed in the accident analysis (Ref. 1). In addition, the thermal analysis of the MPC and CONCRETE CASK assume l that the MPC is filled with dry helium. l DAMAGED FUEL ASSEMBLIES have already released the fission l product gases so they do not have the same confinement requirements of l INTACT FUEL ASSEMBLIES. DAMAGED FUEL ASSEMBLIES and l FUEL DEBRIS have been placed in FAILED FUEL CANS or l DAMAGED FUEL CONTAINERS in designated MPCs. l Short term fuel clad temperatures less than 752EF do not result in gross degradation of the clad. Calculations demonstrate that the maximum l steady state fuel clad temperature that would occur during the vacuum drying process is 659EF for the 17.4 kW loaded basket. This is 93EF less l than the short term fuel clad temperature limit. l LCO A vacuum drying pressure of # 3 torr held for $ 30 minutes assures that l water within the MPC cavity has been evaporated and removed. l Removal of water before filling the MPC with an inert gas ensures l optimum long term storage conditions by inhibiting the potential for fuel clad and confinement boundary degradation. l Fuel clad temperatures are not a concern while the MPC is submerged l within the spent fuel pool (i.e., Cask Loading Pit). However, following Trojan ISFSI B 3.1-6 Amendment 2 l

MPC Cavity Dryness l B 3.1.2 B 3.1 MPC INTEGRITY l B 3.1.2 MPC Cavity Dryness l BASES removal from the spent fuel pool (i.e., Cask Loading Pit), heat transfer is limited with worst case conditions occurring during vacuum drying when conductive heat transfer is limited. Even under these conditions, steady state (i.e., equilibrium) clad temperatures for a 17.4 kW loaded MPC will l not exceed 659EF which is 93EF below the 752EF short term clad l temperature limits identified in Interim Staff Guidance 11, Revision 2.

Although no fuel clad damage is anticipated to occur at temperatures less than 752EF, a 96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months administrative limit to complete the MPC cavity l drying has been established to minimize the time period in which the MPC l cavity atmosphere is not inert. The 96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months administrative limit allows adequate time to complete the MPC preparations and the MPC cavity l drying.

APPLICABILITY This LCO is APPLICABLE during LOADING OPERATIONS but only after the helium leak rate test has been completed. LOADING OPERATIONS begin with the loading of the MPC within the spent fuel l pool (i.e., Cask Loading Pit) and end when the MPC is loaded into a l CONCRETE CASK.

ACTIONS A Note has been added to the ACTIONS which states that, for this LCO, a separate Condition entry is allowed for each MPC. This is acceptable l since the Required Actions for each Condition provide appropriate compensatory measures for each MPC not meeting the LCO. Subsequent l MPCs that do not meet the LCO are governed by subsequent Condition l entry and application of the associated Required Actions.

A.1 If the MPC cavity dryness limit cannot be met, actions must be taken to l meet the LCO. Since the MPC cavity drying process is initiated after the l MPC has been hydrostatically and helium leak rate tested, and the closure l weld dye penetrant tested, there is a high level of assurance that the Trojan ISFSI B 3.1-7 Amendment 2 l

MPC Cavity Dryness l B 3.1.2 B 3.1 MPC INTEGRITY l B 3.1.2 MPC Cavity Dryness l BASES confinement boundary is intact and properly sealed. The most likely mechanism preventing meeting the LCO is a failure of the Vacuum Drying System and/or associated hardware.

Since the maximum steady-state temperature which the spent nuclear fuel would experience during the duration of fuel loading and vacuum drying operations is 659EF (Ref . 2) which is 93EF below the short term fuel clad l temperature limit of 752EF, no degradation of fuel clad is anticipated. A l 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time is considered appropriate for making repairs and correcting failures of the affected components. l B.1.1 and B.1.2 If the Required Action of A.1 cannot be satisfied, either a method of cooling the spent fuel must be established or an inert atmosphere needs to be established for the spent fuel. If the water is not completely drained from the MPC, use of cooling water is desirable to maintain spent fuel l temperatures at lower values. However, once the water has been removed, the most efficient means to protect the spent fuel is by creating an inert atmosphere around the spent fuel. The inert atmosphere will help to remove heat. Cooling the spent fuel can be accomplished by establishing cooling water circulation to the MPC as described in the SAR (Ref. 3). l An inert atmosphere can be established by creating a helium atmosphere in the MPC as described in the SAR (Ref. 3). Either of these actions will l reduce fuel clad temperature and minimize the potential for fuel clad degradation until repairs are completed as necessary to perform MPC l cavity drying until the LCO is satisfied. l B.2 In the event the MPC cavity dryness limit cannot be satisfied within the l allowed Completion Time of ACTION A.1, steps will also be taken to Trojan ISFSI B 3.1-8 Amendment 2 l

