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NRC-2019-000246 - Resp 2 - Final, Agency Records Subject to the Request Are Enclosed. Part 9 of 19
	ML19346E421
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Issue date:	12/05/2019
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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC F'f':013RIETAR:Y INFORMAT ION LICENSING REPORT on The HI-STORE CIS FACILITY by Holtec International Holtec Center One Holtec Drive Marlton, NJ 08053, USA (holtecinternational.com)

USNRC Docket# 72-1051 Holtec Project 5025 Holtec Report# HI-2167374 Safety Category: Safety Significant Page 1 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOL'fEC PROPR:IE'fAR:'1' INFORMATION GLOSSARY OF TERMS USED IN HI-STORE CIS FACILITY LICENSING REPORT Accident Condition Storage Temperature is the max imum 24 hour- average of the ambient temperature at an ISFSI site. The accident condition temperature serves as the input air temperature for a cask system to compute the accident condition peak cladding temperature for which a regulatory limit is specified in ISG 11 Rev 3.

AFR is an acronym for Away from Reactor storage.

Aging Management Program (AMP), outlined in Chapter 18, is a carefull y crafted collection of processes and procedures deemed to be necessary for an effective monitoring, inspection, testing and recovery/remediation plan for the ISFSI to ensure safe operation for its entire Service life.

ALARA is an acronym for As Low- As - Reasonably- Achievable Ambient Temperature for Short Term Operations (operations involving use of a transport cask, a Lifting device and/ or a on-site transport device) is defi ned as the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months average of the local temperature as forecast by the National Weather Service.

Ancillary or Ancillary Equipment is the generic name of a device used to carry out "Short Term Operations.

BWR is an acronym for Boiling Water Reactor.

Canister means an all-welded vessel containing used fuel that has been qualified to serve as a confinement boundary under the rules of 10CFR 72. The terms MPC, DSC, etc., are also used to indicate a seal-welded spent fuel canister.

Canister Transfer Facility (CTF) is a below-grade placement location where the transport cask is temporarily pl aced to effectuate vertical canister transfer between the transport cask and the HI-TRAC CS.

Canister Transfer means transfer operations necessary to translocate a loaded canister between a transport cask, HI-TRAC CS and/or the HI-STORM UMAX storage system.

Cask Crane is the gantry crane installed in the Cask Transfer Building for heavy load hand ling activities Cask Receiving Area is the physical location where loaded casks are received. Consists of a vehicle entrance, vehicle parking area, VCT access port, cask and cask appurtenance lifting apparatus, cask tilting apparatus, location for storage of cask transport appurtenances (e.g.,

personnel banier, impact limiters, etc.), location for cask lid removal and installation, location for transfer of the cask to the VCT, cask inspection and work area. The cask receiving area may be partially or completely enclosed.

Cask Transfer Building (CTB) means the sheet metal enclosure that houses the Canister Transfer Facil ity (CTF) and the cask receiving area and prov ides storage space for anci llary equipment used in short term operations.

Page 2 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMAT ION Cavity Enclosure Container (CEC) means a thick-walled cylindrical steel weldment that defines the storage cavity in HI-STORM UMAX for the storage of the canister.

CG is an acronym for the center- of- gravity.

Closure Lid means the METCON lid that is installed on the CEC to provide physical and shielding protection to the stored canister.

Commercial Spent Fuel (CSF) refers to nuclear fuel used to produce energy in a commercial nuclear power plant.

Confinement Boundary means the outline formed by the cylindrical enclosure of the canister shell welded to a solid baseplate, and at least one top lid to create a hermetically sealed enclosure.

Confinement System means the canister which encloses and confines the spent nuclear fuel during storage.

Container Flange means the ring fl ange that is welded to the upper extremity of the Container Shell.

Container Shell means the cylindrical portion of the Cavity Enclosure Container Controlled Area means that area immediately sunounding the ISFSI over which the HI-STORE Facility owner (Holtec) exercises authority over its use and within which all Short Term Operations are performed.

Controlled Low-Strength Material (CLSM) is a self-compacted, ceme ntitious material used primarily as a backfill in place of compacted fill. Many terms are currently used to describe this material , such as flowab le fill, unshrinkable fi ll , controlled density fi ll, flowable mortar, flowable fly ash, fly ash slurry, plastic soil-cement and soil-cement sluny (ACI 229R-99). CLSM and lean concrete are also referred to as "Self-hardening Engineered Subgrade (SES)"

Cooling Time (or post-irradiation cooling time) for a spent fuel assembly is the time elapsed after its discharge from the reactor to the time it is loaded into the canister.

Critical Characteristic means a feature of a SSC that is necessary for the proper safety function of the SSC. Critical characteristics of a material are those attributes that have been identified, in the associated material specification, as necessary to render the material 's intended function.

Design Basis Earthquake (DBE) is the seismic input applicable to the cask's long term storage on the ISFSI pad.

Design Basis Load (DBL) is a loading defined in this SAR to bound one or more events that are applicable to the storage system during its service life. Thus, the snow pressure loading on the cask's lid specified in this SAR is a DBL because it is set substantially above the pressure from accumulated snow set down in the national consensus standard for the 48 contiguous United States.

Design Basis Missile (DBM) is the applicable missiles used to evaluate the safety of the storage system Page 3 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMATIOM Design Extended Condition Earthquake (DECE) is a beyond design basis seismic input that exceeds the 10,000 year return earthquake at the site.

Design Heat Load or Design Basis Heat Load is the computed heat rejection capacity of the HI-STORM system with a certified canister loaded with CSF stored in uniform storage with the ambient at the normal tem perature and the peak cladding temperature (PCT) at 400°C. The Design Heat Load is less than the thermal capacity of the system by a suitable margin that reflects the conservatism in the system thermal analysis ..

Design Life is the minimum duration for which the SSC or Facility is engineered to perform its intended function set forth in this SAR, if operated and maintained in accordance with this document.

Design Report is a document prepared, reviewed and QA validated in accordance with the provisions of 10CFR72 Subpart G. The Design Report shall demonstrate compliance with the requirements set forth in the Design Specification. A Design Report is mandatory for systems, structures, and components (SCCs) designated as Important to Safety. This SAR serves as the Design Report for the HI-STORE Facility.

Design Specification is a document prepared in accordance with the quality assurance requirements of 10CFR72 Subpart G to provide a complete set of design criteria and functional requirements for a system, structure, or component or Facility intended to be used in the operation, of the HI-STORE CIS Facility. This document serves as the Design Specification for the HI-STORE CIS Facility.

Divider Shell means a cylindrical shell bearing insulation over most of its inner or outer surface that divides the annular space between the canister and the CEC shell into two discrete regions for down- flow and up-flow of air in the HI-STORM UMAX VVM.

Dry Cask Storage System (DCSS) is a system that stores spent fuel or high level waste in a dry condition.

Enclosure Vessel means the pressure vessel defined by the cylindrical shell, baseplate, top lid and associated welds that provides confinement for the helium gas contained within the canister.

The E nclosure Vessel (EV) and the fuel basket together constitute the canister.

Equivalent (or Equal) Material is a material with critical characteristics (see definition above) that meet or exceed those specified for the designated material.

Facility is used as a n abbreviated name for the HI-STORE Consolidated Interim Storage facility Fracture Toughness is a property which is a measure of the ability of a material to limit crack propagation under a suddenly applied load.

FSAR is an acronym for Final Safety Analysis Report (10CFR72).

Fuel Basket means a honeycombed structural weldment with square openings which can accept a fuel assembly of the type for which it is designed.

Gantry Crane is the device used in conjunction with special lifting devices that perform elements of the cask lifting operations in the Cask Receiving Area.

Page 4 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 l:lOLTEC PROPRIETARY INFORMATION High Burnup Fuel (HBF) refers to fuel with a bumup greater than 45,000 MWD/MTU HI-STORE or HI-STORE CIS is the consolidated interim storage facility envisaged to be built and operated in Southeastern New Mexico.

HI-STORM VVM means the vertical ventilated module wherein the canister is stored in the upright orientation.

HI-STORM UMAX System consists of loaded canisters stored in the HI-STORM UMAX VVM under Docket Number 72-1040.

HI-STORM 100 System co nsists of any loaded canister model placed within any design variant of the HI-STORM overpack in Docket Number 72-1014.

HI-STORM FW System is the larger capacity, variable height counterpart of the HI-STORM 100 system certified in Docket Number 72-1032 HI-TRAC CS is the shielded transfer cask used for performing canister transfer between the transport cask and the HI-STORM UMAX system at HI-STORE.

Holtite7M is the trademarked name of a family of neuu*on shield materials owned by Holtec International.

HP is an acronym for Health Physics HS is an acronym for HI-STORE Specific, used in relation to the ancillaries at the facility.

Important to Safety (ITS) means a SSC function or condition required to store spent nuclear fuel safely; to prevent damage to spent nuclear fuel during handling and storage, and to provide reasonable assurance that spent nuclear fuel can be received, handled, packaged, stored, and retrieved without undue risk to the health and safety of the public.

Independent Spent Fuel Storage Installation (ISFSI) means a facility designed, constructed, and licensed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage in accordance with 10CFR72. An ISFSI may be located at a nuclear plant or at an AFR.

Interim Storage means an a utonomous monitored canister storage facility from which the stored canister can be retrieved, if necessary.

Interfacing Components means the weldments certified in other dockets that will be used with the HI-STORM UMAX VVM assemblies for transferring and storing canisters in at the HI-STORE Facility. The canister is an Interfacing Component.

ISFSI Pad means the reinforced concrete pad that defines the top extremity of the HI-STORM UMAX VVM and provides the support surface for the cask handling device.

License Life means the duration for which the system is authorized by virtue of its certification by the U.S. NRC.

Licensing Drawings or Licensing Drawing Package is an integral part of this SAR wherein the essential geometric and material information on HI-STORM UMAX is compiled to enable the safety evaluations pursuant to 10CFR72 to be carried out.

Page 5 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOL.TeC PROPRleT/1.RY lf>lf=ORM.'\TION Long-term Storage means the period of passive storage in the HI-STORM UMAX VVMs at the AFR facility.

Lowest Service Temperature (LST) is the minimum metal temperature of a part for the specified service condition.

METCON means a steel structure fortified by plain concrete.

Mined Geological Disposal System (MGDS) is a nuclear waste repository excavated deep within a stable geologic environment MSE is an acronym for "Most Severe Earthquake," utilized to denote the ultra-high earthquake resistant options used in the HI-STORM UMAX generic license. These options are not cmTently utilized at the HI-STORE facility.

Nil Ductility Transition Temperature (NDT) is defined as the temperature at which the fracture stress in a material with a small flaw is equal to the yield stress in the same material if it had no flaws.

Neutron Absorber is a generic term used in this SAR to indicate any neutron absorber material qualified for use in the canister certified for storage in the HI-STORM UMAX VVM.

Neutron Shielding means a material used to thermalize and capture neutrons emanating from the radioactive spent nuclear fuel.

Normal Storage Condition temperature refers to the integrated time average of the annual ambient temperature at an ISFSI site. It is used, as prescri bed in ISG11Rev3 and NUREG-1536, as the reference air inlet temperature in the ventilated cask's thermal analysis for computing the fuel cladding temperature. In non-ventilated casks, it is used as the surrounding ambient temperature for the thennal analysis of the cask under the so-called normal condition of storage.

Off-Normal Storage Condition refers to the highest three- day average of ambient air temperature at an ISFSI site. The off-normal temperature serves as the air temperature for computing the off-normal peak cladding temperature in a cask system for which an explicit cladding temperature limit is specified in ISG 11 Rev3.

Operating Basis Earthquake is the three-dimensional seismic motion that is assumed to apply to any site activity whose duration exceeds one work shift. For conservatism, the OBE is set equal to the bounding value of 1000 year return earthquake for the HI-STORE site.( Short duration activities lasting less than a work shift are considered seismic-exempt operations)

Plain Concrete is concrete that is unreinforced by re-bars with a nominal or a range of densities specified in this document.

Post-Core Decay Time (PCDT) is synonymous with cooling time.

PWR is an acronym fo r pressurized water reactor.

Reactivity is used synonymously with effecti ve neutron multiplication factor or k-effective.

Redundant Drop Protection Features are mechanical elements of a hydraulic lifti ng device used to prevent the uncontrolled lowering of a load in the event of a loss of power or loss of hydraulic pressure.

Page 6 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY lt4FORl\>1ATIOM Safe Shutdown Earthquake (SSE) is a site' s seismic input applicable to the cask 's long term storage on the ISFSI pad, also called DBE.

Safety Report is a generic term to identify a SAR or any other term that connotes a compilation of all safety analyses and evaluations necessary to demonstrate compliance of a SSC to the its applicable codes and regulations.

Safety Significant is a gene ric term in Holtec's QA system to indicate Safety Related (used in 10CFR 50) and Important- to -Safety (Used in 10CFR71 and 10CFR72)

SAR is an acronym for Safety Analysis Report.

Self-hardening Engineered Subgrade (SES) means CLSM or lean concrete in this SAR.

Service Life means the duration for which the SSC is reasonably expected to perform its intended function, if operated and maintained in accordance with the provisions of this Safety Report. Service Life may be much longer than the Design Life because of the conservatism inherent in the codes, standards, and procedures used to design, fabricate, operate, and maintain the SSC.

Severity Index is the indicator of the safety importance and operational fragility of a SSC (used in Chapter 18) which informs the level of monitoring, inspection and remediation measures required in its Aging Management Program (AMP). The canister has the highest severity index

(=3); NITS items have the severity index of 0.

Shield Gate means the split-plate structure that provides the ability to open and close the bottom closure structure in the HI-TRAC CS transfer cask.

Short-term Operations means those normal operational evolutions necessary to support canister loading into or unloading fro m the HI-STORM UMAX storage system. These include, but are not limited to canister transfer, and onsite handling of a loaded transport cask as descriibed in this SAR.

Single Failure Proof in order for a lifting device or special lifting device to be considered single failure proof, the design must follow the guidance in NUREG-06 12, which requires that a single failure proof device have twice the normal safety margin. This designati.o n can be achieved by either providing redundant devices (load paths) or providing tw ice the design factor as required by the applicable code.

SNF is an acronym for spent nuclear fuel.

Special Lifting Devices are components that meet the definition of ANSI N l 4.6.

SSC is an acronym for Structures, Systems and Components.

STP is an acronym Standard Temperature and Pressure conditions.

Support Foundation Pad (SFP) means the reinforced concrete pad located underground on which the CECs are situated.

Sub-Grade is the 3-D continuum adj acent to each CBC that occupies the vertical space between the SFP below and the ISFSI Pad above.

Page 7 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEG PROPRleTARY IMFORM ATIQN Thermal Capacity of the HI-STORM system is defined as the amount of heat the storage system, containing a canister loaded with CSF stored in storage, will actually reject with the ambient environment at the normal temperature and the peak fuel cladding temperature (PCT) below the ISG-11 Rev 3 limit.

Thermo-siphon is the term used to describe the buoyanc y-driven natural convection circulation of helium within the canister.

Tilt Frame is the device used for tilting of the Transport Cask or HI-TRAC between the vertical and horizontal orientations.

Top-of Grade (TOG) of the ISFSI is identified as the riding surface of the cask transporter.

Traveler means the set of sequential instructions used in a controlled manufacturing program to ensure that all required tests and examinations required upon the completion of each significant manufacturing activity are performed and documented for archival reference.

UG is an acronym for HI-STORM UMAX Generic License components.

Unconditionally Safe Threshold (UST) value is a term-of-art that is assigned to the result of a safety analysis which represents the lowest value that can be wrought by a "change" without requiring a modification to the material in the SAR. The UST is set higher than the required factor-of-safety pursuant to Chapter 4 herein. The significance of a "change" in the safety factor is measured with the UST as the reference value.

Under-grade is the space below the SFP.

Vertical Cask Transporter (VCT) is the generic name for a device that has the ability to raise or lower a cask or a canister with the built-in safety of a redundant drop protection system. A VCT may be designed to be limited in its operation space to the ISFSI pad area and/or it may have the capability to translocate the cask over a suitably engineered haul path.

VVM is an acronym for Vertical Ventilated Module ZPA is an acronym for "zero period acceleration".

Page 8 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY l~IFQRMATION Table of Contents CHAPTER 1: GENERAL DESCRIPTION .......................................................................................... 1-l

1.0 INTRODUCTION

........................................................................................................................ 1-l 1.0.l 10CFR 72.48Evaluations ............................................................................................... l-3 1.1 GENERAL DESCRIPTION OF INSTALLATION ..................................................................... 1-9 1.2 GENERAL SYSTEMS DESCRIPTION .................................................................................... 1- 11 1.2. l Hi-STORM UMAX System Overview ......................................................................... 1-l l 1.2.2 Constituents of the HI-STORM UMAX Vertical Ventilated Module and TSFST Structures ....................................................................................................................... 1-12 1.2.3 Design Characteristics of the HI-STORM UMAX VVM ............................................. 1-16 1.2.4 HI-TRAC CS ................................................................................................................. 1- 18 l.2.5 Operational Characteristics of the HI-STORM UMAX ................................................ 1- 19 1.2.6 Cask Contents ................................................................................................................ 1-21 1.2.7 Ancillary Equipment Used at HI-STORE CIS .............................................................. 1-2 1 1.3 IDENTIFICATION OF AGENTS AND CONTRACTORS ...................................................... 1-30 1.4 MATERIAL INCORPORATED BY REFERENCE .................................................................. 1-37 1.5 LICENSING DRAWINGS ......................................................................................................... 1-38 1.6 REGULATORY COMPLIANCE .............................................................................................. 1-39 CHAPTER 2: SITE CHARACTERISTICS .............................................................. .. .... ............ .... .. .. .. 2-l

2.0 INTRODUCTION

........................................................................................................................ 2-l

2. l GEOGRAPHY AND DEMOGRAPHY ....................................................................................... 2-2

2. l . l Site Location .. .................................................................................................................. 2-2 2.1.2 Site Description ................................................................................................................ 2-2

2. l .3 Population Distribution and Trends ................................................................................. 2-6

