ML19255E988

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Enclosure 18: List of the Changes from CoC 1004 Amendment 15 to Amendment 16
ML19255E988
Person / Time
Site: 07201004
Issue date: 09/03/2019
From:
Orano USA
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML19255E934 List:
References
E-54825
Download: ML19255E988 (21)


Text

Enclosure 18 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 1 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 CoC Condition 1 The Amendment 15 language was redundant to regulations and was replaced by language suggested by the NRC staff, addressing the overarching purpose of the CoC.

CoC Condition 2 The Amendment 15 language was redundant to regulations and was therefore removed.

CoC Condition 3a In Amendment 15, this condition listed the dry shielded canisters (DSCs) and explained their numbering and lettering.

In Amendment 16, this information is retained but in a re-written condition titled TECHNOLOGY and joined with a re-written Amendment 15 Condition 3b, as described next.

CoC Condition 3b In Amendment 15, this condition was a very long and detailed description of the NUHOMS system DSCs, baskets, transfer casks (TCs), and horizontal storage modules.

In Amendment 16, this information is retained but in a re-written, more concise condition titled TECHNOLOGY and joined with Amendment 15 Condition 3a, as discussed above.

The condition regarding the TC design as a lifting device is moved to the new DESIGN FEATURE section of the CoC.

CoC Condition 3c In Amendment 15, this condition described where the system drawings are located in the FSAR. Because this is redundant to the FSAR itself, this condition is removed in Amendment 16.

CoC Condition 3d In Amendment 15, this condition described where the information regarding system basic components that are important to safety is located in the FSAR. Because this is redundant to the FSAR itself, this condition is removed in Amendment 16.

CoC Condition 4 In Amendment 15, this condition cites a reporting regulation.

Because this is redundant to the regulation itself, this condition is removed in Amendment 16 CoC Condition 5 In Amendment 15, this condition cites a reporting requirement if forced cooling is engaged during transfer operations. Because this condition does not meet the graded approach selection criteria, this condition is removed in Amendment 16 CoC Condition 6 In Amendment 15, this condition describes a regulatory requirement.

Because this is redundant to the regulations, this condition is removed in Amendment 16 8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 2 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 CoC Condition 7 (first paragraph)

In Amendment 15, this condition specifies heavy loads requirements. Based on the graded approach selection criteria, this item is moved, unchanged, to TS Section 4, Administrative Controls.

CoC Condition 7 (second paragraph)

In Amendment 15, this condition specifies requirements if a single failure proof crane is not used in conjunction with the OS197L transfer cask. Based on the graded approach selection criteria, this item is moved, unchanged, to TS Section 4, Administrative Controls.

CoC Condition 8 In Amendment 15, this condition specifies pre-operational testing and training exercise requirements. Based on the graded approach selection criteria, this item is moved, unchanged, to TS Section 4, Administrative Controls.

CoC Condition 9 In Amendment 15, this condition specified requirements for 72.212 evaluations for renewed CoC use. In Amendment 16, this condition is unchanged, but is moved to CoC Section III.1.

CoC Condition 10 In Amendment 15, this condition specified requirements for amendments and revisions for the renewed CoC. In Amendment 16, this condition is unchanged, but is moved to CoC Section III.2.

Technical Specification (TS) 1.1 No change, except that based on NRC staff feedback at the public meeting on 02/28/18, the definition for Operability has been added per the example provided in NUREG-1745.

TS 1.2 No change.

TS 1.3 No change.

TS 1.4 No change.

TS 2.1 No change to the TS itself, except that, based on the relocation of TS Table 1-1m, the requirement that The 24PTH-S-LC is only authorized for storage of B&W 15x15 fuel assemblies is added below the DSC model table.

TS 2.1.1 No change.

TS 2.2.1 No change.

TS 2.2.2 Based on the graded approach selection criteria, this NRC-notification requirement item is moved, unchanged, to TS Section 4, Administrative Controls.

8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 3 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 TS 2.2.3 Based on the graded approach selection criteria, this follow-up NRC-notification requirement item is moved, unchanged, to TS Section 4, Administrative Controls.

TS 3.0 No change.

TS 3.1.1 No change.

TS 3.1.2 No change.