MPC Cavity Dryness l B 3.1.2 B 3.1 MPC INTEGRITY l B 3.1.2 MPC Cavity Dryness l BASES return the MPC to the spent fuel pool (i.e., Cask Loading Pit) for l unloading within 30 days. Since cooling of the MPC was reestablished by l ACTION B.1, there is no thermal limit or safety parameter that could be exceeded by not meeting the MPC cavity dryness LCO. Thirty days was l determined to be reasonable to make repairs or obtain replacement parts for the affected components. l SURVEILLANCE SR 3.1.2.1 REQUIREMENTS The long-term integrity of the stored fuel is dependent on storage in a dry, inert environment. Cavity dryness is demonstrated by evacuating the cavity to a very low pressure and verifying that the pressure is held over the specified period of time.

This dryness test must be performed on each MPC within 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months after l verifying the helium leak rate is within limit. A Note has been added to not require the SR be APPLICABLE until 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months after the helium leak rate is acceptable. This allows sufficient time to complete the MPC l preparations and perform the drying operations. The 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months is a l reasonable amount of time to allow the MPC to be without an inert l atmosphere.

REFERENCES 1. SAR 8.2.1 l

2. SAR Table 4.2-12 l

3. SAR 5.1.1.2 l Trojan ISFSI B 3.1-9 Amendment 2 l

TRANSFER CASK Ambient Air Temperature Limit l B 3.2.1 B 3.2 TRANSFER CASK INTEGRITY B 3.2.1 TRANSFER CASK Ambient Air Temperature Limit l BASES BACKGROUND In addition to its functions in the Fuel Building in transporting an MPC l loaded with spent fuel from the spent fuel pool (i.e., Cask Loading Pit) to a CONCRETE CASK, the TRANSFER CASK is used as a support and shielding container in the TRANSFER STATION during the process of transferring an MPC into a Transport Cask. The activities involving the l TRANSFER CASK in the Fuel Building will be in a controlled environment, ensuring that ambient air temperatures are controlled and that solar heating does not become a factor. However, the activities at the TRANSFER STATION will not be in a controlled environment, and ambient air temperatures cannot be controlled. The analysis of the TRANSFER CASK design assumed an ambient air temperature equal to l or greater than 0EF. Since the TRANSFER STATION ambient air l temperatures cannot be controlled, use of the TRANSFER CASK must be restricted to occur only when the ambient air temperature is above this l limit. l APPLICABLE The design characteristics of the TRANSFER CASK are considered in the l SAFETY Safety Analysis for handling spent fuel. Inherent in the design is the ANALYSES assumption that use of the TRANSFER CASK will occur at ambient air l temperatures greater than 0EF. Establishing an ambient air temperature l limit for use of the TRANSFER CASK ensures that its integrity is l maintained and the Safety Analysis is valid.

LCO Limiting use of the TRANSFER CASK to periods when the ambient air temperature is > 0EF ensures the TRANSFER CASK will not fail by l brittle fracture. l APPLICABILITY The APPLICABILITY for this LCO is LOADING, UNLOADING, and STORAGE OPERATIONS. In the event a loaded MPC is to be l transferred into a Transport Cask, the TRANSFER CASK will be used to l support the MPC after it has been raised out of a CONCRETE CASK and l Trojan ISFSI B 3.2-1 Amendment 2 l

TRANSFER CASK Ambient Air Temperature Limit l B 3.2.1 B 3.2 TRANSFER CASK INTEGRITY B 3.2.1 TRANSFER CASK Ambient Air Temperature Limit l BASES until it is lowered back into a Transport Cask at the TRANSFER l STATION. The APPLICABILITY ensures that the LCO applies to all activities involving the use of the TRANSFER CASK.