2. I .4 Land and Water Use ........................................................................................................ 2-7 2.2 NEARBY INDUSTRIAL, TRANSPORTATION, AND MILITARY FACILITIES ................ 2-40 2.2. l Induslrial Facilities ........................................................................................................ 2-40 2.2.2 Pipelines ......................................................................................................................... 2-40 2.2.3 Air Transportation .......................................................................................................... 2-42 2.2.4 Ground Transportation ................................................................................................... 2-46 2.2.5 Nuclear Facilities ........................................................................................................... 2-47 2.3 METEOROLOGY ...................................................................................................................... 2-64 Page 9 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOL'fEC PROPR:IE'fAR:'1' INFORMATION 2.3.1 Regional Climatology .................................................................................................... 2-64 2.3.2 Local Meteorology ......................................................................................................... 2-66 2.3.3 Onsite Meteorological Measurement Progra m .............................................................. 2-66 2.4 SURFACE HYDROLOGY ........................................................................................................ 2-75 2.4. l Hydrologic Description .................................................................................................. 2-75 2.4.2 Floods ............................................................................................................................ 2-78 2.4.3 Probable Maxim um Flood (PMF) .................................................................................. 2-80 2.4.4 Potential Dam Failures (Seismically-Induced) .............................................................. 2-81 2.4.5 Probable Maximum Surge and Seiche Flooding ............................................................ 2-8 1 2.4.6 Probable Maximum Tsunami Flooding ......................................................................... 2-8 1 2.4.7 lee Flooding ................................................................................................................... 2-81 2.4.8 Flood Protection Requirements...................................................................................... 2-81 2.4.9 Environmental Acceptance of Effluents ........................................................................ 2-8 1 2.5 SUBSURFACE HYDROLOGY ................................................................................................ 2-93 2.6 GEOLOGY AND SEISMOLOGY ........................................................................................... 2- 10 1 2.6. 1 Bas ic Geologic and Seismic Tnformation ..................................................................... 2- I OI 2.6.2 Vibratory Ground Motion ............................................................................................ 2-104 2.6.3 Surface Faulting ........................................................................................................... 2- 105 2.6.4 Stability of Subsurface Materials ................................................................................. 2-105 2.6.5 Slope Stability .............................................................................................................. 2-107 2.6.6 Construction Excavation ..... . .. . .. . .. . .. .. . .. . .. ..... . ....... . ..... . .. . ... .. .. . . ...... . .... ....2- 107 2.7 SITE SPECIFIC DATA FOR THERMAL AND STRUCTURAL ANALYSES .................... 2-129 2.8 SAFETY-RELEVANT ENVIRONMENTAL DETERMINATIONS ..................................... 2-132 2.9 REGULATORY COMPLIANCE ............................................................................................ 2-133 CHAPTER 3: OPERATIONS AT THE HI-STORE FACIL ITY ....................................................... 3-l 3.0 INTROD UCTION ........................................................................................................................ 3-l

3.1 DESCRIPTION

OF OPERATIONS ............................................................................................. 3-3

3. l.l Operations at Originating Nuclear Power Plant... ............................................................ 3-4 3.1.2 Operations Between the Originating Nuclear Power Plant and HI-STORE .................... 3-4 3.1.3 Operations Between the Railroad Mainline and HI-STORE ........................................... 3-4 3.1 .4 Operations at HI-STORE ................................................................................................. 3-5

3. 1.5 Identification of Subjects for Safety Analysis ................................................................. 3-8 Page 10 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMATIOM 3.2 SPENT FUEL AND HIGH-LEVEL WASTE HANDLING SYSTEMS ................................... 3-17 3.2. 1 Spent Fuel Canister Receipt, Handl ing, and Transfer. ................................................... 3-17 3.2.2 Spent Fuel Canister Storage ........................................................................................... 3-19 3.3 OTHER OPERATING SYSTEMS ............................................................................................. 3-21 3.4 OPERATION SUPPORT SYSTEMS ........................................................................................ 3-22 3.4. l Instrumentation and Control Systems ............................................................................ 3-22 3.4.2 System and Component Spares ...................................................................................... 3-22 3.5 CONTROL ROOM AND CONTROL AREA ........................................................................... 3-23 3.6 ANALYTICAL SAMPLING ..................................................................................................... 3-24 3.7 POOL AND POOL FACILITY SYSTEMS ............................................................................... 3-25 3.8 REGULATORY COMPLIANCE .............................................................................................. 3-26 CHAPTER 4: DESIGN CRITERIA FOR THE HI-STORE CIS sscs ............................................. 4-l

4.0 INTRODUCTION

........................................................................................................................ 4- l 4.1 MATERIALS TO BE STORED ................................................................................................... 4-5 4.1.1 Spent Fuel Canisters ........................................................................................................ 4-5 4.1.2 High-Level Radioactive Waste ........................................................................................ 4-5 4.2 CLASSIFICATION OF STRUCTURES, SYSTEMS AND COMPONENT S .......................... 4-11 4.3 DESIGN CRITERIA FOR SSCS IMPORTANT TO SAFETY ................................................. 4-16 4.3.1 Multi-Purpose Canisters (MPCs) ................................................................................... 4-16 4.3.2 VVM Components and ISFS l Structures ....................................................................... 4-16 4.3.3 HI-TRAC CS ................................................................................................................. 4-18 4.3.4 HI-STAR 190 ................................................................................................................. 4-19 4.3.5 Cask Transfer Facility (CTF) ......................................................................................... 4-20 4.3.6 Applicable Earthquake Loadings for the HI-STORE CIS Facility ................................ 4-21 4.4 ACCEPTANCE CRITERIA FOR CASK COMPONENTS ....................................................... 4-33 4.4. l Stress and Deformation Limits ...................................................................................... 4-33 4.4.2 Thermal Limits .............................................................................................................. 4-34 4.4.3 Dose Limits .... ................................................................................................................ 4-34 4.5 LIFTING DEVICES (CTB CRANE & VCT, SPECIA L LIFTING DEVICES, AND MISCELLANEOUS ANCILLARIES ........................................................................................ 4-39 4.5.1 Design Require ments Applicable to Lifting Devices and Special L ifting Devices ....... 4-39 4.5 .2 Cask Transfer Building (CTB) Crane ............................................................................ 4-40 Page 11 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL'fEC PROPRIETARY l~IFORMATIObl 4.5 .3 Vertical Cask Transporter .............................................................................................. 4-42 4.5.4 Miscellaneous Ancillaries .............................................................................................. 4-46 4.6 DESIGN CRITERIA FOR CASK TRANSFER BUILDING (CTB) ........................................ .4-61 4.6. l Design Features of CTB ................................................................................................ 4-61 4.6.2 CTB Slab ........................................................................................................................ 4-61 4.7

SUMMARY

OF DESIGN CRITERIA ....................................................................................... 4-65 APP 4.A STRESS U MITS FOR ASME SECTION JrI SUBSECTION NF LINEAR STRUCTURES AND PLATE & S HELL TYPE STRUCTURES ....................... 4A- l 4.A. l Linear Structures ........................................................................................................... 4A- l 4.A.2 Stress Limit Criteria for Plate and Shell Structures ...................................................... 4A-5 CHAPTER S: INSTALLATION AND STRUCTURAL EVALUATION .......................................... 5-l

5.0 INTRODUCTION

........................................................................................................................ 5- 1

5. 1 CONFINEMENT STRUCTURES, SYSTEMS AND COMPONENTS ...................................... 5-5 5.1.1 Desc1iption of Structural Design ..................................................................................... 5-5 5.1.2 Design Criteria ................................................................................................................. 5-5 5.1.3 Material Properties ........................................................................................................... 5-5 5.1.4 Structural Analyses .......................................................................................................... 5-6 5.2 POOL AND POOL CONFINEMENT FACILITIES ................................................................... 5-7 5.3 REINFORCED CONCRETE STRUCTURES ............................................................................. 5-8 5.3. l HI-STORM UMAX ISFSI Pad and Support Foundation Pad ......................................... 5-8 5.3.2 Canister Transfer Facility ................................................................................................ 5-9 5.3.3 Canister Transfer Building Slab....................................................................................... 5-9 5.4 OTHERSSCs lMPORTANTTOSAFETY .............................................................................. 5-12 5.4. l HI-STORM UMAX VVM ............................................................................................. 5-12 5.4.2 HI-TRAC CS ................................................................................................................. 5-14 5.4.3 Cask Transfer Building Crane ....................................................................................... 5-17 5.4.4 Transport Cask Lift Yoke .............................................................................................. 5-17 5.4.5 MPC Li ft Attac hment .................................................................................................... 5-18 5.4.6 Other Special Lifting Devices ........................................................................................ 5-19 5.5 OTHER SSCs ............................................................................................................................. 5-33 5.5.1 Cask T ilt Fraine ............................................................................................................. 5-33 5.5.2 Vertical Cask T ransporter .............................................................................................. 5-34 Page 12 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY llqfiORMA'f'IOlq 5.6 REGULATORY COMPLIANCE .............................................................................................. 5-39 CHAPTER 6: THERMAL EVALUATION .......................................................................................... 6-1

6.0 INTRODUCTION

........................................................................................................................ 6-1

6. 1 DECAY HEAT REMOVAL SYSTEMS ..................................................................................... 6-7 6.2 MATERIAL TEMPERATURE LIMITS ...................................................................................... 6-9 6.3 THERMAL LOADS AND ENVIRONMENTAL CONDITIONS ............................................ 6-10 6.4 ANALYTICAL METHODS, MODELS, AND CALCULATIONS .......................................... 6-12 6.4. l Applicable Systems ........................................................................................................ 6-12 6.4.2 Analysis Methodology ................................................................................................... 6-13 6.4.3 Calculations and Results ................................................................................................ 6- 16 6.5 SAFETY UNDER OFF-NORMAL AND ACCIDENT EVENTS ............................................. 6-35 6.5.1 Off-Normal Events ........................................................................................................ 6-35 6.5.2 Accident Events ............................................................................................................. 6-35 6.5.3 SSCs Important to Safety Guidance for Fire Protection Program ................................. 6-41 6.6 REGULATORY COMPLIANCE .............................................................................................. 6-47 APPENDIX 6A: HOLTEC VALIDATION OF FLUENT FOR CASK APPLTCATIONS ................... 6A- I 6A.1 INTRODUCTION ..................................................................................................................... 6A-1 6A.2 CODE DEVELOPER VALIDATION ...................................................................................... 6A-2 6A.3 HOLTEC VALIDATION .......................................................................................................... 6A-4 CHAPTER 7: SHIELDING EVALUATION ........................................................................................ 7-1

7.0 INTRODUCTION

....................................................................................................................... 7-l 7.1 CONTAINED RADIATION SOURCES ..................................................................................... 7-4 7.1.l General Specification and Approach for Neutron and Gamma Sources ............................ 7-4 7.1.2 Design Basis Assemblies .................................................................................................... 7-4 7.2 STORAGE AND TRANSFER SYSTEMS .................................................................................. 7-7 7.2.1 Design Criteria ................................................................................................................... 7-7 7.2.2 Design Features .................................................................................................................. 7-7 7.3 SHIELDING COMPOSITION AND DETAILS .......................................................................... 7-8 7.3. l Composition and Material Properties ................................................................................. 7-8 7.3.2 Shielding Details ................................................................................................................ 7-8 7.4 SHIELDING ANALYSES METHODS AND RESU LTS ......................................................... 7-10 7.4. 1 Computational Methods and Data ................................................................................. 7- 10 Page 13 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOL'fEC PROl'lR:IE'fAR:'1' INFORMATION 7.4.2 Dose and Dose Rate Estimates ...................................................................................... 7-10 7.5

SUMMARY

................................................................................................................................ 7-20 CHAPTER 8: CRITICALITY EVALUATION................... ........................ ............... ..... ........ ........ ..... 8-1

8.0 INTRODUCTION

........................................................................................................................ 8-l 8.1 CRITICALITY DESIGN CRITERIA AND FEATURES ............................................................ 8-3

8. I . l Criteria ........... .................................................................................................................. 8-3 8.1.2 Features ............................................................................................................................ 8-3 8.2 STORED MATERIAL SPECIFICATIONS ................................................................................. 8-4 8.3 EVALUATION ............................................................................................................................ 8-5 8.3. 1 Model Configuration........................................................................................................ 8-5 8.3.2 Accidental Criticality ....................................................................................................... 8-5 8.4 APPLICANT CRITICALITY ANALYSIS .................................................................................. 8-7 8.5 CRITICALITY MONITORING ................................................................................................... 8-8 CHAPTER 9: CONFINEMENT EVALUATION ................................................................................ 9-l

9.0 INTRODUCTION

........................................................................................................................ 9-l

9. 1 ACCEPTANCECRITERTA ......................................................................................................... 9-3 9.2 CONFINEMENT OF RADIOACTIVE MATERTALS ................................................................ 9-4 9.2.1 Storage Systems ............................................................................................................... 9-4 9.2.2 Operational Activities ...................................................................................................... 9-6 9.3 POOL AND WASTE MANAGEMENT FAClLITCES ................................................................ 9-8 9.3.1 Pool Facilities .................................................................................................................. 9-8 9.3.2 Waste Management Facilities .......................................................................................... 9-8 9.4 CONFINEMENT MONITORING ............................................................................................... 9-9 9.4.1 Storage Confinement Systems ......................................................................................... 9-9 9.4.2 Eftl uents ........................................................................................................................... 9-9 9.5 PROTECTION OF STORED MATERIALS FROM DEGRADATION ................................... 9-10 9.5.1 Confinement Casks or Systems ..................................................................................... 9-10 9.5.2 Pool and Waste Management Systems .......................................................................... 9-10 9.6

SUMMARY

................................................................................................................................ 9-ll CHAPTER 10: CONDUCT OF OPERATIONS ................................................................................. 10-l

10.0 INTRODUCTION

...................................................................................................................... 10- I I0. I ORGANTZATTONAL STRUCTURE ........................................................................................ I0-2 Page 14 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROF'~IETAFH llqfiORMA'FIOM 10.1.1 Corporate and On-site Organization .............................................................................. 10-2 10.1.2 Support Staff (JSFSJ Special ists) ................................................................................... 10-2 10.2 PREOPERATIONAL TESTING AND STARTUP OPERATIONS ......................................... 10-6 10.2.1 Administrative Procedures for Conducting the Test Program ....................................... 10-6 10.2.2 Preoperational Testing Plan ........................................................................................... 10-6 10.2.3 Evaluation of T ests ........................................................................................................ 10-8 10.2.4 Corrective Actions ......................................................................................................... 10-8 10.3 NORMAL OPERATIONS ....................................................................................................... 10-l l I 0.3. l Procedures .................................................................................................................... 10-1 1 I 0.3.2 Records ........................................................................................................................ I 0- 11 10.3.3 Conduct of Operations ................................................................................................. 10-12 10.3.4 Maintenance Program for the HI-STORM UMAX VVM & HI-TRAC CS ................ 10-17 10.3.5 Maintenance Program for the Canister ....................................................................... 10-19 10.3.6 Maintenance Programs for ITS Lifting and Handling Equipment, Including VCT. .... 10-19 10.3.7 Maintenance Programs for ITS Crane Systems ........................................................... 10-19 10.3.8 Ma intenance Programs for HI-STAR 190 Cask .......................................................... 10-19 10.4 PERSONNEL SELECTION, TRAINING, AND CERTTFICATJON ...................................... 10-24 10.4.1 Personnel Organization ................................................................................................ 10-24 10.4.2 Selection and T raining of Operating Personnel ........................................................... 10-24 10.4.3 Selection and T raining of Security Guards .................................................................. 10-24 10.4.4 Selection and Training of Radiation Protection Technicians ....................................... 10-24 10.5 EMERGENCY PLANNING .................................................................................................... 10-28 10.6 PHYSICAL SECURITY AND SAFEGUARDS CONTINGENCY PLANS .......................... 10-29 10.7 RADIATION PROTECTION PLAN ....................................................................................... 10-30 10.8

SUMMARY

.............................................................................................................................. 10-31 CHAPTER 11: RADIATION PROTECTION EVALUATION .... ........ .. .. ......... ..... ...... .... ............ .... 11-l

11.0 INTRODUCTION

...................................................................................................................... 11-1 11.0. l Ensuring Occupational Radiation Exposures are As Low As is Reasonably Achievable ....

....................... ................................................................................................................ 11-l

11. l AS-LOW-AS-REASONABLY-ACHIEY ABLE (ALARA) CONSIDERATIONS ................... 11-4 11.1.1 ALAR A Polic i.es and Programs ..................................................................................... 11 -4 I 1.1.2 Design Considerations ................................................................................................... I 1-5 Page 15 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMAT ION 11.1.3 Operational Considerations ............................................................................................ 11-8 ll.2 RADIATION PROTECTION DESIGN FEATURES .............................................................. 11-10 11.2. 1 Installation Design Features ......................................................................................... l l-10 11.2.2 Access Control ............................................................................................................. 11-11 11.2.3 Radiation Shielding ...................................................................................................... 11-11 11.2.4 Confinement and Yentilation ....................................................................................... 11-12 11.2.5 Area Radiation and Airborne Radioactivity Monitoring Instrumentation ................... 11-12 11.3 DOSE ASSESSMENT .............................................................................................................. 11-14 11.3. l Onsite Dose .................................................................................................................. 11 - 14 11.3.2 Offsite Dose ................................................................................................................. 11-14 11.4 RADIATION PROTECTION PROGRAM .............................................................................. 11-17 11.4. l Organizational Structure .............................................................................................. 11-17 11.4.2 Equipment, Instrumentation, and Facilities ................................................................. 11-18 11.4.3 Policies and Procedures ............................................................................................... 11-19 11.5 REGULATORY COMPLIANCE ............................................................................................ 11-21 CHAPTER 12: QUALITY ASSURANCE PROGRAM ..................................................................... 12-1

12.0 INTRODUCTION

...................................................................................................................... 12-1 12.0.1 Overview ........................................................................................................................ 12-l 12.0.2 Graded Approach to Quality Assurance ........................................................................ 12-2 12.1 REGULATORY COMPLIANCE .............................................................................................. 12-3 CHAPTER 13: DECOMISSIONING EVALUATION ...................................................................... 13-l

13.0 INTRODUCTION

...................................................................................................................... 13-1

13. l DESIGN FEATURES ................................................................................................................. 13-3 13.2 OPERATIONAL FEATURES ................................................................................................... 13-4 13.3 DECOMMISSIONING PLAN ................................................................................................... 13-5 13.3.1 General Provis ions ......................................................................................................... 13-5 13.3.2 Cost Estimate ................................................................................................................. 13-5 13.3.3 Financial Assurance Mechanism ................................................................................... 13-6 13.4 REGULATORY COMPLIANCE .............................................................................................. 13-7 CHAPTER 14: WASTE CONFINEMENT AND MANAGEMENT EVALUATION .................... 14-1

14.0 INTRODUCTION

...................................................................................................................... 14- I 14.1 WASTESOURCES .................................................................................................................... 14-2 Page 16 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRleTARY ll'>IFORMATIOl'>I 14.2 OFF-GAS TREATMENT AND VENTILATION ..................................................................... 14-3 14.3 LIQUID WASTE TREATMENT AND RETENTION .............................................................. 14-4 14.4 SOLJDWASTES ........................................................................................................................ 14-5 14.5 RADIOLOGICAL IMPACT OF NORMAL OPERATIONS .................................................... 14-6 14.6 REGULATORY COMPLIANCE .............................................................................................. 14-7 CHAPTER 15: ACCIDENT ANALYSIS ........................................................................................... 15- l

15.0 INTRODUCTION

...................................................................................................................... 15-l