TS 3.1.3 No change.

TS 3.1.4 Based on the graded approach selection criteria, this requirement to measure HSM maximum air exit temperature with a loaded DSC is moved to new CoC Appendix A, Inspections, Tests, and Evaluations (ITE) as Item 4.4.

TS 3.2.1 No change.

TS 4.0 This item does not meet any graded approach selection criteria and is therefore removed in Amendment 16.

TS 4.1 (first paragraph and table)

Based on the graded approach selection criteria, these requirements for canister criticality control are moved to new CoC Appendix A, ITE as Item 2.0. The introductory language is restructured. The table is enhanced to account for all DSC models, adding the 24P, 24PHB, 52B.

TS 4.1 (Notes and proposed alternatives provision)

In Amendment 15, this specification cited the UFSAR sections incorporated by reference into the TS, regarding neutron absorber testing and acceptance, and provided a provision for requesting NRC approval of alternatives to the requirements.

Based on the graded approach selection criteria, TN suggested that only the necessary testing be required; TN then proposed what that necessary testing would entail, and NRC concurred.

The UFSAR sections are no longer incorporated by reference.

The testing requirements are included in new CoC Appendix A, ITE as Item 2.1 through 2.4.

TS 4.2.1 (first two paragraphs)

Based on the graded approach selection criteria, the codes and standards for the HSM are moved, unchanged, to CoC Section II.1.a.

8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 4 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 TS 4.2.1 (third paragraph)

Based on the graded approach selection criteria, the requirements for certain HSM subcomponents, if operating in a coastal salt water marine environment, are moved, unchanged, to CoC Section II.1.a.

TS 4.2.2 Based on the graded approach selection criteria, the codes and standards for the DSC are moved, unchanged, to CoC Section II.1.b.

TS 4.2.3 (first two paragraphs and table)

Based on the graded approach selection criteria, the codes and standards for the TC are moved, unchanged, to CoC Section II.1.c.

TS 4.2.3 (last two paragraphs)

Based on the graded approach selection criteria, the codes and standards for the TC are moved, unchanged, to CoC Section II.1.c.

TS 4.2.4 In Amendment 15, this specification contained many tables of ASME Code alternatives and a provision for requesting NRC approval of additional alternatives.

Based on the graded approach selection criteria, all of this would have been moved to the CoC,Section II Design Criteria. Because that many tables would have made the CoC document unwieldy, the tables are contained in new CoC Appendix C, which is indicated in CoC Section II.1.d. The provision for requesting new alternatives is accordingly also located in CoC Section II.1.d.

TS 4.3 Based on the graded approach selection criteria, these storage location design features are moved, unchanged, to CoC Section II.2.

TS 4.3.1 Based on the graded approach selection criteria, these storage location design features are moved, unchanged, to CoC Section II.2.a.

TS 4.3.2 Based on the graded approach selection criteria, this specification is only a statement of fact and is therefore removed in Amendment 16.

TS 4.3.3-1 through 11 Based on the graded approach selection criteria, these site-specific parameters and analyses are moved, unchanged, to new CoC Appendix A ITE as Item 3.1.

TS 4.4 Based on the graded approach selection criteria, these transfer cask design features are moved, unchanged, to CoC Section II.3.b, except for the heat loads, which are found in TS figures, and are therefore removed in this CoC condition.

TS 4.4.1 Based on the graded approach selection criteria, these transfer cask design features are moved, unchanged, to CoC Section II.3.b.1.

8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 5 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 TS 4.4.2 Based on the graded approach selection criteria, these transfer cask design features are moved, unchanged, to CoC Section II.3.b.2.

TS 4.4.3 Based on the graded approach selection criteria, these transfer cask design features are moved, unchanged, to CoC Section II.3.b.3.

TS 4.4.4 Based on the graded approach selection criteria, these transfer cask design features are moved, unchanged, to CoC Section II.3.b.4.

TS 4.5 Based on the graded approach selection criteria, the first requirement, involving leakage testing of the confinement boundary during fabrication, is moved to new CoC Appendix A ITE as the first part of Item 4.1.

The second requirement is not a requirement, but rather is a statement, and is therefore removed in Amendment 16.