ACTIONS A.1 and A.2 If ambient air temperature decreases to 0EF or less during use of the l TRANSFER CASK to lift, support, or transport a loaded MPC, l immediate steps will be taken to place the TRANSFER CASK in a safe condition and suspend all further operations involving use of the TRANSFER CASK with a loaded MPC until ambient air temperatures l have returned to greater than 0EF. A safe condition is one in which the l TRANSFER CASK is not being used to lift, support, or transport a loaded l MPC. This may involve unloading the TRANSFER CASK. l SURVEILLANCE SR 3.2.1.1 REQUIREMENTS This SR ensures that the TRANSFER CASK is not used to lift, support, or l transport a loaded MPC whenever the ambient air temperature is outside l its limit at the locations where the TRANSFER CASK is being used prior l to use.

SR 3.2.1.2 This SR ensures that when the TRANSFER CASK is being used to lift, l support, or transport a loaded MPC with an ambient air temperature less l than 5EF, the ambient air temperature is verified greater than 0EF every l four hours at the locations where it is being used.

REFERENCES 1. SAR, Section 4.7.3.1 Trojan ISFSI B 3.2-2 Amendment 2 l

SURVEilLANCE SR3.2.1.1 REQUIREMENTS This SR ensures that the TRANSFER CASK is not used whenever the ambient air temperatures are outside their limits at the locations where the TRANSFER CASK is being used prior to use.

SR 3.2.1.2 This SR ensures that when the TRANSFER CASK is being used with an ambient air temperature greater than 90°F, the ambient air temperature is verified equal to or less than 100 op every four hours at the locations where it is being used.

SR 3.2.1.3 This SR ensures that when the TRANSFER CASK is being used with an ambient air temperature less than 45 °F, the ambient air temperature is verified greater than 40 op every four hours at the locations where it is being used.

REFERENCES 1. SAR, Section 4.7.3.1 Trojan ISFSI B 3.2-3 March 1999

AIR PAD Limits B 3.3.1 B 3.3 AIR PADS B 3.3.1 AIR PAD Limits BASES BACKGROUND The AIR PADS are used to move CONCRETE CASKS (References 1 and 2). The AIR PADS are inserted into the air inlets at the bottom of the CONCRETE CASK. Air compressors are used to inflate and maintain pressure in the AIR PADS. The inflated AIR PADS lift the CONCRETE CASK above the ground and allow it to float on a cushion of air. A transport vehicle is connected to the CONCRETE CASK to move it.

When installed, the AIR PADS partially block the CONCRETE CASK air inlets and reduce the cooling air flow. However, when the AIR PADS are inflated, for analysis purposes, it is assumed that all air flow is blocked even though there is some natural circulation through an unblocked opening and forced air flow from the AIR PAD itself. In either case (i.e.,

AIR PADS installed or inflated), although the air flow from natural draft air flow or forced air flow, respectively, will provide cooling, the extent of that cooling has not been determined.

APPLICABLE The CONCRETE CASK bulk concrete temperature is the limiting thermal SAFETY design parameter (References 3 and 6). Because of the temperature ANALYSES gradient across the concrete, the bulk concrete temperature is difficult to determine and use in analyses. Therefore, the inner concrete temperature is used in lieu of the bulk concrete temperature and is limited to 225EF for long-term normal operational storage (Reference 3). This is conservative since the bulk concrete temperature will not exceed the inner concrete temperature.

In the Full Blockage of Air Inlets accident evaluated in the SAR l (Reference 4), 100EF ambient air and complete air flow blockage of all l inlets is assumed. For a CONCRETE CASK loaded with an MPC with a l 17.4 kW heat load, the inner concrete temperature will increase, reaching l the long-term normal operation storage limit of 225EF in approximately 20 l hours, the short-term off-normal limit of 300EF in approximately 39.5 l hours, and the short-term accident limit of 350EF in approximately 57.1 l hours (Reference 3). In order to prevent the inner concrete temperature from reaching the long-term normal storage limit, installation of the AIR PADS will be restricted to no more than 20 consecutive hours. Twenty l l