15. 1 ACCEPTANCE CRITERIA ....................................................................................................... 15-3 15.1. l Off-Normal Events ........................................................................................................ 15-3 15.1.2 Accident Events ............................................................................................................. 15-3 15.2 OFF-NORMAL EVENTS .......................................................................................................... 15-4 15.2. 1 Off-Normal Pressure ...................................................................................................... 15-4 15.2.2 Off-Normal Environmental Temperature ...................................................................... 15-5 15.2.3 Leakage of One Seal ...................................................................................................... 15-5 15.2.4 Partial Blockage of the Air Inlet Plenum ....................................................................... 15-5 15.2.5 Hypothetical No n-Quiescent Wind ................................................................................ 15-6 15.2.6 Cask Drop Less Than Design Allowable Height ........................................................... 15-6 15.2.7 Off-No rmal Events Associated with Pool Facilities ...................................................... 15-6 1.5.2.8 Safety Evaluation ........................................................................................................... 15-6 15.3 ACCIDENTS .............................................................................................................................. 15-7 1.5.3.l Fire Accident. ................................................................................................................. 15-7 15.3.2 Partial Blockage of MPC Basket Vent Holes .............................................................. 15-10 15.3.3 Tornado Missiles .......................................................................................................... 15-10 15.3.4 Flood ............................................................................................................................ 15-11 15.3.5 Earthq uake ................................................................................................................... 15-1.2 15.3.6 100% Fuel Rods Rupture ............................................................................................. 15-13 15.3.7 Confinement Bo undary Leakage ................................................................................. 15-14 15.3.8 Explosion ..................................................................................................................... 15-14 15.3.9 Lightning ...................................................................................................................... 15-14 15.3. 10 100% Blockage of Air lnlets ........................................................................................ 15-14 15.3.1 1 Burial Under Debris ..................................................................................................... 15- 14 15.3.1 2 Extreme Environmental Temperature .......................................................................... 15- 14 Page 17 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC F'~OF'RIETARY INFORMATION 15.3.13 Cask Tipover ................................................................................................................ 15-14 15.3.14 Cask Drop .................................................................................................................... 15-14 15.3.15 Loss of Shielding ......................................................................................................... 15-15 15.3.16 Adiabatic Heatup ......................................................................................................... 15-15 15.3.17 Accidents at Nearby Sites ............................................................................................ 15-15 15.3.18 Accidents Associated with Pool Facilities ................................................................... 15-15 15.3.19 Building Structural Failure onto SSCs ......................................................................... 15-15 15.3.20 100% Rod Rupture Accident Coincident with Accident Events ................................. 15-16 15.4 OTHER NON-SPECIFIED ACCIDENTS ............................................................................... 15-18 15.5 I&C SYSTEMS ........................................................................................................................ 15-19 15.6 REGULATORY COMPLIANCE ............................................................................................ 15-20 CHAPTER 16: TECHNICAL SPECIFICAITONS ............................................................................ 16-l

16.0 INTRODUCTION

...................................................................................................................... 16- l 16.l FUNCTIONAL/OPERATING LIMITS, MONITORING INSTRUMENTS, AND LIMITING CONTROL SETTINGS .............................................................................................................. 16-3 16.2 LIMITING CONDITIONS ......................................................................................................... 16-4 16.3 SURVEILLANCE REQUIREMENTS ...................................................................................... 16-5 16.4 DESIGN FEATURES ................................................................................................................. 16-6 16.5 ADMINISTRATIVE CONTROLS ............................................................................................ 16-7 16.6 REGULATORY COMPLIANCE .............................................................................................. 16-9 APPENDIX 16.A TECHNICAL SPECIFICATIONS (LCO) BASES FOR THE HOLTEC CIS FACILITY ................................................................................................................................... 16.A- 1 CHAPTER 17: MATERIAL CONSIDERATIONS ........................................................................... 17-l 17 .0 INTRODUCTION ...................................................................................................................... 17-1 17.l MATERIAL DEGRADATION MODES ................................................................................... 17-6 17.2 MATERIAL SELECTION ....................................................................................................... 17-12 17 .2.1 Structtu-al Materials ...................................................................................................... 17-12 17.2.2 Non-Structural Materials ............................................................................................. 17-13 17.3 APPLICABLE CODES AND STANDARDS .......................................................................... 17-17 17.4 MATERIAL PROPERTIES ..................................................................................................... 17-18 17.4. 1 Mechanical Properties .................................................................................................. 17-18 17.4.2 Thermal Properties ....................................................................................................... L7- 1. 8 Page 18 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLT EG PROPRIETARY INFORMAT ION 17.4.3 Protection Against Brittle Fracture of Ferritic Steel Parts ........................................... l 7-1 8 17 .4.4 Protection Against Creep ............................................................................................. 17-19 17.5 WELDING MATERIAL AND WELDING SPECJFICATJON ............................................... 17-21 17.6 BOLTS AND FASTNERS ....................................................................................................... 17-23 17.7 COATINGS AND CORROSION MlTlCATlON .................................................................... 17-24 17.7.1 Exterior Coating ........................................................................................................... 17-24 17.8 GAMMA AND NEUTRON SHIELDING MATERIALS ....................................................... 17-26 17.8.1 Plain Concrete .............................................................................................................. 17-26 17.9 NEUTRON ABSORBING MATERIALS ............................................................................... 17-27 17.10 SEALS ...................................................................................................................................... 17-28 17.11 CHEMICAL AND GALVANIC REATIONS ......................................................................... 17-29 17.12 FUEL CLADDING INTEGRITY ............................................................................................ 17-31 17.13 EXAMINATIONS AND TESTING ......................................................................................... 17-32 17.14 REGULATORY COMPLIANCE ............................................................................................ 17-33 CHAPTER 18. AGING MANAGEMENT PROGRAM .................................................................... 18- l

18.0 INTRODUCTION

...................................................................................................................... 18-1 18.1 SCOPING EVALUATION AND SEVERITY INDEX ............................................................. 18-4 18.2 MAINTENANCE PROGRAM FOR THE HI-STORM UMAX VVM & HI-TRAC CS .......... 18-7 18.3 MECHANISMS FOR AGING OF sscs ................................................................................... 18-8 18.4 UNIQUE ASPECTS OF THE HI-STORE C IS WITH NEXUS TO ITS AMP ....................... 18-14 18.5 CANISTER AGING MANAGEMENT PROGRAM ............................................................... 18-15 18.5. l Visual Examination ...................................................................................................... 18-15 18.5.2 Accelerated Coupon Testing ........................................................................................ 18-16 18.5.3 Eddy Current Testing ................................................................................................... 18-16 18.6 HT-TRAC CS TRANSFER CASK AGING MANAGEMENT PROGRAM ........................... 18-19 18.7 VVM AGING MANAGEMENT PROGRAM ......................................................................... 18-21 18.8 REINFORCED CONCRETE AGING MANAGEMENT PROGRAM ................................... 18-22 18.9 HBF AGING MANAGEMENT PROGRAM .......................................................................... 18-23 18.10 LIFfING DEVICE AGING MANAGEMENT PROGRAM ................................................... 18-24 18.11 TILT FRAME AGING MANAGEMENT PROGRAM ........................................................... 18-25 18.12 LEARNING BASED AMP ...................................................................................................... 18-26 18.13 T IMING OF AGING MANAGEMENT JMPLEMENTATION .............................................. 18-28 Page 19 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY l~JFORMATIOf~

18.13. 1 Canisters ..................... .... .......... ..................................... .. ............................................ . 18-28 18.13.2 All Other SSCs ............................................................................................................. 18-28 18.14 AMELIO RA TING THE RISK OF CANISTER DEGRADATION OVER A LONG TERM STORAGE DURATION ........... ... ............. ... ...... ................ ......... ............ ..... .............. .. ... ........ . 18-29 18.15 RECOVERY PLAN ........................ ........ ................................................................................. . 18-30 CHAPTER 19: REFERENCES ... ..... .... ... .. .. ... .................... .. ...................... .. ....... .. .... .... ............... ........ 19-l Page 20 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY llqfiORMA'f'IOlq CHAPTER 1: GENERAL DESCRIPTION*

1.0 INTRODUCTION

This Safety Analysis report, prepared pursuant to 10CFR72.24, provides the necessary information to justify the licensing of an Independent Spent Fuel Storage Installation (ISFSI) facility on an extensively assayed and environmentally qualified land in southeastern New Mexico. The storage facility has been named ID-STORE CIS, the acronym CIS intended to denote consolidated interim storage pursuant to the Presidential Blue Ribbon Commission report

[ 1.0.1] subsequently adopted by the US Department of Energy (USDOE).

It is planned to situate HI-STORE CIS on a large parcel of presently unused land owned by ELEA, LLC. ELEA was formed in 2006 in accordance with an enabling legislation passed in New Mexico and consists of an alliance of (in alphabetical order) the city of Carlsbad, the county of Eddy, the city of Hobbs and the county of Lea which together, as shown in the geographical layout in Figure 1.0.l completely surround the proposed site. (ELEA is a composite of Eddy and Lea counties which are members of the alliance). As HI-STORE CIS is an autonomous facility without any physical nexus to an operating reactor, it qualifies being referred to as an away-from-reactor (AFR) facility.

The ELEA/ Holtec compact envisages Holtec securing the site specific license pursuant to 10CFR72.6 for the HI-STORE CIS from the USNRC, carrying out the necessary detailed designs & site construction, and managing CIS ' security, maintenance and ongoing operations.

Thus Holtec International will serve as the operator of the HI-STORE CIS with undivided responsibility for its safety and security. Holtec International has also committed to ELEA that the storage technology deployed at the HI-STORE CIS will meet the site boundary dose limit specified in 10CFR72 [1.0.5] with substantial margins under any normal and credible accident scenarios.

The HI-STORE CIS will be built in several stages of storage system groups to correspond to the (expected) increasing need from the industry and the US government. The first stage of the storage module group and other overview information on the site germane to its intended use can be found in Table 1.0. 1.

The major milestone dates for licensing, building and commissioning the HI-STORE CIS facility are presented in Table 1.0.2. This milestone schedule presumes continued DOE and NRC support and enthusiasm on the part of the utilities to avail themselves of this faci lity.

This license application accordingly conta ins the necessary information specified in Regulatory Guide 3.50 [1.0.2] and in NUREG-1567 [1.0.3] to articulate the safety case for the site specific license pursuant to 10CFR72.6. In accordance with 10CFR72.24, the site-specific license for HI-STORE CIS requires a comprehensive consideration of a ll aspects of the facility that bear upon its safe and ALARA installation and operation. These include:

AJJ references are in placed within square brackets in this report and are compiled in Chapter 19 of this report Page 21 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HObTeC PROPRleT/1.RY ll'>IFORMATIOl'>I

Siting of the AFR site and design of the storage and security system. Site-specific demonstration of compliance with regulatory dose limits. Implementation of a facility-specific ALARA program.

An evaluation of site-specific hazards and design conditions that may exist at the AFR site or the transfer route between the plant's cask Receiving Area and the storage location.

These include all naturally occurring extreme environmental phenomena that are defined as credible events in the Environmental Report[l.0.4] for the HI-STORE CIS facility

Determination that the physical and nucleonic characteristics and the condition of the SNF assemblies to be stored meet the fuel acceptance requirements for the site.

Detailed site-specific operating, maintenance, and inspection procedures prepared in accordance with the generic procedures and requirements provided in Chapters 3 and 10 herein.

Performance of pre-operational testing.

Implementation of a safeguards and accountability program in accordance with 10CFR73. Preparation of a physical security plan in accordance with 10CFR73.55.

Essentials of the site emergency plan, quality assurance (QA) program, training program, and radiation protection program.

In addition to the sixteen chapters set forth in NUREG- 1567, Chapters 17 and 18 have been added to this SAR to explicjtly address materi al selection considerations and long term Ageing Management.

This safety analysis report on the HI-STORE CIS is li mited at this time to the canisters and contents approved by the NRC in the generic docket (# 72-1040) for HI-STORM UMAX. T able 1.0.3 identifies systems, components, and/or documents submitted to and approved by the NRC in other dockets and incorporated in this application by reference. Table 1.0.3 indicates the native and subsequent adoption dockets for systems and documents incorporated by reference (including systems/components safety analyses) into this HI-STORE application.

Within this report, all figures, tables and references cited are identified by the double decimal syste m m.n.i, where m is the chapter number, n is the section number, and i is the table number.

For a complete listing of Ta bles and Figure the Table of Contents should be consulted. For example, Figure 1.2.1 is the first fi gure in Section 1.2 of Chapter 1. Similarly, the following convention is used in the organization of chapters:

a. A chapter is identified by a whole numeral, say m (i.e., m=3 means Chapter 3)

b. A section is identified by one decimal separating two numerals. Thus, Section 3. 1 is section 1 in Chapter 3.

c. A subsection has three numerals separated by two decimals. Thus, Subsection 3.2. 1 is subsection 1 in Section 3.2.

d. A paragraph is denote d by four numerals separated by three decimals. Thus, Paragraph 3.2.1.1 is paragraph 1 in Subsection 3.2.1.

Page 22 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY l~lFORMATION

e. A subparagraph has five numerals separated by four decimals. Thus, Subparagraph 3.2.1.1.1 is subparagraph 1 in Paragraph 3.2. 1.1.

Tables and figures associated within a section are placed after the text narrative. The drawing packages are controlled separately within the Holtec QA program with individual revision numbers and are inc luded in Section 1.5 of this chapter.

Finally, the Glossary contains a listing of the terminology and notation used in this SAR.

1.0.110 CFR 72.48 Evaluations It is noted that the informatio n incorporated herein by reference is based on the docketed, NRC -

approved licensing basis. If any change is made to a canister under the original licensing basis using 10CFR72.48, such change will need to be evaluated against the HI-STORM UMAX FSAR before the canister can be sto red in a HI-STORM UMAX system.

Canister records must be provided to the HI-STORE facility personnel prior to shipment of a canister. These records must be reviewed and any applicable 10CFR72.48 screenings or evaluations written against the canister's original licensing basis evaluated against the HI-STORE site specific license to determine if a change requiring NRC approval is necessary.

To facilitate evaluation and to avoid clutter in this SAR, the numerical results of the safety analyses summarized in this document are reported along with, where practicable, an "unconditionally safe threshold" value. The unconditionally safe threshold value (please see Glossary) is defined as the numerical result that defines the boundary of a materially non-consequential & insignificant change that does not require the use of a 10CFR72.48 change process avoiding the need to modify the material in the SAR; rather, the documentation of the "change" may be limited to the calculation package and other actionable project documents. A result that exceeds the unconditionally safe threshold (UST ) value requires the impleme ntation of the 10CFR72.48 process to determine the admissibility of the proposed change.

Page 23 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROPRIETARY l~lf=ORMJITIOl'>I Table 1.0.1: Overview of the HI-STORE Facility Item Data Comment Land area of the site 1045 acres Overall land area Maximum design capacity 10,000 Each stage is envisaged to have Envisaged in this license 500 storage cavities.

application (UMAX/Canisters)

Maximum quantity of Uranium 173,600 MTUs Each stage is envisaged to have (Note 1) 8,680 MTUs Maximum number of stages Up to 20 stages Each construction stage to take envisaged for the HI-STORE up to 1 year to complete CIS Facil ity to reach design capacity Capacity of the installation for 500 19 subsequent expansion phases the first licensing application to be constructed over course of 20 years and under future licensing applications Total land area occupied by the Approx. 288 acres Includes restricted ISFSI area, storage system at maximum parking lot, administrative capacity building, security building and batch plant Land area occupied by the CIS Approx. 28% See comment above.

storage systems as a percentage of the total site area Storage system type used at the HI-STORM UMAX Introduced in Section 1.2 site (NRC Docket# 72-1040

[1.0.6])

Distance of the nearest 1.5 miles Ranch north of the site, see permanent human settlement Chapter 2 from the site Distance from nearest loaded 400 meters (1,3 12 feet) Occupancy at this distance is UMAX VVM to Site Boundary conservatively assumed to be (Controlled Area Boundary) 2000 hours0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months per year, see Chapter 7 Approximate number of Less than 20 (average) Total of five ranches, see permanent residents in 6 miles Chapter 2 radius from the center of the site Elevation of the site above sea 3520 to 3540 No risk of flood, see Chapter 2 level, feet Geological formation Stable No known faults in the region, see Chapter 2 Page 24 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATIOf~

Table 1.0.1 : Overview of the HI-STORE Facility Location( distance) of the 3.8 miles west (SWR) Southwestern Railroad (SWR) existing rail terminal from the 32 miles east (TNMR) Texas-New Mexico Railroad site (TNMR)

Maximum excavation depth Approx. 25 feet Construction activity will not be required to build the facility in contact with groundwater Note 1: Maximum quantity of uranium per loaded canister is for design basis PWR fuel assembly (MPC-37) for the HI-STORM UMAX. The quantity of uranium per loaded MPC-37 canister bounds the quantity per loaded canisters containing BWR fuel assembly.

Page 25 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Table 1.0.2: Projected Milestone dates for HI-STORE CIS*

Activity Scheduled or expected date License Application Submitted March 2017 License Application Approval M arch 201 9 Site preparation begins June 2018 Site construction begins December 2018 Site and ISFSI construction completed M arch 2021 Protected area and security infrastructure established June 2021 Site Specific procedures prepared, vetted and adopted December 2021 Site QA and Safety program installed December 2021 Facility pre-commissioning (dry run) begins December 2021 Facility declared operational -NRC's concurrence secured June 2022 First batch of canisters arrives at the site' s Receiving Area June 2022

Pursuant to the provisions in I0CFR72.40(b), the site construction of the HJ-ST ORE C IS facility will require regulatory approval. Additionally, in accordance with 10CFR72.22, the construction program will be undertaken only after a defi nitive agreement with the prospective user/payer for storing the used fuel (USDOE and/or a nuclear plant owner) at HI-STORE CJS has been established. These regulatory and contractual predicates may adversely affect the schedule dates and durations set forth in this table.

Page 26 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRleTARY l~lFORMAT ION Table 1.0.3: Systems and Documents Incorporated by Reference for HI-STORE (Note 1)

System/Document Native Docket) Secondary Adoption Docket HI-STORM UMAX System 72-1040 NIA HI-STORM FW Canisters (MPCs 72-1032 72-1040 37 and 89)

Holtec International QA Manual 7 1-0784 72-1040 Note 1: Where specifically incorporated by reference in this report, additional information such as repo,t title, sections or specific analyses within reports incorporated by reference, and technical justification of applicability to HI-STORE CIS Facility are provided.

Table 1.0.4: Canisters Allowed for Storage in HI-STORM UMAX at HI-STORE Canister Native Docket Secondary Adoption Docket MPC-37 72-1032 72-1040 MPC-89 72-1032 72- 1040 Page 27 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IAI TFA PRAPRIFTARY l~JFARMAT IAN

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Figure 1.0.1: Geographical Layout of Proposed HI-STORM UMAX CIS ISFSI Site Page 28 of 689 Revision OC May 201 8

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRleT/1.RY lf>lf=ORM.'\TIGN 1.1 GENERAL DESCRIPTION OF INSTALLATION The HI-STORE CIS Facil ity layout drawing in Section 1.5 provides the general arrangement of the HI-STORE CIS Facility. The facility (site) layout drawing depicts the site at design basis capacity (Table 1.0.1). However, this application is limited to the initial licensing capacity (Table 1.0.1). As shown in the layout drawing, the HI-STORE CIS consists of the following SSCs:

a . The HI-STORM UMAX VVMs (Figure 1.2.2)

b. Rail Spur and Cask receiving area

c. Equipment Building to store HI-TRAC, the Vertical Cask Transporter, ancillaries and spare parts.

d. Administrative Building to ho use inspection, security and administrative staff as well as access control facilities.

e. Security Building at the entrance to ISFSI to house security personnel, some health physics staff as required and some health physics or other monitoring instruments.