TS 5.1 In Amendment 15, this TS Section 5 administrative control specification requires certain procedures. The first paragraph is retained and is in Amendment 16 TS Section 4, the new section for administrative controls.

The list of areas for which procedures are required is redundant to other requirements and is therefore removed in Amendment 16.

The remaining information is somewhat redundant to UFSAR operating procedures chapters, but those chapters are updated for any non-redundant information (e.g., UFSAR Section K.8.2.1, passages between Steps 14 and 15).

TS 5.1.1 These Amendment 15 provisions for a program for DSC loading, unloading and preparation are redundant to other TS or regulations and are therefore removed in Amendment 16.

TS 5.1.2 Items 1 and 3 of this ISFSI operations program are simply verifications that certain other TS are met. Those TS stand on their own merit and Items 1 and 3 therefore serve no purpose and are removed in Amendment 16.

Item 2, a verification of consistency with certain UFSAR analysis, is maintained in the Amendment 16 TS, as administrative control 4.4.1.C.

TS 5.1.3 In Amendment 15, this TS addresses aging management program procedures and reporting. Amendment 16 retains this requirement, as administrative control TS 4.2.2.

8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 6 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 TS 5.2 (Introduction)

This TS requires implementation of certain programs. This TS is retained in Amendment 16 as administrative control TS 4.3 and lists the programs which remain in the TS.

TS 5.2.1 This TS describes a 10 CFR 72.48 program and is totally redundant to the regulation. The TS is removed in Amendment 16.

TS 5.2.2 In Amendment 15, this TS provided training program requirements.

Based on the graded approach selection criteria, these training program requirements are moved to UFSAR Section 9.3 TS 5.2.3 In Amendment 15, this TS establishes a program similar to that required by 10 CFR 72.44(d)(2) for specific licenses. Based on the graded approach selection criteria, Amendment 16 retains this requirement, as administrative control TS 4.3.1.

TS 5.2.4 (Introduction)

This TS introduces the radiation protection program and is redundant to regulations. The TS is removed in Amendment 16.

TS 5.2.4.a Based on the graded approach selection criteria, in Amendment 16 these specific radiation protection program requirements are retained as administrative control TS 4.3.2.

TS 5.2.4.b Based on the graded approach selection criteria, in Amendment 16 these DSC closure weld NDE requirements are retained as CoC new Appendix A ITE Item 4.3.

TS 5.2.4.c Based on the graded approach selection criteria, in Amendment 16 these DSC inner seal weld leak testing requirements are retained as CoC new Appendix A ITE 4.1.

TS 5.2.4.d Based on the graded approach selection criteria, in Amendment 16 this check for TC/DSC contamination has been converted to a limiting condition for operation (LCO) as TS 3.3.1.

TS 5.2.4.e Based on the graded approach selection criteria, in Amendment 16 these transfer cask dose rate measurement requirements are retained as CoC new Appendix A ITE 3.2.

TS 5.2.5 Associated with request for additional information (RAI) Th-1, based on the graded approach selection criteria, in Amendment 16 these HSM thermal monitoring program requirements are retained as TS 4.3.6.

8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 7 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 TS 5.2.6 Based on the graded approach selection criteria, in Amendment 16 these hydrogen gas monitoring requirements are retained as administrative control TS 4.3.3. Because they apply to all DSC models, the list of specific models is removed in Amendment 16.

TS 5.3.1 Based on the graded approach selection criteria, in Amendment 16 these TC/DSC lifting and handling height limits are retained as administrative control TS 4.4.1.

TS 5.3.2 Based on the graded approach selection criteria, these cask drop requirements are moved to UFSAR operating procedure chapters (e.g., Chapter K.8, Section K.8.1.2 Step 10a).

TS 5.3.3 Based on the graded approach selection criteria, these transfer cask alignment with the HSM requirements are moved to UFSAR operating procedure chapters (e.g., Chapter K.8, Section K.8.1.6 Step 14).

TS 5.3.4 Based on the graded approach selection criteria, in Amendment 16 these requirements associated with a trailer shielding drop onto an OS197L transfer cask are retained as administrative control TS 4.4.2.

TS 5.4 Based on the graded approach selection criteria, in Amendment 16 these HSM dose rate evaluation requirements are retained as CoC new Appendix A ITE 3.3.