Trojan ISFSI B 3.3-1 Amendment 2 l

AIR PAD Limits B 3.3.1 B 3.3 AIR PADS B 3.3.1 AIR PAD Limits BASES l

hours is more than sufficient time to complete the movement of the l CONCRETE CASK using the AIR PADS. However, the analysis shows l that the AIR PADS could be installed for 57 hours6.597222e-4 days 0.0158 hours 9.424603e-5 weeks 2.16885e-5 months without exceeding the l short-term accident limit for concrete. Should the 20 consecutive hours l limit be approached, it is expected the AIR PADS would be removed until l the recirculation is restored and the difficulty in moving the CONCRETE l CASK would be resolved. l Since the Full Blockage of Air Inlets accident evaluated in the SAR l assumes an initial ambient air temperature of 100EF, a 100EF temperature l limit is placed upon installation and use of the AIR PADS on a loaded CONCRETE CASK.

In the Blockage of One-Half of the Air Inlets case in the SAR (Reference 5), which assumes blockage of one-half of the air inlets, for a CONCRETE CASK loaded with an MPC with a 17.4 kW heat load, the inner concrete l temperature will not reach the long-term storage limit of 225EF. This analysis also assumes an initial ambient air temperature of 75EF.

LCO Restricting installation of the AIR PADS to no more than 20 consecutive l hours ensures that the long-term inner concrete storage temperature is not l exceeded and that the CONCRETE CASK is not adversely affected.

Restricting the installation of the AIR PADS on a loaded CONCRETE CASK to periods when the ambient air temperature is less than or equal to 100EF ensures that the long-term inner concrete storage temperature is not l exceeded. l APPLICABILITY The loaded CONCRETE CASKS will only be moved in LOADING, TRANSPORT, or STORAGE OPERATIONS. Therefore, this LCO and SR are only applicable during these conditions.

Trojan ISFSI B 3.3-2 Amendment 2 l

AIR PAD Limits B 3.3.1 B 3.3 AIR PADS B 3.3.1 AIR PAD Limits BASES ACTIONS A.1 If the AIR PADS are installed for more than 20 consecutive hours, the l AIR PADS must be immediately removed. This will reestablish air flow to cool the concrete.

B.1 If ambient air temperature exceeds 100EF, the AIR PADS must be l immediately removed. This will reestablish air flow to cool the concrete and stay within analyzed limits. l SURVEILLANCE SR 3.3.1.1 REQUIREMENTS Since the long term integrity of the concrete is ensured by maintaining its temperature below the specified limits, the length of time during which the AIR PADS can be installed is monitored every 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months while they are l installed.

SR 3.3.1.2 The ambient air temperature is monitored hourly whenever it is greater l than 90EF and the AIR PADS are installed. The long term integrity of the l concrete is ensured by maintaining its temperature below the specified l limits. To ensure the temperature of the concrete does not exceed its l limits, the ambient temperature during the period of time in which the AIR l PADS are installed is monitored hourly when ambient temperature l is > 90EF. l Trojan ISFSI B 3.3-3 Amendment 2 l

AIR PAD Limits B 3.3.1 B 3.3 AIR PADS B 3.3.1 AIR PAD Limits BASES REFERENCES 1. SAR Section 5.1.1.4 l

2. SAR Section 5.2.1.1.8 l

3. SAR Table 4.2-12

4. SAR Section 8.2.7

5. SAR Section 8.1.2.2

6. SAR Table 4.2-2a Trojan ISFSI B 3.3-4 Amendment 2 l

v t e Letter Sequence Approval
EPID:L-2017-LNE-0009, Screenshot/References Used in Environmental Assessment Prepared for the Trojan Independent Spent Fuel Storage Installation License Licensee Renewal Request (Approved, Closed) EPID:L-2017-RNW-0011, Screenshot/References Used in Environmental Assessment Prepared for the Trojan Independent Spent Fuel Storage Installation License Licensee Renewal Request (Approved, Closed)
Initiation Request, Request, Request, Request, Request Acceptance... Administration Questions 23 April 2018 23 April 2018 19 September 2018 31 December 2018 4 February 2019 4 February 2019 19 March 2019 Answers Results Approval, Approval, Approval, Approval, Approval, Approval Other: ML19296B636, ML19296B637
MONTHYEAR2019-02-04 [Table View]

ML19221B650

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