The following features of the Facility are important to its safety and security functions and to its emergency preparedness:

a. Each ISFSI pad is separated from its adj acent pad by a substantial mass of earth (Table 1.1.1) to ensure that the excavation for a pad with an adjacent operating ISFSI would not introduce a geo-structural or shielding problem.

b. As can be seen from Figure 1.2.1, there are no large obstructions in the storage region that may block the visual ability to identify an intruder.

c. The storage pads and ISFSI at large are equipped with an efficient drainage system.

d. Parking facility for cars, trucks and other conveyances are located far from the fuel storage area to preclude the risk of a mass fire from combustion of fuel or transmissio n fluid.

e. A substantial area adjacent to the loaded ISFSI is cleared of any brush or foliage that may serve as a fire stimulant.

f. The data in Table 1.1.1 provides additional information on the HI-STORE Facility. The HI-STORE facility systems descriptio ns are provided in Section 1.2.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION Table 1.1.1: HI-STORE CIS General arrangement data Item Value Nominal layout of each pad 25 by 20 Inter-cavity pitch 17 feet Pad to Pad distance 100 feet Nominal Size of the Equipment Storage 60 feet by 75 feet Building (non-safety)

Nominal size of the Admin Building 50 feet by 75 feet (non-safety)

Nominal Size of the Cask Transfer 350 X 100 X 60 (feet)

Building (CTB) (Length/Width/Height)

Page 30 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HObTeC PROPRIETARY INFORM 4IIQN 1.2 GENERAL SYSTEMS DESCRIPTION 1.2.1 HI-STORM UMAX System Overview The centerpiece of the HI-STORE CIS facility is the HI-STORM UMAX canister storage system certified in NRC docket # 72- 1040. HI-STORM UMAX is the subterranean version of HI-STORM FW and HI-STORM 100 of which the latter was the reference storage system for the licensed AFR site scheduled to be sited in the PFS LLC's Skull Valley, Utah licensed in 2006 in docket # 72-22. The HI-STORM UMAX stores a hermetically sealed canister containing spent nuclear fuel in a subterranean in-ground Vertical Ventil ated Module (VVM). The safety evaluation of HI-STORM UMAX is maintained in USNRC docket # 72- 1040. The annex identifier UMAX is an acronym of Underground MAXimum safety.

HI-STORM UMAX is a dry, in-ground spent fuel storage system consisting of any number of Vertical Ventilated Modules (VVMs) each containing one can ister. The HI-STORM UMAX has all the safety attributes that are attributed to in-ground storage, such as enhanced protection from incident projectiles and threats from extreme environmental phenomena such as hurricanes, tornado borne missi les, earthquakes, tsunamis, fires, and explosions. Figure 1.2.1 provides a pictorial illustration of an anay of HI-STORM UMAX systems that depicts its security-friendl y diminutive profile.

The HI-STORM UMAX version that will be employed in the HI-STORE CIS is essentially the design (without the ultra-high earthquake-resistant options, referred to as MSE options) licensed in the HI-STORM UMAX docket (72-1040). The only other respect in which the HI-STORE VVM design differs from the generic FSAR design is the provision that the storage cavity depth is made fixed (not variable, as permitted in the general certification) at two discrete dimensions.

The height of the lateral seismic restraint at the top of the canister is adjusted to accord with the he ight of the canister that will be stored in the cavity, and a second set of seismic restraints are situated between the Divider Shell and Cavity Enclosure Container (CEC) at the same height and location as the lateral seismic restraint. As a result, the structural performance of the system remai ns unaffected and other safety metrics such as shielding and thermal (heat rejection) are either unaffected or improved (depending on the height of the canister being stored).

To differentiate this minor tweak to the HI-STORM UMAX configuration deployed in the past, the HI-STORM UMAX drawings in Section 1.5 of this ch apter refer to the HI-STORE VVM as Version C. Version C's certification basis remains in docket # 72- 1040; it is not a new embodiment from a certification standpoint. The drawing package for Version C is included in this SAR principally to avoid having to refer to the drawing sets in the HI-STORM UMAX FSAR, which include severa] geometric options not used in the Version C design.

The essential characteristics of HI-STORM UMAX that make it uniquely suitable to serve as the heart of the proposed consolidated interim storage fac ility are:

a. The canister is stored below-grade which makes it essentially invulnerable to the various extreme environmental phenomena that arise in nature. The intensity of the earthquake Page 31 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I !OLTEC PROPRIETARY l~lFORMAT ION for which the HI-STORM UMAX system is qualified (documented in this SAR) bounds the Design Basis Earthquake for the site.

b. The HI-STORM UMAX storage system provides an essentially inviolable protection to the stored canisters against incident missiles such as a crashing aircraft. The source of the structural protection of the canister in HI-STORM UMAX lies in the fact that the only path for an incident missile to access the canister is by piercing the thick lid which is made of a steel weldment buttressed by concrete. The lateral surface of the canister is protected by a self-hardening engineered subgrade (SES) around each canister and by the surrounding expanse of the earth beyond. While the top lid is presently designed for 10CFR72 Design Basis Missiles, it can be effortlessly swapped for an even more impregnable lid structure if the level severity of threat to the facility were to increase in the future.

c. The storage cavity of HI-STORM UMAX is sufficiently large to accommodate every canister type licensed under different 10CFR72 dockets and in use in the United States at this time. Therefore, it is possible to qualify the entire universe of used fuel canisters presently deployed at the ISFSis around the country for storage in the HI-STORM UMAX system. HI-STORM UMAX is intended to provide a safe and regulation-compliant storage for even NUHOMS canisters which are normally stored horizontally.

(The safety analysis in support of LAR# 3 to the HI-STORM UMAX CoC indicates that all metrics for safe storage including decay heat rejection are maintained or improved when a canister is rotated to the vertical storage orientation in HI-STORM UMAX from its native horizontal storage in NUHOMS. LAR # 3 to the HI-STORM UMAX CoC is not a part of this application, but may be incorpora ted through a licensing action at a later date)

d. Because the on-site canister transfer operation (described in Section 10.3 herein) occurs vertically (specifically, doesn 't involve horizontal pushing or pulling of the heavy loaded canister against surface friction), there is no risk of gouging or scratching of the ASME code boundary of the canister. This is an important benefit at a CIS site where (presumably) thousands of canisters will be handled.

e. As can be ascertained from the design information in this SAR, the HI-STORM UMAX CIS features no above-ground important-to-safety building structure. All canister transfer facilities are below-ground.

f. As described in the canister Aging Management Program [ 1.2. l], a canister installed in a HI-STORM UMAX cavity can be remotely examined to assay the state of integrity of its confinement boundary shell making its long term monitoring a low dose activity.

g. Because of its below-ground fuel storage configuration, the HI-STORM UM AX CIS meets the site boundary accident dose limit of 10CFR 72.106 with large margins, as quantified in Section 7.4 of this SAR. The minuscule accreted dose, zero effluent release, and extreme hazard-resistance features of the HI-STORM UMAX CIS facility will make Page 32 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I !OLTEC PROPRIETARY lf>lf=ORMATIOl'>I its footprint on the environment vanishingly small, as described in the Environmental Report [1.0.4].

h. The canister's confinement boundary consists of thick circular stainless steel plate-type parts at the two extremities joined by a relatively thin shell. As a result, it is the canister's shell that has been the focus of stress corrosion cracking threat over prolonged periods of storage. Unlike horizontally disposed canister, the canister shell in HI-STORM UMAX is not in physical contact with any other structure precluding the risk of crevice corrosion, galvanic corrosion, etc.

Finally, it is insu*uctive to note that the canister in HI-STORM UMAX is laterally confined at its top and bottom extremities inside the HI-STORM UMAX VVM cav ity so that it would not significantly move or rattle under a seismic event. Thus the thennal-hydraulic fl ow configuration around the canister is fixed for the duration of storage. This lateral fixity feature in the HI-STORM UMAX storage system along with its subterranean disposition are key reasons that underlie its ability to withstand severe earthquakes.

All HI-STORM UMAX System components are and their sub-components are categorized as ITS, as applicable, in accorda nce with NUREG/CR-6407 [1.2.2].

To summarize, the HI-STORM UMAX System has been engineered to:

maximize shielding and physical protection for the canister;

minimize the extent of handling of the SNF;

minimize dose to operators during loading and handling;

require minimal ongoing surveillance and maintenance by plant staff;

facilitate SNF transfer of the loaded canister to a compatible transport overpack for transportation; 1.2.2 Constituents of the HI-STORM UMAX Vertical Ventilated Module and ISFSI Structures The HI-STORM UMAX VVM, shown in the licensing drawing in Section 1.5 provides for storage of the canister in a vertical configuration inside a subterranean cylindrical cavity entirely below the top-of-grade (TOG) of the ISFSI. The key constituents of a HI-STORM UMAX VVM and ISFSI structures are:

(i) YVM Components

a. The Cavity E nclosure Container (CEC)

b. The Di vider Shell

c. The Closure Lid (ii) ISFSI Structures

d. The ISFSI Pad Page 33 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMAT ION

e. The Support Foundation Pad

f. The Subgrade and Under-grade A brief description of each constituent part is provided in the following:

a. Cavity Enclosure Container:

The Cavity Enclosure Container (CEC) consists of a thick walled shell integrally welded to a bottom plate. The top of the container shell is stiffened by a ring shaped flange which is also integrally welded. The constituent parts of the CEC are made of low carbon steel plate. In its installed configuration, the CEC is interfaced with the surrounding subgrade for most of its height except for the top region where it is encased in the ISFSI pad.

With the Closure Lid removed, the CEC is a closed bottom, open top, thick walled cylindrical vessel that has no penetrations or openings. Thus, groundwater has no path for intrusion into the interior space of the CEC. Likewise, any water that may be introduced into the CEC through the air passages in the top lid will not drain into the groundwater.

The CEC top contains an air plenum box which works in conjunction with the Closure Lid to channel incoming air into the down-comer flowing region of the CEC. The air plenum box also contains rigid embedded locations for securing the HI-TRAC CS against moveme nt during Canister Transfer operations.

b. Divider Shell:

The Divider Shell is important to the thermal performance of the VVM system. The Divider Shell, as its name implies, is a removable vertical cylindr ical shell concentrically situated in the CEC that divides the CEC into an inlet flow down-comer and an outlet flow passage. The Divider Shell divides the rad ial space between the canister and the CEC cavity into two annuli.

The bottom end of the Divider Shell has cutouts to enable movement of air from the down-comer to the up-flow region around the canister. The cutouts in the Divider Shell are sufficiently tall to ensure that if the cavity were to be filled with water, the bottom region of the canister would be submerged to a depth of several inches. Thi s design feature ensures adequate thermal performance of the system if flood water were to block air flow. The Divider Shell is not attached to the CEC which allows its convenient removal for decommissioning or for any in-service maintenance or periodic inspection.

The cylindrical surface of the Divider Shell is equipped with insulation to prevent significant preheating of the inlet air. The insulation material is selected to be water and radiation resistant as well as non-degradable under accidental wetting.

c. The Closure Lid:

The Closure Lid is a steel structure filled with plain concrete that can withstand the impact of the Design Basis Missiles defined for the site. Both the inlet and outlet vents are located at the grade level. The Closure Lid internals form segregated air channels for air inlet and outlet. A set of inlet passage located on top of the CEC provide maximum separation from the large outlet passage which is located in the center of the lid and channel the inlet air into the CEC's air Page 34 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION plenum box. As depicted in the licensing drawings in Section 1.5, the geometry of the inlet and outlet ducts make the HI-STORM UMAX VVM essentially insensitive to the direction and speed of the wi nd.

The Closure Lid fu lfi lls the following principal performance objectives:

1 The Closure Lid is physically constrained against horizontal movement during a Design Basis Earthquake event or a tornado missile strike.

2 To minimize the radiation emitted from the storage cavity, a portion of the Closure Lid extends into the cylindrical space above the canister. This cylindrical below-surface extension of the Closure Lid is also made of steel fi lled with shielding concrete to maximize the blockage of skyward radiation issuing from the canister.

3 As can be seen from the drawings in Section 1.5, the Closure Lid is substantially larger in diameter than the CEC and the canister is positioned to be at a significant vertical depth below the top of the Container Flange. These geometric provisions ensure that the Closure Lid will not fall into the canister storage cavity space and strike the canister were to accidentally drop during its handling. Because the Closure Lid is the only removable heavy load, the carefully engineered design features to facilitate recovery from its accidental drop provide added assurance that a handling accident at the ISFSI will not lead to any radiological release. This additional measure against accidental Closure Lid drop does not replace the drop prevention features mandated in this Safety Report on heavy load lifting devices (such as the cask transporter) that have been a standard and established requirement in the HI-STORM dockets.

d. The ISFSI Pad:

The ISFSI Pad serves to augment shielding, to provide a sufficiently stiff riding surface for the cask transporter, to act as a batTier against gravity-induced seepage of rain or floodwater around the VVM body as well as to shield against a missile. The ISFSI pad is a monolithic reinforced concrete structure that provides the load bearing surface for the cask transporter. The appropriate requirements on the structural strength of the ISFSI pad are specified in Section 4. 3.

e. T he Support Foundation Pad:

The Support Foundation Pad (SFP) is the underground pad which supports the HI-STORM UMAX ISFSI. The SFP on which the VVM rests must be designed to minimize long-term settlement. The SFP and the under-grade must have sufficient strength to support the weight of all the loaded VVMs during long-term storage and earthquake conditions. As the weight of the loaded VVM is comparable to the weight of the subgrade which it replaces, the additional pressure acting on the SFP is quite small. The appropriate requirements on the structural strength of the SFP are specified in Section 4.3.

f. The Subgrade and Under-grade:

The lateral space between each CEC, the SFP and the ISFSI pad is referred to as the subgrade and is filled w ith a Controlled Low-Strength Material (CLSM). A lternatively, " lean concrete" may also be used.

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ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATION CLSM is a self-compacted, cement1t1ous material used primarily as a backfill in place of compacted fi ll. ACI 229R-99 notes several terms, such as flowable fill, unshrinkable fill, controlled density fill , fl owable mortar, flowable fly ash, fl y ash slurry, plastic soil-cement and soil-cement slurry to describe CLSMs. ACI l 16R-00 defines lean concrete as a material with low cementitious content. CLSM and lean concrete are also referred to as "Self-hardening Engineered Subgrade" (SES).

The subgrade material must meet the shear velocity and density requirements in Section 4.3. The space below the SFP is referred to as the under-grade.

Evaluations in Section 5.4 show that the Self-hardening Engineered Subgrade (SES) provides a stable lateral support system to the ISFSI under the Design Basis Earthquake. The interface between the SES and the native subgrade defines the radiation protection boundary of the ISFSI.

1.2.3 Design Characteristics of the HI-STORM UMAX VVM All HI-STORM UMAX locations are alike except for their cavity depth. The design of HI-STORM UMAX cavities has been standardized into certain discrete depths as tabulated in the Licensing Drawing Package (Section 1.5). Different depth Hl-STORM UMAX cavities enable canisters of different heights to be housed in the cavity of appropriate depth. The maximum HI-STORM UMAX cavity depth corresponds to that certified in docket # 72-1040.

The liberal pitch between the CEC cavities, as shown in the Licensing Drawing package, allows the Cask Transporter to traverse over any storage cavity and independently access any storage location. T hus, any canister located in any storage cavity can be independently accessed and retrieved using a qualified Vertical Cask Transporter (VCT) and a suitable transfer cask.

The essential design and operational features of the HI-STORM UMAX System are:

a. Because of its underground staging in HI-STORM UMAX, tip-over of the canister in storage is not possible.

b. In HI-STORM UMAX Version C, there are two fixed cavity depths referred to as Type SL and Type XL, respectively. Type SL cavity is sized to permit storage of all BWR fuel bearing canisters and PWR canisters that are shorter than the reference BWR canister.

Type XL is a deeper cavity sized to accommodate the canisters that accommodate SNF from South Texas and AP-1000 plants (which are exceptionally long). The vast majority of the storage cavities will be of the "SL" type. For all canister heights, the VVM constraint at the top of the canister are positioned to engage with the structurally robust canister lid where the Divider Shell is also hardened against lateral loads.

c. To exploit the biological shielding provided by the surrounding soil subgrade, the canister is entirely situated well below the top-of-grade level. The open plenum above the canister also acts to boost the ventilation action of the coolant air.

d. Removal of water from the bottom of the storage cavity can be carried out by the simple expedient use of a flexible hose inserted through the air inlet or outlet passageways.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION

e. All practical efforts are made to coat exposed surfaces of the VVM with proven low VOC and/or ANSVNSF Standard 6 1 [1.2.3] compliant surface preservatives to preclude toxicological effects on the environment to the maximum reasonable extent.

1.2.3.1 Shielding Materials Steel, concrete, and the subgrade are the principal shielding materials in the HI-STORM UMAX.

The steel and concrete shielding materials in the Closure Lid provide additional gamma and neutron attenuation to reduce dose rates.

The fuel basket structure provides the initial attenuation of gamma and neutron radiation emitted by the radioactive contents. The canister shell, baseplate, and thick lid provide additional gamma attenuation to reduce direct radiation.

1.2.3.2 Lifting Devices Lifting and handling devices used to load or unload a canister into the HI-STORM UMAX VVM shall be designed per Paragraph 1.2. 1.5 of the HI-STORM FW FSAR (docket # 72-1032).

The lifting and handling of all heavy loads that are within 10CFR72 jurisdiction , such as the HI-TRAC (Transfer Cask) and the HI-STORM UMAX Closure Lid, shall be carried out us ing single failure proof (see definition in the Glossary) equipment w ith below-the-hook lifting devices that comply with the stress limits of ANSI N 14.6 [1.2.4] and/or applicable portions of NUREG-0612

[l.2.7].

1.2.3.3 Threaded Anchor Locations Threaded anchor locations are provided in the CEC Fla nge region of each CEC. These will serve as the anchoring location for the device used for canister transfer (Section 10.3). Threaded anchor locations serve no function during long term storage.

1.2.3.4 Design Life The design life of the HI-STORM UMAX System is set forth in Table 17.0.1. This is accomplished by using materials of construction with a long proven history in the nuclear industry, specifying materials known to withstand their operating environments with little to no degradation (Section 17 .2), and protecting material from corrosion by using appropriate mitigation measures.