TS 5.5 Based on the graded approach selection criteria, in Amendment 16 these HSM-H concrete testing requirements are retained as CoC new Appendix A ITE 4.2.

TS 5.6 Based on the graded approach selection criteria, in Amendment 16 these HSM-H configuration change restrictions are retained as administrative control TS 4.5.

8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 8 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 Table 1-1a Mostly retained in TS. The following characteristics have been removed from the TS table but remain in UFSAR Table 3.1-1:

Maximum Assembly Length (unirradiated)

Nominal Cross-Sectional Envelope Maximum Assembly + BPRA Length (unirradiated)

With Burnup > 32,000 and 45,000 MWd/MTU With Burnup 32,000 MWd/MTU Nominal Cross-Sectional Envelope The following parameters were added:

Minimum Cooling Time Maximum Burnup Minimum Assembly Average Initial Enrichment Decay Heat (Fuel + BPRA)

Table 1-1b Mostly retained in TS. The following characteristics have been removed from the TS table but remain in UFSAR Table 3.1-2:

Maximum Assembly Length (unirradiated)

Nominal Cross-Sectional Envelope The parameter Assembly Average Burnup, Initial Enrichment, and Cooling Time was changed to:

Minimum Cooling Time Maximum Burnup Minimum Assembly Average Initial Enrichment Decay Heat Table 1-1c Mostly retained in TS. The following characteristics have been removed from the TS table but remain in UFSAR Table K.2-3:

Maximum assembly length Nominal assembly width (excluding channels)

The following Alternate Radiological parameters were deleted:

Fuel Burnup, Initial Assembly Average Enrichment, Cooling Time Maximum Initial Uranium Content Maximum Decay Heat The following Alternate Radiological parameters were added:

Maximum Decay Heat (excluding transfer in OS197L)

Maximum Decay Heat for Transfer in OS197L Minimum Cooling Time, Maximum Burnup Minimum Assembly Average Initial Enrichment 8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 9 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 Table 1-1d Based on the graded approach selection criteria, this TS table, which is redundant to UFSAR Table K.2-3, is deleted from TS in Amendment 16.

Table 1-1e Mostly retained in TS. Deleted reference to Table 1-1f in Fuel Assembly Class parameter text.

Deleted parameters:

Allowable heat load zoning configurations for each 32PT DSC per Figure 1-2, Figure 1-3, Figure 1-4 and Figure 1-4a For a 32PT DSC contained in an OS197L TC, the heat load zoning configuration is per Figure 1-30 Added the following parameters:

Fuel Cladding, Minimum Cooling Time (excluding transfer in OS197L)

Maximum Burnup (excluding transfer in OS197L)

Minimum Assembly Average Initial Enrichment (excluding transfer in OS197L)

Decay Heat (excluding transfer in OS197L)

Minimum Cooling Time for transfer in OS197L Maximum Burnup for transfer in OS197L Minimum Assembly Average Initial Enrichment for transfer in OS197L Decay Heat for transfer in OS197L Table 1-1f Deleted and moved to UFSAR Table M.2-2 (32PT).

The maximum uranium content (MTU/assembly) for the 32PT DSC is moved to TS fuel specification Table 1-1e.

Table 1-1g No change Table 1-1g1 No change Table 1-1g2 No change Table 1-1g3 No change Table 1-1h No change 8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 10 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 Table 1-1i The following parameters were deleted and have been moved from the TS to the UFSAR Table N.2-1:

Physical Parameters (without CCs)

Physical Parameters (with CCs)

Nominal Cross-Sectional Envelope The following Nuclear parameters were changed from:

Burnup, Enrichment, and Minimum Cooling Time for Configuration 1 (Figure 1-8)

Burnup, Enrichment, and Minimum Cooling Time for Configuration 2 (Figure 1-9)

To:

Minimum Cooling Time Maximum Burnup Minimum Assembly Average Initial Enrichment Only the 1.3 kW FQT (Table 1-2p) is retained in the TS. The remaining fuel qualification tables are deleted from the TS and placed in UFSAR Appendix N.2.

Table 1-1j Mostly retained in TS. Deleted reference to Table 1-1d in Fuel Design parameter.