Maintenance programs, as specified in Section 10.3, are also implemented to ensure that the service life will exceed the design life. The design considerations that assure the HI-STORM UMAX System performs as designed include the following:

HI-STORM UMAX VVM and HI-TRAC CS Transfer Cask:

a. Exposure to Environmental Effects

b. Material Degradation

c. M aintenance and Inspection Provisions Canisters:

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ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY l~lFORMAT ION

a. Corrosion

b. Structural Fatigue Effects

c. Maintenance of Helium Atmosphere

d. Allowable Fuel Cladding Temperatures

e. Neutron Absorber Boron Depletion The adequacy of the materials for the designated design life is discussed in Chapter 18 of this report.

1.2.4 HI-TRAC CS The proposed transfer cask for the HI-STORE CIS facility to carry out all on-site canister transfer operations is termed HI-TRAC CS which is a variation of the HI-TRAC VW transfer cask licensed in docket number 72-1032 for the HI-STORM FW and later adopted for HI-STORM UMAX system in docket number 72-1040. HI-TRAC CS utilizes steel and higher density concrete, meeting the requirements in Appendix l.D of the HI-STORM 100 FSAR

[ l. 3.3] to provide dose a ttenuation. HI-TRAC CS is also characterized by a split lid configuration wherein the bottom lid is in in the form of two halves with both halves engineered to retract or approach symmetrically. Figure l.2.3a shows HI-TRAC CS in fully closed and fully open bottom lid configurations.

The design and operational features of HI-TRAC CS are summarized in the following:

a. The body of the cask features two concentric steel shells buttressed by a set of thick radial ribs that are welded to the two shells. The interstitial annular space between the two shells is filled with densified plain concrete that meets the requirements of Appendix 1.D of the HI-STORM 100 FSAR (docket # 72-1014) [1.3.3]. The appellation "CS" indicates that the transfer cask is "concrete shieldecf'.

b. The bottom of the HI-TRAC features a pair of articulating, half-moon-shaped shield gates housed in a heavy steel weldment. The shield gates are made of multiple stacked, thick-steel plates on a low-friction bearing pad. The shield gates slide in the housing to allow the passage of the MPC from the HI-TRAC to the HI-STORM UMAX and vice versa. In the closed position, the shield gates support the weight of the MPC and provide shielding from the bottom of the loaded MPC. The maj or advantage of the split door configuration is that, in the fully retracted state, it does not intrude on the space occupied by the air vent projection in adjacent HI-STORM UMAX cavities and does not prou*ude into the canister vertical travel space. The shield gates feature air passages which allow for once-through air cooling of the canister (Figure l.2.3b). The air cooling features of the HI-TRAC CS supplement the conductive and radiation cooling of the HI-TRAC CS.

Ambient air rises thro ugh multiple Z-shaped passages in the shield gates, up through the annulus and out the open top of the HI-TRAC CS. A segmented alignment r ing on the bottom of the HI-TRAC is used to concentrically align the HI-TRAC with the HI-STORM UM AX CEC during MPC transfer into the HI-STORM UMAX. The segmented alignment ring allows air to enter the region beneath the shield gates such that MPC Page 38 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HObTeC PROPRleT/1.RY ll'>IFORMATIOl'>I cooling air flow is assured even if the HI-TRAC is placed fl at on the ground. The air passage inlets through the shield gates passively uses the ground to shield personnel from downward-streaming radiation. The top region of the cask body features a set of lifting trunnions. The Trunnions are for lifting and handling of the HI-TRAC via the cask handling crane or VCT. The HI-TRAC bottom region also features a set of trunnions suitable for cask's tilting operations.

c. The bottom region of the cask is outfitted with a heavy wall steel structure that houses the articulating shield gates. The shield gates ride on a low fri ction surface to enable them to be pulled apart (or pushed together) with a modest force to open the cask's cavity for canister transfer when needed. Shield gate opening and closure occurs via a set of hydraulic cylinders located on the outer edges of the shield gate housing.

d. The shielding concrete in the transfer cask is installed through suitably sized openings in the cask's top closure plate which also provide the exit path for any gases that may be generated during a hypothetical fire event. The HI-TRAC concrete space is supplemented with an internal cylindrical steel ring that supplements the gamma shielding in the shield gate region.

e. During the canister trnnsfer operation, the transfer cask is secured to the top pad of the recipient cavity (HI-STORM UMAX ISFSI pad or the CTF pad) by a set of anchor bolts which eliminates kinematic stability concerns during the Design Basis Earthquake (DBE) event or any other credible environmental mechanical loading applicable to the site.

f. The top of the transfer cask features a thick annular steel ring which serves to prevent an inadvertent lifting of the canister beyond the biological shielding space provided by the transfer cask and also provides shielding axially.

g. The transfer cask is engineered to directly mate with the HI-STORM UMAX cavity as well as the Canister Transfer Facility (CTF) cavity eliminating the need for the traditional Mating Device ancill ary. Elimination of the M ating Device has the salutary advantage of reducing the aggregate crew dose (i.e., promoting ALARA).

The Licensing drawing package in Section 1.5 of this chapter provides the necessary design details of HI-TRAC CS that support the required safety analyses documented in this SAR.

1.2.5 Operational Characteristics of the HI-STORM UMAX The major operational steps to load a HI-STORM UMAX cavity consists of the following: The cask transporter carrying the transfer cask with the loaded canister aligns over the top of the HI-STORM UM AX and the HI-TRAC is placed on the HI-STORM UMAX VVM. The canister inside the transfer cask is lifted slightly by the VCT to allow the HI-TRAC's shield gates be opened. The canister is slowly lowered into the VVM cavity below. The transfer equipment is removed and the Closure Lid is installed. The principal operational characteristics of short term operations at an ISFSI are:

a. Prior to loading the VVM, the Closure Lid or other temporary lid is removed and the Divider Shell is installed.

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b. The HI-TRAC CS cask is mounted on the VVM cavity and secured with large fasteners that are sized to protect the cask from tip- over under the site's DBE.

c. The canister is lowered into the storage cavity.

d. After the HI-TRAC Transfer Cask is removed then the Closure Lid is installed.

The loading operation is characterized by the following essential features:

a. The vertical insertion (or withdrawal) of the canister eliminates the risk of gouging or binding of the canister with the CEC parts.

b. All load handling operations are carried out using the Vertical Cask Transporter (VCT) that meets the criteria for lifting devices in Subsection 1.3.3 to preclude uncontrolled lowering of the load.

Details of the generic operational steps involving either installation or removal of the loaded canister at the HI-STORE CIS facility are provided in Section 10.3 along with reference to the safety measures that are known from experience to avert human performance errors. The visual depiction of the required ope rational steps in Figures 3. 1. l (a-v) provides a brief illustration of the loading steps for the HI-STORM UMAX CIS.

1.2.5.1 Design Features The design features of the HI-STORM UMAX System are intended to meet the following principal performance characteristics under all credible modes of operation:

a. Prevent unacceptable release of contained radioactive material at all times.

b. Minimize occupational and site boundary dose.

c. Permit retrievability of contents (the canister must be recoverable after accident conditions in accorda nce with ISGs 2 and 3 [1.2.5, 1.2.6]).

Chapter 11 identifies the many design features built into the HI-STORM UMAX Syste m to minimize dose and maximize personnel safety. Among the design features intrinsic to the system that facilitate meeting the above objectives are:

a. The loaded canister is always maintained in a vertical orientation during its handling at the ISFSI and is handled using ANSI Nl4.6 [l.2.4] compliant ancillaries.

b. Almost all personnel activities during canister transfer occur at ground level which helps promote safety and ALARA.

1.2.5.2 Identification of Subjects for Safety and Reliability Analysis (a) Criticality Prevention Every canister brought over to the HI-STORE facility must be approved under a USNRC docket to store used nuclear fuel or HLW. Therefore, the criticality compliance of the canister at HI-STORE is assured, as discussed in Chapter 8 of this report.

(b) Chemical Safety Page 40 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TEC PROPRleTARY l~lFORMATION There are no chemical safety hazards associated with operations of the HI-STORM UMAX System. No chemicals are stored inside the Protected Area.

(c) Operation Shutdown Modes The HI-STORM UMAX System is totally passive and consequently, operation shutdown modes are unnecessary.

(d) Instrumentation As stated earlier, the HI-STORM UMAX canister, which is seal welded, non-destructively examined, and pressure tested, confines the radioactive contents. The HI-STORM UMAX is a completely passive system with appropriate margins of safety; therefore, it is not necessary to deploy any instrumentation to monitor the cask in the storage mode.

(e) Maintenance Program Because of its passive nature, the HI-STORM UMAX System requires minimal maintenance over its lifetime. Section 10.3 describes the maintenance program set forth for the HI-STORM UMAX System.

1.2.6 Cask Contents This sub-section contains information on the cask contents pursuant to 10CFR 72.236(a),(m).

Only those canisters certified to be stored in the HI-STORM UMAX system in Docket # 72-1040 are permitted to be stored at HI-STORE CIS Facility.

Section 4.1 provides additional details.

1.2.7 Ancillary Equipment Used at HI-STORE CIS Ancillary equipment for the HI-STORE CIS are those that are needed to conduct cask and canister handling and transfer operations in full compliance with the safety and ALARA commitments.

The major ancillary equipment includes:

a. Vertical Cask Transporter

b. Gantry Crane

c. Cask Tilt Frame

d. Special Lifting Devices T he above list does not include minor ancillaries that are available for procurement to the applicable ANSI standards such as common rigging, ladders, platforms, equipment stands, service and mobile cranes for handling non-critical loads, etc. The above list does not include commercial test and measurement equipment such as radiological survey equipment, leak testing equipment a nd cask test connectors.

The Design Criteria for the above major ancillaries are provided in Section 4.5, and analyses are presented in Sections 5.4 and 5.5; a brief description is provided below.

Page 41 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROPRIETARY l~Jf=ORMATIOl'>I

a. Vertical Cask Transporter The Vertical Cask Transporter (VCT) is the principal load handling device used for MPC transfer operations at the HI-STORE ClS. Used in conjunction with the special lifting devices, it provides the critical lifting and handling fun ctions associated with the canister transfer operations. It is a custom-designed equipment consisting of a set of caterpillars or multiple wheels, a diesel engine with a robust gear train and transmission housed in a rugged structural frame that also supports a set of hydraulically-actuated lifting towers. Figure 1.2.4 illustrates the general configuration of a VCT. The VCT uses the same controls and red undant drop protection features used to prevent an unplanned lowering of the critical load under a loss-of-power or hydraulic system failure as used at other ISFSis in the United States where the VCT is performing the canister transfer operations.

b. Gantry Crane:

The Cask Handling Crane System consists of a crane, trolley, and hoist(s). The Crane System is electricall y driven and rides on crane rails which are mounted to its supporting structure in the Cask Receiving Area. The trolley rides on crane rails mounted to the top of the crane girders and has at least one electric wire rope hoist for load lifting. The hoist hook will be used to lift the load and sha ll interface with the required rigging and below the hook lifting devices as required for the process.

The Crane System shall comply with ASME NOG-1 [3.0.1], and the latest revision of CMAA 70

[4.5.2], and OSHA. Design criteria for the Gantry crane is in Chapter 4 of this SAR.

c. Cask Tilt Frame:

The Cask Tilt Frame is used in conjunction with the Gantry Crane and its special lifting devices to transfer the HI-ST AR 190 Transport Cask between the vertical and horizontal orientations.

The Cask Tilt Frame consist of a set of trunnion support stanchions and a cask support saddle.

The trunnion support stanchions engage the cask's rotation trunnions and provide a low-friction rotation point for cask tilting. The saddle supports the upper portion of the cask when the cask reaches the horizontal orientation. A brief illustration of the upending of a HI-STAR 190 Transport Cask or using the Crane and Tilt Frame through insertion into the CTF is demonstrated in Chapter 3. Downending of the HI-STAR 190 is performed in the reverse order for shipments away from the CIS.

d. Special Lifting Devices:

The Special Lifting Devices include those lifting components used to connect the cask or canister to the Gantry Crane or the VCT's lift points, as illustrated in Figure 1.2.4. Special Lifting Devices are defined in ANSI N 14.6 [1.2.4].

Page 42 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLT EC LETTER 5025025 HOLT EG PROPRIETARY INFORMATION Figure 1.2.1: illustration of an Array of HI-STORM UMAX Systems Page 43 of 689 Revision OC May 201 8

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION Closure Lid Canister Divider Shell Cavity Enclosure Container Figure 1.2.2(a): VVM Components Shown in Exploded, Cut-Away View Page 44 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Figure 1.2.2(b): VVM Components Shown in Assembled, Cut-Away View Page 45 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMAT ION Support Foundation Pad Figure 1.2.2(c): UMAX ISFSI in Partial Cut-Away View Page 46 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Figure 1.2.3a: HI-TRAC General Configuration Shown with Shield Gates Closed and Open Page 47 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATIOM (b)(4)

Figure 1.2.3b: HI-TRAC CS Bottom End Cross Section View Showing Air Flow Passages Through the Shield Gates Page 48 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETAR'1' llqfiORMAilOlq HI-TRAC lifting link Figure 1.2.4: Vertical Cask Transporter (VCT) with loaded HI-TRAC CS Transfer Cask and Special Lifting Device Page 49 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMATIOM 1.3 IDENTIFICATION OF AGENTS AND CONTRACTORS This section contains the necessary information to fu lfill the requirements pertaining to the qualifications of the applicant pursuant to 10CFR72.22. Holtec International, with its operation centers in Florida, New Jersey, Pennsylvania, and Ohio in The United States, is the system designer and applicant for certification of the HI-STORE CIS facility.

Holtec International is an engineering technology company with a principal focus on the power industry. Holtec International Nuclear Power Division (NPD) specializes in spent fuel storage technologies. NPD has can-ied out turnkey wet storage capacity expansions (engineering, licensing, fabrication, removal of existing racks, performance of underwater modifications, volume reduction of the old racks and hardware, installation of new racks, and commissioning of the fuel pool for increased storage capacity) in numerous nuclear plants around the world. Over 90 plants in the U.S., Britain, Brazil, Korea, Mexico, China and Taiwan have utilized the Company's wet storage technology to establish their state-of-the-art in-pool storage capacities.

Holtec's NPD is also a turnkey provider of dry storage and transportation technologies to nuclear plants around the globe. The company is contracted by 59 nuclear units in the U.S. and 42 overseas to provide the company's dry storage and transport systems. Utilities in Belgium, China, Korea, Spain, South Africa, Sweden, Ukraine, the United Kingdom and Switzerland are also active users of Holtec lnternational's dry storage and transpo1t systems.

Four U.S. commercial plants, namely, Dresden Unit 1, Trojan, Indi an Point Unit 1, and Humboldt Bay have thus far been completely defueled using Holtec lnternational's technology.

For many of its dry storage clients, Holtec International provides all phases of dry storage including: the required site-specific safety evaluations; ancillary designs; manufacturing of all capital equipment; preparation of site construction procedures; personnel training; dry runs; and fuel loading. The USNRC dockets in 10CFR71 and 10CFR72 currently maintained by the Company (as of February 20 17) are listed in Table 1.3. 1.

Holtec lnternational's corporate engineering consists of professional engineers and experts with extensive experience in every discipline germane to the fuel storage technologies, namely structural mechanics, heat transfer, computational fluid dynamics, and nuclear physics. Virtually all engineering analyses for Holtec's fuel storage projects (including HI-STORM UMAX) are carried out by the company's full-time staff. The Company is actively engaged in a continuous improvement program of the state-of-the-art in dry storage and transport of spent nuclear fuel.

The active patents and patent applications in the areas of dry storage and transport of SNF held by the Company (ca. June 2016) are listed in Table 1.3.2. Table 1.3.3 lists Holtec patents on dry storage technologies that have been published by the US patent office but not yet granted. Many of these listed patents have been utilized in the design of the HI-STORM UMAX Syste m.

Holtec Intem ational's quality assurance (QA) program was originally developed to meet NRC requirements delineated in 10CFR50 [ 1.3. 1], Appendix B, and was expanded to include provisions of 10CFR7 l [l.3.2], Subpart H, and 10CFR72 [1.0.5], Subpart G, for structures, systems, and components designated as important to safety. The Holtec quality assurance program, which satisfies all 18 criteria in 10CFR72, Subpart G, that apply to the design, Page 50 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMATIOM fabrication, construction, testing, operation, modification, and decommissioning of structures, systems, and components important to safety is incorporated by reference into this SAR. Holtec Intemational's QA program has been certified by the USNRC (Certificate No. 7 1-0784) [12.0. l ].

The HI-STORM UMAX System will be fabricated by the manufacturing plants owned by Holtec International and operated under the Company's QA program. The Company's HMO in Pittsburgh is a long-term ASME N-Stamp holder and fabricator of nuclear components. In particular, HMO has been manufacturing HI-STORM and HI-STAR system components since the inception of Holtec International' s dry storage and transportation program in the 1990s.

HMO routinely manufactures ASME code components for use in the U.S. and overseas nuclear plants. Holtec lntemational's engineering and manufacturing organizations have been subj ect to triennial inspections by the USNRC. If another fabricator is to be used for the fabrication of any part of the HI-STORM UMAX System, the proposed fabricator will be evaluated and audited in accordance with Holtec Intemational 's QA program approved by the USNRC.

Holtec Intemational's Nuclear Power Division (NPD) also can-ies out site services for dry storage deployments at nuclear power plants. N umerous nuclear plants, such as Trojan and Waterford 3 , Waterford 3, Pilgrim and Comanche Peak have deployed dry storage at their sites using a turnkey contract with Holtec International.

The Company has considerable prior experience in the design and licensing of AFRs sites, having successfully led the licensing of PFS, LLC's Skull Valley in Utah (2005) and the "Central Spent Fuel Storage Faci lity" in Ukraine (ongoing).