The following characteristics have been removed from the TS table but remain in UFSAR Table K.2-3:

Maximum assembly length (unirradiated)

Nominal assembly width (excluding channels)

The following parameters were changed from:

Fuel Burnup, Initial Assembly Average Enrichment, and Cooling Time Maximum Decay Heat To:

Minimum Cooling Time Maximum Burnup Minimum Assembly Average Initial Enrichment Maximum Decay Heat (excluding transfer in OS197L)

Maximum Decay Heat for Transfer in OS197L Table 1-1k No change 8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 11 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 Table 1-1l Deleted reference to Table 1-1m in Fuel Design parameter.

The following characteristic has been deleted and moved from the TS to UFSAR Appendix P.2:

Nominal Assembly Width for Intact and Damaged Fuel Only The following parameters were added:

Maximum Initial Uranium Content Fuel Cladding The following parameters were changed from:

Allowable heat load zoning configurations for each 24PTH DSC are Figure 1-11, Figure 1-12, Figure 1-13, Figure 1-14, Figure 1-15, or Figure 1-15a To:

Minimum Cooling Time Maximum Burnup Minimum Assembly Average Initial Enrichment The 1.5 kW FQT is retained in the TS for the 24PTH-S-LC DSC, and the 2.0 and 2.5 kW FQTs are retained for the 24PTH-S/-L DSCs.

The remaining fuel qualification tables are deleted from the TS and placed in UFSAR Appendix M.2.

Table 1-1m Deleted and moved to UFSAR Table P.2-3 (24PTH).

The maximum uranium content (MTU/assembly) for the 24PTH DSC is moved to TS fuel specification Table 1-1l.

Table 1-1n Title updated and the following parameter was deleted: Decay Heat (Watts/DSC). This information has been moved to the UFSAR in the following tables: Table P.2-2 (24PTH) and Table N.2-2a (24PHB).

Table 1-1o Not used Table 1-1p No change Table 1-1q No change Table 1-1q1 No change Table 1-1r No change Table 1-1s Deleted 8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 12 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 Table 1-1t The following parameter was added:

Fuel Cladding The following parameters were changed from:

Burnup, Enrichment, and Minimum Cooling Time for Heat Load Zoning Configurations 1 through 10 Burnup, Enrichment, and Minimum Cooling Time for fuel with 20 GWd/MTU and 0.5 to 0.9 wt. % in all Heat Load Zoning Configurations To:

Minimum Cooling Time Maximum Burnup Minimum Assembly Average Initial Enrichment The 0.54 kW and 1.2 kW FQTs are retained in the TS. The remaining fuel qualification tables are deleted from the TS and placed in UFSAR Appendix T.2.

Table 1-1u Deleted. This information has been moved to UFSAR Table T.2-2.

Table 1-1v No change Table 1-1w No change Table 1-1w1 No change Table 1-1x No change Table 1-1y Not used Table 1-1z Not used 8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 13 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 Table 1-1aa Deleted reference to Table 1-1bb in Fuel Assembly Class parameter text.

The following parameters were added:

Fuel Cladding Maximum Initial Uranium Content The following parameters were changed from:

Allowable heat load zoning configurations for each 32PTH1 DSC are Figure 1-26, Figure 1-27, Figure 1-28, Figure 1-28a, Figure 1-28b, or Figure 1-28c To:

Minimum Cooling Time Maximum Burnup Minimum Assembly Average Initial Enrichment The 1.5 kW FQT is retained in the TS (Table 1-3k and Table 1-3p (32PTH1 DSC column)). The remaining fuel qualification tables are deleted from the TS and placed in UFSAR Appendix M.2.

Table 1-1bb Deleted. This information was moved to UFSAR Table U.2-3 (32PTH1).

The maximum uranium content (MTU/assembly) for the 32PTH1 DSC is moved to TS fuel specification Table 1-1aa.

Table 1-1cc No change Table 1-1dd No change Table 1-1dd1 No change Table 1-1ee Title updated and the following parameter was deleted: Decay Heat (Watts/DSC). This information has been moved to the UFSAR in the following tables: Table M.2-2a (32PT) and Table U.2-2 (32PTH1).

Table 1-1ff No change 8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 14 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 Table 1-1gg Deleted reference to Table 1-1ii in Fuel Assembly Class parameter text.

The following parameters were deleted:

Fissile Material UO2 The following parameters were added:

Fuel Cladding Maximum Initial Uranium Content The following parameters were changed from:

Burnup, Enrichment, and Minimum Cooling Time for Heat Load Zoning Configurations 1 through 7 Burnup, Enrichment, and Minimum Cooling Time for fuel with 20 GWd/MTU and 0.5 to 0.9 wt. % in all Heat Load Zoning Configurations To:

Minimum Cooling Time Maximum Burnup Minimum Assembly Average Initial Enrichment The 0.6 kW and 0.9 kW FQTs (Table 1-7k and Table 1-7m) are retained in the TS. The remaining fuel qualification tables are deleted from the TS and placed in UFSAR Appendix Y.2.

Table 1-1hh Not used Table 1-1ii Deleted. This information was moved to UFSAR Table Y.2-2 (69BTH).

Table 1-1jj No change Table 1-1kk No change 8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 15 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 Table 1-1ll Deleted reference to Table 1-1nn in Fuel Assembly Class parameter text.

The following parameter was deleted and has been moved from the TS to the UFSAR Appendix Z.2:

Fissile material The following parameter was added:

Fuel Cladding The following parameter was changed from:

Allowable heat load zoning configurations for each 37PTH DSC per Figure 1-39 or Figure 1-40 To:

Minimum Cooling Time Maximum Burnup Minimum Assembly Average Initial Enrichment The 1.2 kW FQT is retained in the TS (Table 1-3i and Table 1-3p (37PTH DSC column)). The remaining fuel qualification tables are deleted from the TS and placed in UFSAR Appendix M.2.

Table 1-1mm Not used Table 1-1nn Deleted. This information was moved to UFSAR Table Z.2-3 (37PTH).

Table 1-1oo No change Table 1-1pp No change Table 1-1qq Title updated and the following parameter was deleted: Decay Heat (Watts/DSC). This information has been moved to the UFSAR in the following table: Table Z.2-2 (37PTH).

Table 1-1rr No change Table 1-1ss No change TS Table 1-2a Based on the graded approach selection criteria and the approach to fuel qualification, no changes were made to this table.

TS Table 1-2b Based on the graded approach selection criteria and the approach to fuel qualification, no changes were made to this table.

8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 16 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 TS Table 1-2c Based on the graded approach selection criteria and the approach to fuel qualification, no changes were made to this table.

TS Tables 1-2d thru 1-2m Not used.

TS Table 1-2n Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is N.2-3.

TS Table 1-2o Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is N.2-4.

TS Table 1-2p Based on the graded approach selection criteria and the approach to fuel qualification, this table is related to the bounding source terms and is therefore retained in the TS; no changes were necessary for this table.

TS Table 1-2q Based on the graded approach selection criteria and the approach to fuel qualification, no changes were made to this table.

TS Table 1-3a Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is M.2-5.

TS Table 1-3b Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is M.2-6.

TS Table 1-3c Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is M.2-7.

TS Table 1-3d Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is M.2-8.

8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 17 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 TS Table 1-3e Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is M.2-9.

TS Table 1-3f Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is M.2-10.

TS Table 1-3g Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is M.2-11.

TS Table 1-3h Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is M.2-12.

TS Table 1-3i Based on the graded approach selection criteria and the approach to fuel qualification, this table is related to the bounding source terms and is therefore retained in the TS. A change was necessary for this table to identify the specific related DSC, the 37PTH.

TS Table 1-3j Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is M.2-14.

TS Table 1-3k Based on the graded approach selection criteria and the approach to fuel qualification, this table is related to the bounding source terms and is therefore retained in the TS. A change was necessary for this table to identify the specific related DSCs, the 24PTH-S-LC and the 32PTH1.

TS Table 1-3l Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is M.2-14b.

8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 18 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 TS Table 1-3m Based on the graded approach selection criteria and the approach to fuel qualification, this table is related to the bounding source terms and is therefore retained in the TS. A change was necessary for this table to identify the specific related DSCs, the 24PTH-S and the 24PTH-L.