Page 51 of 689 Revision OC May 2018

A TTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRleT/1.RY lf>lf=ORM.'\TION Table 1.3.1:

USNRC DOCKETS ASSIGNED TO HOLTEC INTERNATIONAL System Name Docket Number HI-STORM 100 (Storage) 72- 1014 [1.3.3]

HI-ST AR 100 (Storage) 72- 1008 [l. 3.4]

HI-STAR ATB 1T (Transportation) 7 1-9375 HI-STAR 100 (Transportation) 7 1-9261 [l. 3.5]

HI-STAR 180 (Transportation) 7 1-9325 HI-STAR l 80D (Transportation) 7 1-9367 HI-STAR 190 (Transportation) 7 1-9373 [1.3.6]

HI-ST AR 60 (Transportation) 71-9336 HI-ST AR 80 (Transportation) 7 1-9374 Holtec Quality Assurance Program 71-0784 [12.0. 1]

HI-STORM FW (Storage) 72-1032 [1.3.7)

HI-STORM UMAX (Storage) 72-1040 [1.0.6)

Page 52 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY lf>lf=ORMATIOl'>I Table 1.3.2: Dry Stora2e and Transport Patents Held by Holtec International Item Colloquial Name of the Patent USPTO Patent No. Number

1. Honeycomb Fuel Basket 5,898,747

2. Radiation Absorbing Refractory Composition (METAMIC) 5,965,829

3. HI-STORM lOOS Overpack 6,064,710

4. Extrusion Fabrication Process for Discontinuous Carbide 6,042,779 Particulate Metal Matrix Composites and Super Hypereutectic A 1/S 1(MET AMIC-CLASSIC)

5. Duct Photon Attenuator 6,519 ,307B 1

6. HI-TRAC Operation 6,587,536Bl

7. Cask Mating Device (Hermetically Sealable Transfer Cask) 6,625,246B l

8. Improved Ventilator Overpack 6,718,000B2

9. Below Grade Transfer Facility 6,793,450B2

10. HERMIT (Seismic Cask Stabilization Device) 6,848,223B2

11. Cask Mating Device ( operation) 6,853,697

12. Davit Crane 6,957,942B2

13. Duct-Fed Underground HI-STORM 7 ,068,748B2

14. Forced Helium Dehydrator (design) 7 ,096,600B2

15. Below Grade Cask Transfer Facility 7,139,358B2 16 . Forced Gas Flow Canister Dehydration 7,210,247B2 (alternate embodiment)

17. HI-TRAC Operation (Maximizing Radiation Shielding During 7,330,525 Cask Transfer Procedures)

18. HI-STORM lOOU 7 ,330,526B2

19. Flood Resistant HI-STORM 7,590,213Bl

20. HI-STORM 100M (Underground Manifolded module assembly) 7,676,016B2

21. Dew Point Temperature Based Canister Dehydration 7,707,741B2

22. Optimized Weight Transfer Cask with Detachable Shielding 7,786,456B2

23. VESCAP (Apparatus, System, and Method for Facilitating Transfer 7 ,820,870B2 of High Level Radioactive Waste to and/or From a Pool

24. HI-STORM lOOF (Counter-flow Underground Vertical Ventilated 7,933,374B2 Module)

25. Apparatus for Transporting and/or Storing Radioactive Materials 7 ,994,380B2 Having Jacket Adapted to Facilitate Thermo-siphon Fluid Flow

26. M ethod of Removing Radioactive Materials from Submerged State 8,067,659B2 and/or Preparing Spent Nuclear Fuel for Dry Storage

27. HI-STORM lOOUS 8,098,790B l

28. Canister Apparatus and Basket for Transporting, Storing and/or 8, 135,107B2 Supporting Spent N uclear F uel(Double Wall Canister)

29. Apparatus System and M ethod for Low Profile Translation of High 8,345,813 Level Radioactive Waste Containment Structure (L ow Profile Page 53 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRleTARY l~lFORMAT ION Table 1.3.2: Dry Stora2e and Transport Patents Held by Holtec International Item Colloquial Name of the Patent USPTO Patent No. Number Transporter)

30. Method of Storing High Level Waste (HI-STORM lOOF) 8,345,813B2

31. Apparatus for Providing Additional Radiation Shielding to a 8,415,521B2 Container Holding Radioactive Materials, and Method of Using the same to Handle and/or Process Radioactive Materi als

32. Systems and Methods for Storing Spent Nuclear Fuel 8,625,732

33. System and Method for the Ventilated Storage of High Level 8,660230B2 Radioactive Waste in a Clustered Anangement

34. Method of Transferring High Level Radioactive Materials, and 8,718,221B2 System for the Same

35. Manifold System for the Ventilated Storage of High Level Waste 8,7 18,220B2 and a Method of Using the Same to Store High Level Waste in a Below-Grade Environment

36. Method and Apparatus for Preparing Spent Nuclear Fuel for Dry 8,737,559B2 Storage

37. Apparatus for Storing and/or Transporting High Level Radioactive 8,798,224B2 Waste, and Method for Manufacturing the Same

38. Method for Controlling Temperature of a Portion of a Radioactive 9,105,365B2 Waste Storage Svstem and for Implementing the Same

39. Ventilated System for Storing High Level Radioactive Waste 8,905,259B2 Page 54 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRleTARY ll'>IFORMATIOl'>I Table 1.3.3: Holtec International Pending Patents on Fuel Storage Title Submittal USPTO Publication Date FILE Number NUMBER

1. System And Method For The Ventilated Storage 22-Dec-08 12340948 US2009 0159550 Of High Level Radioactive Waste In A C lustered Arrangement(HIC-Storm)

2. Spent Fuel Basket, Apparatus And Method 02-Jul-07 11772610 US2008003 l 396 Using The Same For Storing High Level Radioactive Waste (HI-STAR 180)

3. System And Method For Storing Spent Nuclear 19-Feb- 10 12709094 US20100150297 Fuel Having Manifolded U nderground Vertical Ventilated Module (100M)

4. Cask Apparatus, System And Method For 28-Apr-10 12769622 US20100272225 Transporting And/Or Stori ng High Level Waste (HI-SAFE)

5. Spent Fuel Basket For Storing High Level 29-0ct-08 12260914 US20090175404 Radioactive Waste (HEXCOMB Racks)

6. Shield Transfer Canister for Inter-Unit Transfer 16-Dec-10 12970901 US20110150164 of Spent Nuclear Fuel

7. Method of Removing Radioactive Materials 29-Nov-11 13306948 US2012014299 1 from a Submerged State and/or Preparing Spent Nuclear Fuel for Dry Storage

8. System and Method of Storing and/or 18-Apr-1 3 61625859 W0201 3158914 Transferring High Level R adioactive Waste

9. Container and System for Handling Damaged 19-Feb- 14 61525583 W0201 3055445 Nuclear Fuel and Method of Making Same

10. S ubterranean Canister Storage System For 10-Mar- 14 61532397 US20140226777A 1 Monitored Retrievable Storage of Nuclear Materials

11. Vertical Ventilated Cask with Distributed Air 13-May-14 14358032 US201 4329455Al Inlets for Storing Fissile Nuclear Materials

12. A Radioactive Material Storage Canister and 03-Jul- 14 61746094 US20150340112 Method for Sealing Same

13. Method of Storing High Le vel Radioactive 07-Jul- 14 13736452 US20140192946A l W aste

14. System and Method for Minimizing Movement 26-Feb- 15 61694058 US20150310947 of Nuclear Fuel Racks During a Seismic Event Page 55 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMAT IOM Table 1.3.3: Holtec International Pending Patents on Fuel Storage Title Submittal USPTO Publication Date FILE Number NUMBER

15. System and Method for Storing and Leak 26-Feb-15 61695837 W02014036561 Testing a Radioactive Mate rials Storage Canister

16. High-Density Subterranean Storage System for 10-Dec- 15 14760215 US20150357066A 1 Nuclear Fuel and Radioactive Waste

17. System for Storing High Le vel Radioactive 07-Jul-16 15053608 US20160196887Al Waste

18. Storage System for Nuclear Fuel 14-Jul-16 14912754 US20160203884A 1 Page 56 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY l~JFORMATION 1.4 MATERIAL INCORPORATED BY REFERENCE Materials incorporated by reference into this report are discussed in Section 1.0 and identified in Table 1.0.3. The majority of this information is incorporated from the HI-STORM UMAX docket, with some supplementary information from the HI-STORM FW. Each individual chapter provides a table which identifies the specific material incorporated by reference into each chapter, with specific sections and specific references.

Page 57 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLT EG PROPRIETARY INFORMAT ION 1.5 LICENSING DRAWINGS The licensing drawings for the HI-STORM UMAX System, the HI-TRAC Transfer Cask and other important to safety anci llary systems/components employed at the HI-STORE CIS, pursuant to the requirements of 10CFR72.24(c)(3), are provided in this section. The licensing drawings contain the necessary information to enable the margins of safety under different operating modes for the facility to be quantified in a conservative manner to support its safety case.

The drawing packages developed specifically for the proposed HI-STORE facility are listed in Table 1.5.1 and placed in their numerical sequence at the end of this chapter.

Table 1.5.1: Drawin2 Packa2es for the HI-STORE CIS Facility Revision Drawing Caption Number 10868 HI-TRAC CS 0 10895 Cask Transfer Facility (CTF) 0 10899 Tilt Frame 0 10875 HI-STORM UMAX Vertical Ventilated Module (Version C) 0 10902 Lift Yoke for HI-STAR 190 l 10900 Lift Yoke got HI-TRAC CS 1 10894 HI-STAR Horizontal Lift Beam 0 10901 HI-TRAC CS Lift Link 0 10891 MPC Lift Attachment l 10889 MPC Lifting Dev ice Extension 1 10912 Cask Transfer Building Floor Slab 0 10940 HI-STORE Site Plan and General Arrangement 0 6505 MPC-37 Enclosure Vessel 17 65 12 MPC-89 Enclosure Vessel 18 Page 58 of 689 Revision OC May 2018

(b){41 (b){41

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRleT/1.RY lf>lf=ORM.'\T ION-1.6 REGULATORY COMPLIANCE This section ensures compliance with 10CFR72.18, 72.22, 72.24 and 72.44 as indicated m NUREG 1567 [1.0.3] Section 1.

10CFR72.18 discusses material incorporated by reference, wh ich is discussed in Section 1.4.

10CFR72.22 requires that general and financial information about the applicant is prov ided, including age, address, description of business, estimated cost of construction and operation of the facility and decommissioning, which is discussed in Section 1.3 (with the exception as indicated below).

10CFR72.24 requires that the application includes technical information , including overview of the installation, principal characteristics of the ISFSI (dimensions, weights, and construction materials, licensing drawings), facility allowance for decommissioning (retrievability), and general description of contents to be stored at the facility. Information regarding fac ility systems descriptions and agents and contractors are required to be provided.

10CFR72.44 describes the license conditions, which are provided in the license document for the facility.

The chapter complies with 10CFR72 requirements above and follows the guidance of NUREG-1567 [1.0.3] with the following qualifications:

1. For proprietary reasons financial information, including cost of construction, operation and decommissioning will be submitted separately from this SAR.

2. Due to the significant quantity of material incorporated by reference into this SAR, information regarding weights will be incorporated by reference into other chapters for analysis purposes. As such, to maintain adequate configuration control, information on weights will be included in Chapter 5 (Structural) of this report. Similarly, information on contents to be stored in the HI-STORM UMAX is provided in Chapter 4 of this report.

Page 97 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INf'ORMATION CHAPTER 2: SITE CHARACTERISTICS*

2.0 INTRODUCTION

This chapter presents the relevant characteristics of the proposed HI-STORE Consolidated Interim Storage (CIS) Facility site (Site). The purpose of this chapter is to: (1) characterize local land and water use and population so that individuals and populations likely to be affected can be identified; (2) identify the external natural and man-induced phenomena for inclusion in design basis considerations; and (3) characterize the transport processes which could move any released contamination from the facility to the maximally exposed individuals and populations. More details regarding the environmental characteristics of the Site and surroundings is found in the Environmental Report (ER) [1.0.4].

All references are placed within square brackets in this report and are compiled in Chapter 19 of this report Page 98 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATIOM 2.1 GEOGRAPHY AND DEMOGRAPHY 2.1.1 Site Location The center of the Site is at latitude 32.583 north and longitude 103.708 west, in Lea County, New Mexico, 32 miles east of Carlsbad and 34 miles west of Hobbs (Figure 2.1. l ). Larger population centers are Roswell, New Mexico, 74 miles to the northwest; Odessa, Texas, 92 mjles to the southeast; and Midland, Texas, also to the southeast at 103 miles. The nearest international airport is located between Midland and Odessa, Texas 98 miles to the southeast.

2.1.2 Site Description The Site is currently owned by the Eddy-Lea Energy Alliance (ELEA), a limited liability company owned by the cities of Carlsbad and Hobbs, and Eddy County and Lea County. In April 2016, Holtec and ELEA signed a memorandum of agreement (MOA) [2. 1.1] covering the design, licensing, construction and operation of the Site. Among other things, that MOA provides the terms by which Holtec could purchase the Site. On July 19, 201 6, the New Mexico Board of Finance approved the sale of the Site to Holtec [2.1.2].

The Site consists of mostly undeveloped land used for cattle grazing with the only boundary being a four-strand barb wire fence along the south side of the property until it nears Laguna Gatuna, where it turns south to the highway. This fence is the boundary between two grazing allotments administered by the Bureau of Land Management (BLM). The maj ority of allotments are grazed year-round with some type of rotational grazing. Figure 2. 1.2 depicts the Site boundaries.

Rangelands comprise a substantial portion of the Site and provide forage for livestock. Pasture rotation, with some of the p astures being rested for a least a portion of the growing season, is standard management practice for grazing allotments. Grazing allotments near the site can be seen in Figure 2. 1.3. Vegetative monitoring studies to collect data on the utilization of the land, and the amount of precipitation by pasture from each study allotment are conducted annually on Federal lands to compare production with consumption. Currently, the BLM permits nine animal unit months' per 640 acres [2.1.3]. Because the Site is privately held, it does not fall under the BLM range management rules, although the rules apply to most of the adjacent lands that are managed by the same rancher.

The following list of structures is shown on Figures 2. 1.2, 2. 1.13, and 2.1 .20. A map of the utility infrastructure is shown on F igure 2.1.4. An aerial view of the Site is shown in Figure 2. 1.5 and several plot views of the HI-STORE CIS Facility with all Phases complete are shown in Figures 2.l.6(a), (b), and (c).

A communications tower in the southwest corner of the Site;

A former producing gas and distillate well is located near the communications tower;

A small water drinker (livestock) is located along the aqueduct in the northern half of the Site;

Oil recovery facility (abandoned) that still has tanks and associated hardware left in place in the northeast corne r; 1

An "animal unit month" is the amount of forage needed to feed a cow for one month.

Page 99 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC F'~OF'RIETARY INFORMATION

An o il recovery facility with tanks and associated hardware still in place in the far southwest corner;

Existing natural gas pipelines run underground alo ng the North-South axis to the East of the Site;

A temporary flexible pipeline for natural gas runs aboveground diagonally through the center of the Site.

As can be seen in Figure 2.1.2, the oil recovery facility that is currently in place in the southwest corner of the Site is a potential fire hazard to the SSCs of the CIS Facility. Table 2. 1.4 lists conservative values for input parameters used to assess the risk this oil recovery facility poses to the SSCs of the CIS Facility. A detailed discussion of this evaluation is presented in S ubsectio n 6.5.2.

The natural gas pipelines can be seen in Figures 2.1.13 and 2. l.20. The temporary fl ex ible pipeline that runs aboveground through the center of the Site will be moved prior to or during the early construction phases of the CIS Facility. The natural gas pipelines which run along the North-So uth ax is to the East of the site are underground and not considered to present a threat to the C IS Facility operations.

No water wells are located on the Site. However, the Site has been associated with o il and gas exploration and development with at least 18 plugged and abandoned o il and gas wells located on the property. However, none of these plugged and abando ned oil and gas wells are located within the area where the ISFSI would be located or where any la nd would be disturbed and they are not expected to affect the construction and operation of the CIS Facility. The plugged wells are estimated to be 30-70 years o ld. It is possible that hydrocarbon contamination exists at the Site as a result of these past practices [1.0.4]. There are no active wells on the Site and there are no plans to use any of the plugged and abandoned wells on the Site.

United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) Soil Survey Maps of Lea County, NM [2. 1.4] were reviewed in order to identify the soil units present at the Site. A Soil Survey Map is provided as Figure 2. 1.7. Abo ut 90 percent of the soils within the Site are classified as Simona-Upton association (SR) and Simona fine sandy loam (SE). Simona soils are calcareous eolian deposits derived from sedimentary rock and consist of fine sandy loam underlain by gravelly fine sandy loam and cemented material , and gravelly fine sandy loam underla in by fine sandy loam and cemented material. The rema ining soil s (approximately 10 percent) consist of Midessa and wink fine sandy loam (MN), Mobeetie Potter Association (MW), Stony rolling land (SY), and Mixed alluvial land (M U). Details regarding the Site soil types and characteristics were compiled from Appendix D of the ER [1.0.4], and are summarized below.

Simona-Upton Association (SR)

Simo na (50 percent of soil unit)

0 to 8 inches: gravelly fine sandy loam; saturated hydraulic conducti vity (Ksat) of 14.11 to 42.34 micrometers per second.

8 to 16 inches: fine sandy loam; Ksat of 14. 11 to 42.34 micrometers per second.

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ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROPRIETARY INFORMAT ION

16 to 26 inches: cemented material (Petrocalcic Restrictive Layer i.e. Caliche); Ksat of 0.00 to 0.42 micrometers per second.

Upton (35 percent of soil unit)

0 to 8 inches: gravelly loam; Ksat of 4.23 to 14. 11 micrometers per second.

8 to 18 inches: cemented material; Ksat of 0 .07 to 4.23 micrometers per second.

18 to 60 inches: very gravelly loam; Ksat of 4.23 to 14. 11 micrometers per second.

Simona fine sandy loam (SE)

0 to 8 inches: fine sandy loam; Ksat of 14.11 to 42.34 micrometers per second.

8 to 16 inches: gravelly fine sandy loam; K sat of 14.11 to 42.34 micrometers per second.

16 to 26 inches: cemented material (Petrocalcic Restrictive Layer i.e. Caliche); Ksat of 0.0 to 0.42 micrometers per second.

Midessa and wink fine sandy loams (MN)

Midessa (45 percent of soil unit)

0 to 4 inches: fine sandy loam; Ksat of 14.11 to 42.34 micrometers per second.

4 to 22 inches: clay loam; Ksat of 1.35 to 1.55 micrometers per second.

22 to 60 inches: clay loam; Ksat of 4.23 to 14.11 micrometers per second.

Wink (40 percent of soil unit)

0 to 12 inches: fine sandy loam; Ksat of 14.11 to 43.34 micrometers per second.

12 to 23 inches: sandy loam; Ksat of 14. 11 to 43.34 micrometers per second.

23 to 60 inches: sandy loam; Ksat of 14.11 to 43.34 micrometers per second.

Mobeetie-Potter Association (MW)

Mobeetie (70 percent of soil unit)

0 to 4 inches: fine sandy loam; Ksat of 14.11 to 43.34 micrometers per second.

4 to 24 inches: fines sandy loam; Ksat of 14. 11 to 43.34 micrometers per second.

24 to 60 inches: fine sandy loam; Ksat of 14. 11 to 43.34 micrometers per second.

Potter (24 percent of soil unit)

0 to 4 inches: gravelly fine sandy loam; K sat of 4.23 to 14.11 micrometers per second.

4 to 14 inches: extremely cobbl y loam; K sat of 4.23 to 42.34 micrometers per second.

Stony rolling land (SY)

Page 101 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC F'~OF'~IETAFH INFO~MATIOI~

Ton-iorthents (85 percent of soil unit)

0 to 20 inches: extremely gravelly sandy loam; Ksat of 14.11 to 42. 34 micrometers per second.

20 to 60 inches: bedrock; Ksat of 0.42 to 14.00 micrometers per second.

Mixed alluvial land (MU)

Ustifluvents (85 percent of soil unit)

0 to 60 inches: stratified sand to loamy fine sand to loam to sandy clay loam to clay loam to clay; K sat of 0.42 to 141.14 micrometers per second.

Appendix D of the ER [1.0.4] provides additional information regarding soil descriptions, soil features, and physical, chemical, and engineering properties, including soil salinity. Laboratory analyses of soil samples within the Site indicated chloride concentrations of 26-43,000 mg/kg in the soil [2.1.3]. The soil samples were taken in the eastern portion of the Site, in areas previously used for oilfield disposal. The highest chloride concentrations are considered to be localized and not reflective of the concentrations where the CISF would be located [2. 1.3]. A review of the available soil data, including engineering properties of the Site soils, indicates favorab le conditions for foundations, utilities, surface pavement, and other improvements [2.1.3]. Removal of fill would not induce seismic activity or affect subsurface faults [1.0.4]. Section 4.3 of the ER [1.0.4] provides additional details regarding the potential impacts of the CIS Facility on soils, including a discussion of construction activities adjacent to a finished ISFSI structure.

In December of 2017, a site characterization for HI-STORE CISF Phase 1 was completed . The field explorations included borings and geophysical testing at the HI-STORE site. Figure 2. 1.8 shows the location of the 9 borings and ancillary borings. Detailed profiles for these borings can be found in the Geo technical Data Report prepared by GEl [2. 1.24] or in Sections 2.5 and 2.6 of this report.

Vegetation and habitats within the Site and immediately sunounding area are common within the region. The Site does not support any vegetation of significance. Significance is defined in this document as any plant, animal, or habitat that: (1) has high public interest or economic value or both; or (2) may be critical to the structure and function of the ecosystem or provide a broader ecological perspective of the region.

The Project area is in the primary vegetation community of Desert Grasslands, which is w idespread at lower elevations in southern and western New Mexico. These communities are characterized by significant amounts of grasses and less than 10 percent of total cover being forbs and shrubs

[2.1.5]. Typical vegetation in Desert Grassland communities include black grama (Bouteloua eriopoda), blue grama (Bouteloua gracilis), bluestem, buffalo grass (Bouteloua dactyloides), western wheatgrass (Pascopyrum smithii), galletas (Hilaria spp.), tobosa (Pleuraphis mutica), alkali sacaton (Sporobolus airoides), three-awn (Aristida spp.), mesquite (Prosopis spp.), serviceberry (Amelanchier denticulate), skunkbush sumac (Rhus trilobata), sand sagebrush (Artemisia .fil(folia), Apache plume (Fallugia paradoxa), creosotebush (Larrea tridentata), and cliffrose (Purshia mexicana). With appropriate moisture (generally more than is typically experienced) sunflower (Helianthus annuus), croton (Croton spp.), and pigweed (Amaranthus palmeri) may grow in disturbed or ponded depressions.

Page 102 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY llqfiORMAT IOlq A biological survey in October of 2016 (Appendix Bin the ER [1.0.41) also documented a variety of mesquite scrubland and very few grassland species. This further indicates that vegetation in the area has changed from a desert grassland to mesquite scrubland due to overgrazing. The dominant species documented during this survey include broom snakeweed, honey mesquite, prairie verbena (Glandularia bipinnatifida), prickly pear (Opuntia engelmannii), scarlet globemallow (Sphaeralcea coccinea), silverleaf nightshade (Solanum elaeagn~folium), tobosa grass, western peppergrass (Lepidium montanum), and wooly croton (Croton capitatus).

The topography of the Site shows a high point located on the southern border of the Site and gentle slopes leading to the two drainages (Laguna Plata and Laguna Gatuna). Both of these drainages would be able to accept a one day severe storm total within the 7.5 inch range with excess free board space. The natural drainage of the Site is useful by providing a natural area for impoundment of excess runoff during severe storms [2.1.3]. Figures 2.1. 9 - 2.1.1 1 depict the topography for the Site and the surrounding area.

There are no United States Army Corps of Engineers (USACE) jurisdictional wetlands on the Site

[2.1.3]. Additionally, there no floodplains identified or mapped for the Site or Lea County, New Mexico [2.1.6, 2.1.7].

2.1.3 Population Distribution and Trends This section describes population distribution and trends for the 50-mile region of influence (ROI) surrounding the proposed Site including Lea and Eddy Counties in New Mex ico and Andrews and Gaines Counties in Texas (see Figure 2. 1.12). Lea County is primarily rural, as are the other counties in the ROI. Between 2000 and 2010, the population in the ROI has grown at a slower rate in comparison to New Mexico-wide population growth. Population estimates in the ROI are proj ected to grow at a slower rate than New Mexico, increasing 10 percent between 2015 and 2025 while New Mexico is projected to increase 19 percent during the same time period. Table 2. 1. l lists historical population and Table 2.1.2 lists projected population in the ROI and New Mexico and Texas.

The population in the ROI in 2015 was estimated to be 166,914 [2.1.9]. In 2015, 43 percent of the population of the ROI resided in Lea County, New Mexico. Between 2010 and 2015, the counties within the ROI all experienced an increase in population. Gaines County, Texas had the greatest increase at 14 percent, while Eddy County, New Mex ico had the lowest increase at seven percent during the same time period.

The nearest residence to the S ite is the Salt Lake Ranch located 1.5 miles north of the Site. There are additional residences at the Bingham Ranch, two miles to the south, and near the Controlled Recovery Inc. complex, three miles to the southwest. There is an average population of less than 20 residents among the five ranches within a six mile radius. This is a population density of less than 5 residents per square mile [2. 1.3]. Table 2. 1.3 presents the population density per square mile of land for the ROI in 2010. Figure 2. 1.13 presents a sector map of population in segments surrounding the Site for distances of 1, 2, 3, 4, and 5 miles. As shown on that Figure, there are only 9 people living within 5 miles of the proposed Site. As discussed in Section 3.8.1 of the ER, population estimates in the Region of influence (ROI) are projected to grow at a slower rate than New Mexico, increasing 10 percent between 2015 and 2025, while New Mexico is projected to increase 19 percent during the same time period. Assuming a 10 percent growth between 201 5 and Page 103 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION 2025, the projected population living within 5 miles of the CIS Facility would grow from 9 to 10 persons.

With regard to transient populations within 5 miles of the CIS Facility, Holtec contacted all employers within 5 miles a nd determined that there are currently approximately 303 persons working within 5 miles of the CIS Facility boundary, broken down as follows:

Land Farm (R360 Disposal): 1.9 miles southwest of the CIS Facility Site boundary; 43 full time equivalent (FTE) workers;

Intrepid East Mine: 4.9 miles east of the CIS Facility Site boundary; 2 10 FTE's;

Intrepid N orth Mine: 4.2 miles west of the CIS Facility Site boundary; 40 FTE's;

Caliche Mine: 4 miles southwest of the CIS Facility Site boundary; 10 FTE's

[2. 1.14).

With regard to future projections, there are no reasonably foreseeable projects expected to occur within 5 miles of the CIS Facility boundary and no changes to the existing transient workforce were forecast by the employers in the area [2. l.14]. Consequentl y, it is assumed that th e transient population of 303 workers would remain constant going forward.

The nearest local school facilities, daycare, nursing homes and hospitals are located in Hobbs, NM.

The educational institutions include three colleges, a high school and an alternative high school, three middle schools, twelve elementary schools, and two private schools. The Lea Regional Medical Center is the nearest hospital. There are no school fac ilities or hospitals located within 5 miles of the proposed Site.

Because the only mechanism for radiological exposure would be from radiation (neutrons and gamma rays) emitted from the storage casks, the highest public dose would result from an individual located as close to the SNF casks as possible. For details on the radiation protection evaluation for the Site, see Chapter 11 of this SAR.

2.1.4 Land and Water Use As shown on Figure 2. 1.14 a nd 2. 1.15, almost all of the land immediately surrounding the Site is owned and managed by the BLM. Land uses in the area are limited to oil and gas exploration and production, oil and gas related services industries, livestock grazing, and limited recreational activity. Lands within six miles of the Site are privately owned, state lands, or BLM lands. Land use within six miles of the Site falls into two categories; livestock grazing and mineral e xtraction.

Within 50 miles of the Site, except for the communities located in the area, the land use and ownership is essentially the same as within the six mile radius. Along with the mining, grazing, and oil/gas activity, agriculture is a maj or activity [2. 1.3].

Lea County is approximately 2.8 million acres in size. Property ownership is 17 percent Federal government, 31 percent state government, and 52 percent pri vate. The Federally-owned land is primarily located in the southwestern portion of the county, the state-owned land is predominately located throughout the middle, and the privately owned land primarily extends from north to south in the county's eastern portio n. Large tracts of land in Lea County are privately owned by fa rmers, ranchers, oil, gas, and mining companies. Urbanized areas near cities and towns include ownership of smaller tracts of land for residential, municipal, and commercial purposes. Approximately 93 Page 104 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROPRIETARY llqfiORMAilOlq percent of Lea County is used as range land for grazing, and approximately 4 percent is used for crop farming. Urban areas and the roadway system account for the remaining land use. Most of the land acti vely farmed in Lea County is irrigated [2.1.15].

Mineral extraction in the area consists of underground potash mining and oi l/gas extraction. Both industries support major faci lities on the surface, although mining surface facilities are confined to a fairly small area. Intrepid Mining LLC (Intrepid) owns two potash mines located within 6 miles of the Site. The Intrepid North mine, located nearly 6 miles to the west, is no longer actively mining potash underground. However, the surface faci lities are still being used in the ma nufacture of potash products. The Intrepid East fac ility is still min ing its underground potash ore [2. 1.3];

however, it too is nearly 6 miles to the southwest of the site. Mineral resources near the Site, as determined from the USGS Mineral Resources Data System and the New Mexico Mining Minerals Division, are mapped on Figure 2.1.12. The USGS and NM MMD databases indicate that the CIS Facility is not co-located with existing mining facilities.

Potash was discovered in southeastern New Mexico in 1925 in a well that was being drilled for oil and gas. By the mid-1930s, there were 11 companies exploring for potash in southeastern New Mexico. The potash in southeastern New Mexico has been a major potash resource. The remaining potash reserves are estimated to be 500 million tons. Potash production continues in the Delaware Basin with active mining by Intrepid Mining and Mosaic Co. Although much of the high-grade zones have been mined out, exploration for commercially viable deposits continues [2.1.16].

Conventional mechanized underground mining operations are the most widely used method for the extraction of potash ore. A variety of mining techniques and equipment may be employed depending on factors such as: the orebody depth, geometry, thickness and consistency, the geological and geotechnical conditions of the ore and surrounding rock, and the presence of overlying aquifers. Methods in widespread use include variations of room and pillar, longwall, cut and fill, and open slope techniques. After the ore is extracted, it is generally transfe1Ted by bridge conveyor, shuttle cars or load-haul-dump units to a system of conveyors that carry it to underground storage bins, prior to haulage to the surface through a shaft by automated skips. On rare occasions shallow mines may use a decline and conveyor arrangement [2. 1.20].

In general, potash ore zones are nearly flat lying; the potash ore is mined with slightly modified conventional coal-mining equipment. Room and pillar workings are commonly 6 feet high; as much as 60-70 percent of the ore is removed during the first stage of mining. Some operations also use a second "pillar-robbing" mining technique, allowing overlying rock to settle slowly. In this manner, as much as 92 percent of the ore may be removed [2. 1.20, 2.1.16].

When the potash to be extracted is at a depth of 3,000 feet or deeper and/or the potash it is located in sedimentary rock then solution mining provides a cost effective, efficient and safe way to extract the resource. Conventional mining involves extracting a lot of rock material to access the mineral resource resulting in large underground caverns and this excess waste material must also be stored on surface. With solution mining, a bri ne is heated and injected into the deposit to dissolves the potash. The potash-rich brine is then pumped out of the cavern to the surface where the water is evaporated. Solution mining is currently used at a number of operations in New Mexico, and Page 105 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY l~lFORMAT ION Intrepid Potash was recently approved to conduct solution mining of potash minerals in order to extract some of the remaining ore from suspended mines in the main potash mining area [2.1.16].

Subsidence is the phenomenon or response that occurs when an underground opening is created.

In the Delaware Basin, subsidence caused by human activities largely has occurred as a result of potash mining and activities involving the withdrawal or injection of fluids for oil and gas production and brine extraction. Subsidence from mining creates voids that cause collapse of strata above the mining level. The overlying and surrounding rock or soil naturally deforms in an effort to arrive at a new and more stable overall equilibrium position. This equilibrium-seeking action can result in both vertical and horizontal ground movement, and, if not controlled or minimized, can cause damage to both surface and subsurface structures. It can result in the development of undesirable surface topography, such as surface cracking or collapse, sinkholes, blocking or changing stream channels, a nd modification of drainage pathways. The rate of sub sidence is largely dependent on the type of material being mined and the amount of material mined [2.1.16].

The magnitude, rate of development, and surface expression of the subsidence process are controlled by several factors, most of which are interdependent. These include mining method, depth of extraction, size and configuration of openings, rate of advance or extraction, seam thickness, topography, lithology, structure, hydrology, in situ stresses, and rock strength and deformational properties. Taken collectively, they demonstrate the complexity of the subsidence process [2.1.22].

Subsidence is expected in areas where 90 percent extraction rates occur with the room-and-pillar mining technique typically used in potash mining. Subsidence is not expected where 60-70 percent extraction rates are employed (e.g., first stage potash mining). The amount of subsidence is similar to findings concerning historic potash mining in the area where, given an average 6-feet mining extraction height, the maximum subsidence was found to be a nominal 4 feet. Subsidence fractures have been observed in the land surface above workings that have collapsed at depths of 1,000 feet or more [2.1. 16].

As a general rule, the amount of maximum subsidence (i.e., the depth of subsidence) that could occur cannot exceed the thickness of the zone of mineral extracted (the mining thickness).

Maximum subsidence depth, however, is seldom observed, due to one or more of the following reasons:

Because subsidence actually spreads over an area somewhat larger than the mined area, the subsidence is proportionally less.

Convergence, or closure of the mined area, is never fully complete or total, so some voids inevitably remain, reducing the amount of subsidence.

The overlying rocks expand slightly in volume due to breakage as the ground moves downward into the mined area, resulting in a " bulking" effect, which contributes to a reduction in subsidence volume and depth.

The subsidence process can be slow for rocks that creep--several hundred (or more) years may be required for ultimate subsidence to occur [2.1.16].

Page 106 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY l~lFORMATION It is important to note that both historic data and anecdotal evidence suggest that for the southeastern New Mexico potash mines, virtual completion of the maximum surface subsidence profile occurs within just a fe w years (5 to 7 years) after completion of mining [2.1.16].

In some instances, surface subsidence induced by underground mining may alter river and stream drainage patterns, disrupt overlying aquifers, and damage buildings and infrastructure. The degree of subsidence depends on factors such as orebody thickness and geometry, the thickness of the overlying rock and the amount of ore recovered. The effects of subsidence have been reduced to some extent, through either: (1) the design of the ore extraction layout so as to reduce the rate and exte nt of subsidence, or (2) by backfilling openings with processing wastes suc h as salt tail.ings, to reduce or prevent subsidence [2.1.21].

Figure 2.1.17 shows potash that has been historically mined within 6 miles of the proposed CIS Facility. As shown on that figure, the nearest mined potash is approximately 2 miles from the southwestern boundary of the CIS Facility Site. However, no active potash mines are within 4.2 miles of the Site. Per Mr. Robert Baldridge, Operations Manager for Intrepid Potash, potash mines in the area are generally a maximum of approximately 1,800-3,000 feet in depth, and the thickness of the zone of mineral extrac ted is a fraction of this total depth [2. 1.19]. According to Golder and Associates, "the zone of disturbance of strata above the mine workings extends beyond the limit of the mine workings and data from the southeast New Mexico potash fields suggest that a reasonable limit for defining this zone of disturbance would be an angle of 45 degrees from the vertical" [2.1.18]. Conseque ntly, for potash mining at a nominal 3,000-feet depth, the subsidence effects area could extend 3,000 feet beyond the edge of the mine workings [2. l.18]. G iven that the nearest historic potash mine is approximately 2 miles away from the CIS Facility, subsidence effects at the CIS Facility Site from past or cun-ent potash mines would not be expected to occur.

With regard to the nearest potash mine (the National Potash Mine, located approximately 4.2 miles west of the Site, and shown on Figure 2.2.1 of the SAR), no deep mining has occurred at that mine since 1982. Given that surface subsidence generally occurs within 5 to 7 years after completion of mining, no further subsidence from that mine is expected. That mine is considered a surface facility and is used by Intrepid Potash as a warehouse and distribution center [2.1. 19].

With regard to potential future potash mining near the CIS Facility, Figures 2.1.18 and 2.1.19 show the locations of potash core holes and potash leases within 6 miles of the CIS Facility Site. As shown on those fi gures, numerous potash core holes have been drilled in the areas surrounding the CIS Facility and there are potash leases surrounding the CIS Facility Site. As previously stated in Section 2.6.4 of the SAR, with regard to potential future drilling on the Site, Holtec has an agreement with Intrepid Mining LLC (Intrepid) such that Holtec controls the mineral rights on the Site and Intrepid will not conduct any potash mining on the Site.

Oil in southeastern New Mexico was discovered in 1909, 8 miles south of Artesia, but the well was never completed as a producer due to mechanical problems. Oil and gas production began in the New Mexico portion of the Delaware Basin in 1924 with the discovery of the Dayton-Artesia Fie ld. Until the year 2000, 4.5 billion barrels of oil had been produced mainly from fi elds on the Northwest Shelf and Central Platform areas in the Delaware Basin. More than 3.5 billion barrels of the total production was extracted from Permian-age rocks. The U.S. Geological Survey (USGS) estimates that the greater Permian Basin area, including parts of southeastern New Mexico Page 107 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HObTeC PROPRleT/1.RY ll'>IFORMATIOl'>I and west Texas, contains substantial undiscovered oil and gas resources on the order of 1.3 billion barrels of oil and 4 1 trillion c ubic feet of gas [2.1.16].

As a precaution for the potash mines in this region, the mining companies historically left protection pillars around the oil and gas boreholes. Well casing corrosion is a common problem in the Delaware Basin, caused by contact with the brine fluids being withdrawn or injected depending on the purpose of the well. There are documented cases where escape of unsaturated brines and dissolution of salt formations caused catastrophic collapse to the surface, not only in the Delaware Basin, but in other basins having substantial thicknesses of salt layers and numerous wells penetrating the salt for the purpose of flui d withdrawal [2. l.16].

Thousands of wells have been drilled through evaporate formations in the Delaware Basin to explore for and produce oil and gas (see Figure 2. 1.20, which depicts wells immediately surrounding the CIS Facility) Because of the extent of the evaporites (salt and anhydrite), drilling and completion operations have to be conducted in a manner that prevents the dissolution of the salt and protects the well during drilling and through the p roductive lives of the wells, often 20 to 30 years or more. Oil and gas exploration targets range from relatively shallow oil and gas at 5,000 feet deep in the Delaware Canyon Formation to deep gas targets in middle Paleozoic formations in excess of 16,000 feet deep [2. 1.16].