TS Table 1-3n Based on the graded approach selection criteria and the approach to fuel qualification, this table is related to the bounding source terms and is therefore retained in the TS. A change was necessary for this table to identify the specific related DSC, the 32PT.

TS Table 1-3o Based on the graded approach selection criteria and the approach to fuel qualification, this table is related to the bounding source terms and is therefore retained in the TS. A change was necessary for this table to identify the specific related DSCs, the 24PTH-S and the 24PTH-L.

TS Table 1-3p Based on the graded approach selection criteria and the approach to fuel qualification, this table is related to bounding source terms and is therefore partially retained in the TS. A change was necessary for this table to restructure the retained information and to identify the specific related DSCs, the 24PTH, the 32PT, the 32PTH1, and the 37PTH.

TS Table 1-3 notes The table notes are changed due to the changed number of tables to which they apply.

TS Tables 1-5a thru 1-5g Not used.

TS Table 1-4a Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is T.2-5.

TS Table 1-4b Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is T.2-6.

TS Table 1-4c Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is T.2-7.

8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 19 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 TS Table 1-4d Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is T.2-8.

TS Table 1-4e Based on the graded approach selection criteria and the approach to fuel qualification, this table is related to the bounding source terms and is therefore retained in the TS. A change was necessary for this table to specify a minimum 3 year cooling time for certain burnups and enrichments.

TS Table 1-4f Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is T.2-10.

TS Table 1-4g Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is T.2-16.

TS Table 1-4h Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is T.2-17.

TS Table 1-4i Based on the graded approach selection criteria and the approach to fuel qualification, this table is related to the bounding source terms and is therefore retained in the TS; no changes were necessary for this table.

TS Table 1-4 notes The table notes are changed due to the changed number of tables to which they apply.

TS Table 1-6a Based on the graded approach selection criteria and the approach to fuel qualification, no changes were made to this table.

TS Table 1-6b Based on the graded approach selection criteria and the approach to fuel qualification, no changes were made to this table.

TS Table 1-6c Based on the graded approach selection criteria and the approach to fuel qualification, no changes were made to this table.

TS Table 1-6d Based on the graded approach selection criteria and the approach to fuel qualification, no changes were made to this table.

8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 20 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 TS Table 1-6 notes Based on the graded approach selection criteria and the approach to fuel qualification, no changes were made to these table notes.

TS Table 1-7a Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is Y.2-5.

TS Table 1-7a1 Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is Y.2-6.

TS Table 1-7b Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is Y.2-7.

TS Table 1-7c Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is Y.2-8.

TS Table 1-7d Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is Y.2-9.

TS Table 1-7e Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is Y.2-10.

TS Table 1-7f Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is Y.2-11.

TS Table 1-7g Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is Y.2-12.

8 to E-54825 List of the Changes from CoC 1004 Amendment 15 to Amendment 16 Page 21 of 21 Changed Area of Amendment 15 Description of Change in Amendment 16 TS Table 1-7h Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is Y.2-13.

TS Table 1-7i Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is Y.2-14.

TS Table 1-7j Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is Y.2-15.

TS Table 1-7k Based on the graded approach selection criteria and the approach to fuel qualification, this table is related to the bounding source terms and is therefore retained in the TS. A change was necessary for this table to specify a minimum 3 year cooling time for certain burnups and enrichments.

TS Table 1-7l Based on the graded approach selection criteria and the approach to fuel qualification, this table is not related to the bounding source terms and is therefore removed from the TS. The corresponding UFSAR Table is Y.2-17a.

TS Table 1-7m Based on the graded approach selection criteria and the approach to fuel qualification, this table is related to the bounding source terms and is therefore retained in the TS. A change was necessary for this table to specify a minimum 3 year cooling time for certain burnups and enrichments.

TS Table 1-7 notes The table notes are changed due to the changed number of tables to which they apply.

TS Figures No changes were made to the existing figures in the Amendment 15 TS.

Related to the response to RAI Sh-1, two new figures were added.

Figures 1-16a and 1-25c, which show the location of peripheral and inner fuel locations in the 24PTH and 61BTH DSCs, respectively, were added as a result of the movement of most fuel qualification tables (FQTs) to the UFSAR, with the associated fuel specification tables (Table 1-1l and 1-1t, respectively) changed to refer to these figures.