Salt can be extracted from subsurface formations by using wells that inject fresh water to dissolve the salt followed by extractjon of the saturated water. In the Delaware Basin, these wells are referred to as brine wells. Brine wells in the Delaware Basin are used to extract saline water for use in oil and gas well drilling and workover fluids. Recently, a few brine wells in Eddy County that were 200 to 300 feet in diameter and 100 to 200 feet deep suffered catastrophic collapse causing sinkhole development at the surface. Each of the wells associated with the collapse were former oil and gas wells converted to brine wells. At one brine well in Carlsbad, New Mexico, geophysical surveys indicated the presence of subsurface fracturing, cavities, and collapse, but no surface manifestation of collapse has occurred other than tilting of the ground surface [2. 1.16].

There are several examples in the Permian Basin of catastrophic subsidence as a result of suspected oil fi eld casing corrosion and dissolution of salt. The examples of subsidence associated with oil and gas operations include the Wink Sinks I and II and the Jal Sink. There are other similar incidents that occurred in areas underlain by salt in Texas and in Kansas. The Wink Sinks developed in the Hendrick oil field in Winkler County, Texas, near the town of Wink, which is approximately 75 miles southeast of the proposed CIS Faci lity Site. Wink Sink I developed in 1980 and Wink Sink II occuned in 2002 [2.1.16].

The Jal sinkhole, which developed in 2001, is located about 8 miles northwest of Jal, New Mexico and approximately 50 miles southeast of the proposed CIS facility Site. T he geologic settings of the Wink and Jal sinkholes are similar to that of the CIS Facility Site as they occurred at the basin margin above the Capitan Reef. In each incident, sinkholes formed around a well location and the sinks had diameters ranging from 200 to over 700 feet. Although the exact cause of development of these sinkholes is not known, it is suspected that casing fai lure allowed unsaturated water to come into contact with, and subsequently dissolve, salt layers [2.1.16]. Potash deposits are located around and within the Site as shown on Figure 2. 1.2 1. With regard to potential future drilling on the Site, Holtec has an agreement [2.6.9] with Intrepid such that Holtec controls the mineral rights Page 108 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOL'fEC PROPRIETARY INFORMAT ION on the Site and Intrepid will not conduct any potash mining on the Site. An area for a potash mine nearby and west of the Site has been identified as shown on Figure 2. 1.21; while the operational and construction footprint for the CIS Facility does not intersect the area for the potash mine (identified on Figure 2. 1.2 1 as "Belco shallow" and "Belco deep" potash drill islands), the proposed railroad spur has the potential to cross these drill islands.

The Belco Shallow and Belco Deep drill islands are located approximately 0.25 and 0.5 miles, respectively, from the CIS Facility Site boundary, and are intended to accommodate multiple oil and gas well locations, all or most of which will be horizontal wells completed below the Bone Springs fonnation (7,800 feet below the ground surface. Oi l and gas drilling has occurred on those drill islands in the past and could be used in the future. Similarly, as shown on Figure 2. 1.20, oil and gas wells have been drilled in the Green Frog Cafe Drill Island located just east of the proposed CIS Facility [2.1. 17]. Water demand in Lea County increased 33 percent from 1985 to 1995 and in 1998, the demand was about 189,000 acre-feet per year. Similar increases in water use from 1985 to 1995 occurred in Irrigated Agriculture (33 percent) Public Supply (26 percent),. Domestic (40 percent), Livestock (106 percent) and Commercial (21 percent) use categories. The water use by category, as a percentage of Lea County's total, is 78 percent Irrigated Agricultural, 10 percent for Public Water Supply, 7 percent Mining, and 3 percent Power. Present water use by Domestic, Livestock, Commercial Reservoir Evaporation, and Recreation uses are all less than l percent of the total use [2.1. 15].

The largest water use in Lea County is for non-municipal irrigation. The New Mexico Office of the State Engineer (NMOSE) has on record a total of 2,007 non-municipal wells with an associated water right of 344,600 acre-feet. The next largest user group is municipalities, with water rights of 48,000 acre-feet). The city of Hobbs is the largest water-rights holder with water rights of 20,100 acre-feet per year [2.1. 15].

Over the next 40 years, if unrestrained, the water use in Lea County is estimated to increase to approximately 360,000 acre-feet, 90 percent greater than the 1995 total. The largest part of this increase is anticipated to come from Irrigated Agricultural, which is projected to require 290,000 acre-feet in 2040, in response to demands for feed from Lea County's expanding dairy industry.

All other water use categories are expected to increase in Lea County over the next 40 years.

Specifically, 55 percent Pub lic Supply, 58 percent Domestic, 364 percent Livestock, 58 percent Commercial, 134 percent Industrial, 32 percent Mining, 57 percent Power, and 55 percent Recreation are estimated above 1995 uses. These other categories account for a total of approximately 70,000 acre-feet per year of the total annual 2040 estimate [2.1.15].

Page 109 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLT EC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Table 2.1.1 POPULATION ESTIMATES FOR REGION OF INFLUENCE [2.1.9, 2.1.10, 2.1.11]

Census Census Census Population Estimates as of July 1 Area 1990 2000 2010 2011 2012 2013 2014 2015 Lea 55,765 55,528 64,727 63,690 64,670 65,681 66,876 71,180 Eddy 48,605 51,633 53,829 53,288 53,693 54,284 54,834 57,578 Andrews 14 ,338 13,004 14,786 14,500 15,006 15,554 16,126 18,105 Gaines 14 ,123 14,467 17,526 17,123 17,572 18,019 18,496 20,051 Total ROI 132,831 134,632 150,868 148,601 150,941 153,538 156,332 166,914 New Mexico 1,515,069 1,819,046 2,059,179 2,037, 136 2,055,287 2,069,706 2,080,085 2,085,109 Texas 16,986,510 20,85 1,820 25,145,561 24,774,187 25,208,897 25,639,373 26,092,033 27,469,114 Page 110 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATIOf~

Table 2.1.2 POPULATION PROJECTIONS FOR THE REGION OF INFLUENCE [2.1.10, 2.1.11]

Area 2020 2025 2030 2035 2040 Lea 78,407 85,773 93,712 102,090 110,661 Eddy 57,908 59,945 61 ,836 63 ,595 65 ,258 Andrews 16,450 17,244 17,973 18,695 19,378 Gaines 20,064 21 ,420 22,858 24,316 25,644 Total ROI 172,829 184,382 196,379 208,696 220,941 New Mexico 2,351 ,724 2,487 ,227 2,613 ,332 2,727,118 2,827,692 Texas 27,238,610 28 ,165,689 28,994,210 29,705 ,207 30,305,304 Page 111 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HQI IEC PBOPRIETA.RY lf>lf=ORMATION Table 2.1.3 POPULATION DENSITY PER SQUARE MILE OF LAND FOR THE REGION OF INFLUENCE, 2010 [2.1.12]

Area 2010 County Lea 14.7 Eddy 5.4 Andrews 9.9 Gaines 11.7 County Subdivision and Place Eunice City, Lea County 970.6 Hobbs City, Lea County 1,424.4 Jal City, Lea County 446.4 Lovington City, Lea County 2,320.9 Carlsbad City, Eddy County 903.3 Page 112 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY IMFORMATION Table 2.1.4 CONSERVATIVE VALUES USED TO EVALUATE OIL RECOVERY FACILITY FOR FIRE CONSIDERATIONS Parameter Description Distance (Units)

Nearest location of Loaded Conveyance on 450 (ft)

Haul Path to East of Oil Recovery Facility Nearest location of Loaded Conveyance on 350 (ft)

Haul Path to North of Oil Recovery Facility Nearest location of HI-STORM for Phase 1 to 1750 (ft)

Oil Recovery Facility Nearest location of HI-STORM for All 900 (ft)

Phases to Oil Recovery Facility Page 113 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I !OLT EG PROPRleT/1.RY IMFORMATIQN New Mexico

(

New\ Mexico i Games County

'\

\ )

Texas Ecjdy County 1

~

I Andrews Coi:mtr'

~

Legend N

CISFS.tt

- State Boundary nsi_r---,M,les County Boundary I) 2 -4 8 Figure 2.1.1: Location of HI-STORE Page 114 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION

~Ganm ClSF Sa Boo!mry 0 2:£1 :{)) 7%). HOO SKtim>U.- Kore: Konh-Somh distance of Site is appro:runately 1 I

Cammc:iuticms nn.-.r ~

IJ Prodoc::m: Well ' Oil R.ecO\-ery Paa.my

.5,280 feet East-West chswice is appromnately 11,870 feet -f 0 lCOO

M.tas

~'.X) 3(XX)

[] Oil Reco\w Fociwy (Alw:dllmd)

Wam- Dmikor (Lk'MtllCk)

Foo:

Figure 2.1.2: HI-STORE CIS Facility Site Boundaries [2.1.3]

Page 115 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY l~IFORMATION 6'ilr>t ......... 4 l IO 1

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--.....":"'.:::z:.- -._. - wih t e ~A p 6 Ar C Figure 2.1.3: Grazing Allotments near the CIS Facility Site Page 116 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY l~lFORMATION

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.. - 7,:x.-. -- - :Ac 4 Figure 2.1.4,: Utility Infrastructure near the CIS Facility Site Page 117 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IAI TFA PRAPRIFTARY INFARMATIAN Figure 2.1.5: Aerial View of the Site (Full Build-Out) [2.1.8]

Page 118 of 689 Revision OC May 2018

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Page 119 of 689 Revision OC May 2018

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Page 120 of 689 Revision OC May 2018

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Page 121 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION BO Bad land SO IL Su RVEY MAP

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Page 122 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATION (b)(7)(F)

Figure 2.1.8: Phase 1 Boring Location Map [2.1.24)

Page 123 of 689 Revision OC May 201 8

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION

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Page 124 of 689 Revision OC May 2018

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Page 125 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATION Figure 2.1.11: Topography of Site and Surrounding Area [2.1.3]

Page 126 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY l~lFORMATION 50-Mile Radius Eddy Gain s 01 1.1,155,581 0 10 :a:>

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! &11 ""'"' t ~ -, Ell Cln ("Ja'O l<O"II, W1 KOAOC Figure 2.1.12: Region of Intluence with a SO-Mile Radius of the Site [2.1.13]

Page 127 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRleTARY ll'>IFORMATIOl'>I N

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D County Boundary 2 Figure 2.1.13: Sector Population Map Page 128 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 rtOL'fEC PROPR:IE'fAR:'1' INFORMATION Holtec Hi-Store Facility I I

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Page 129 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HObTeC PROPRleT/1.RY ll'>IFORMATIOl'>I

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 l:iOLTEC PROPRIETARY INFORMATION Figure 2.1.16: Mineral Resources near the Site Page 131 of 689 Revision OC May 2018

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION 2.2 NEARBY INDUSTRIAL, TRANSPORTATION, MILITARY, AND NUCLEAR FACILITIES 2.2.1 Industrial Facilities Figure 2.2.1 identifies industrial facilities located within approximately 5 miles of the Site. These facilities are:

1. Land Farm - oilfield waste management company tha t remediates contaminated soil from oil and gas operations. Located 1.9 miles southwest of the Site, contaminated soils are trucked to the facility and remediated using microbial degradation of the hazardous compounds.

2. Potash Facility - National Potash Mine, located approximately 4.2 miles west of the Site.

This mine first began operations in 1957. Potassium (mainly) is mined below surface with boring machines and lifted to the surface through shafts using hoists.

3. Transwestern - gas pipe line compressor station located approximately 5.2 miles southwest of the Site. This sta tion consists of a small building with compressors used to compress natural gas, transporting it through the gas pipeline.

4. Caliche - mining operation located approximately 4 miles southwest of the Site. Caliche generally occurs on or near the surface or at depths of 10-20 feet. Caliche is mined using traditional excavation machinery and is used in construction applications.

None of the faci lities located within 5 miles of the Site are engaged in operations that would pose a hazard to the Site or affect the design basis of the Site.

2.2.2 Pipelines There are approximately 27,000 miles of energy-related pipelines in New Mexico that are regulated by the U.S. Department of Transportation' s Pipeline and Hazardous Materials Safety Administration (PHMSA). Three pipelines are currently near the CIS Facility Site: (1) a Transwestern (TW) 20-inch diameter natural gas pipeline located approximately 0.8 miles from the western boundary of the Site, and (2) a DCP Midstream (DCP) 20-inch diameter natural gas pipeline located approximately 0.16 miles east of the eastern boundary of the Site; and (3) a DCP 10-inch diameter natural gas pipeline located approximately 0. 17 miles east of the eastern boundary of the Site. The two 20-inch pipelines are classified as high-pressure pipelines rated for a pressure of 1,180 pounds per square inch (psi). They are normally operated at a p ressure of approximately 680 psi. A fourth pipeline is proposed to be constructed near the two DCP pipelines east of the CIS Facility Site. That pipeline would be a 10.75-inch diameter low-pressure natural gas pipeline and would run south-to-north between the two existing pipelines which are east of the CIS Facility [2.2. l].

PHMSA has collected pipeline incident reports since 1970. Although the reporting regulations and incident report formats have changed several times over the years, PHMSA merged the various report formats to create pipeline incident trend lines going back 20 years. PHMSA defines significant incidents based on any of the following conditions:

Page 137 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRIETARY INFORMATIOM

Fatality or injury requiring in-patient hospitalization;

$50,000 or more in total costs, measured in 1984 dollars; or

Highly volatile liquid releases of 5 barrels or more or other liquid releases of 50 barrels or more [2.2.4] .

Tables 2.2.1 and 2.2.2 identify significant incidents over the past 20 years involving PHMSA-regulated pipelines in the U.S. and in New Mexico, respectively.

The most significant incident in New Mex ico occurred on August 19, 2000, when a 30-inch diameter El Paso Natural Gas pipeline ruptured near Carlsbad, New Mexico. That incident killed 12 members of an exte nded family camping over 600 feet from the rupture point. The force of the escaping gas created a 51-foot-wide crater about 113 feet along the pipe. A 49-foot section of the pipe was ejected from the crater, in three pieces measuring approximately 3 feet, 20 feet, and 26 feet in length. The largest piece of pipe was found about 287 feet northwest of the crater. The cause of the failure was determined to be severe internal corrosion of that pipeline [2.2.3].

In order to determine whether the potential failure of a pipeline could have significant impact on people or property, the PHMSA has developed a calculation that accounts for the size of the pipeline and the max imum allowable operating pressure. The term "PIR" means the radius of a circle within which the potential failure of a pipeline could have significant impact on people or property. The PIR is determined by the following formula:

r=0.69*~

where:

r = the PIR in feet, p = the pipeline maximum operating pressure in pounds per square inch (psi), and d = the nominal pipeline diameter in inches [2.2.2].

Figure 2.2.2 depicts a graphic representation of the results of that formula. As can be seen from that figure, for the maximum expected diameter pipeline (42-inch) operating at the maximum pressure (l 450 psi), the hazard area radius is not expected to exceed approximately 1, 100 feet from the explosion. For the CIS Facility, there are no pipelines in the vicinity greater than 20-inch diameter or with operating pressures greater than 1,180 psi. As shown on Figure 2.2.2, for a 24-inch diameter pipeline with an operating pressure of approximately 1,180 psi, the hazard area radius is not expected to exceed approximately 600 feet from the explosion. All pipelines near the CIS Facility are located more than 600 feet from the Site boundary, and more than 1 mile from the ISFSI.

Table 2.2.3 presents a summary of some of the most relevant pipeline explosions that have occurred in the U.S. since approximately 1969. As can be seen from that table, impacts occurred within 1,000 feet of all explosions. Given that there are no pipelines within one-half mile of the proposed operations at the CIS Facility, it would be extremely unlikely for a pipeline rupture to impact operations at the facility.

Page 138 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOL'fEC PROP~IETAFH INFORMATION With regard to past operations at the site involving an oil recovery facility with tanks within the CIS Facility Site boundary, it should be noted that there are no oil recovery operations presently occurring on the Site and none are reasonably foreseeable. There are 7 aboveground storage tanks (ASTs) associated with past brine disposal activities on t he site. These ASTs are holding tanks that were used for storing brine and settling solids and separating residual oil from oil-field brines.

'The tanks range in size from 150 barrels to 250 barrels. These holding tanks or ASTs are not in use. No containers of hazardous substances have been noted in p1ior site visits (2007) or most recent site visits (2016). Within Section 13, which is where the CIS Facility would be located, two additional tanks (250 gallon barrels) are present at the well location in the southwest portion of the Site.

One active oil/gas well on the southwest portion of Section 13 operates at minimum production to maintain mineral rights.

2.2.3 Air Transportation The airspace surrounding the CIS Facility is unrestricted and at any given time there would be the potential for commercial aircraft, military aircraft, and civilian aircraft to be tlying in that airspace at various altitudes and at various speeds. Commercial aircraft would fly in accordance with flight plans fil ed with the Federal Aviation Administration (FAA) and would be controlled by the national air traffic control system [2.2.5] [2.2. 181, Military aircraft would fl y within designated Military Training Routes (MTRs), which may or may note be flown under air traffic control.

Commercial aircraft flight plans would be limited to the Federal Airways that make up the en route airspace structure of the National Airspace System. There are multiple federal airways near the CIS Facility: V83, Vl02, and V29 1 [2.2.161 [2.2. 17). Victor routes are low altitude airways that make up the majority of the lower stratum of the federal en route airspace structure. V ictor routes extend from the floor of the controlled airspace up to but not including 18,000 feet above mean sea level [2.2.18]. They are defined as straight line segments between VOR stations and have a width of 4NM on either side of the centerline when VOR stations are less than 102 NM apart, with the width increasing for VORs farther apart [2.2. 18]. Additional information for these airways, including their distances from the site, is included in Table 2.2.5. These federal airways are illustrated on Figure 2.2.6.

Because airspace above the United States from the surface to 10,000 feet above sea level is limited to 250 knots (i ndicated airspeed) by FAA regul ations, any aircraft below 10,000 feet would be travelling at speeds of Jess than 250 knots. There is a military exception to this requirement, however. The Military Training Route Program is a joint venture by the FAA and the D epartment of Defense (DOD), developed for use by military aircraft to gain and maintain proficiency in tactical "low-level" flying. These low-level training routes are generall y established below 10,000 feet for speeds in excess of 250 knots. Military Training Routes do not constitute an offic ial airspace and are all open to civilian traffic [2.2.6].

MTRs are designated either IR (Instrument Route) or YR (Visual Route), with IR routes being flown under air traffic control [2.2. 19). Military training routes are usually limited to 420 knots, and in no case are aircraft allowed to exceed Mach 1 within United States sovereign airspace, except in designated Military Operation Areas. While on the route, military aircraft squawk a Mode C Transponder code of '4000', which informs controllers that they are 'speeding' on a route.

This squawk however is only legal by military ai rcraft, while inside a properly scheduled route corridor [2.2.201.

Page 139 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLT EG PROPRleTARY IMFORMATIQN There are four designated M ilitary Training Routes in the vicinity of the proposed CIS Facility:

IR- 128, IR- 180, IR- 192, and IR- 194. However, these four designations represent only 2 mapped airways, as IR- 128 and IR- 180, and IR- 192 and IR- 194 share the same airway but represent opposite directions of travel (hereafter referred to as IR- 128/ 180 and IR-1 92/194, respectively).

IR-128 and IR-192 both represent the North to South direction, while IR- 180 and IR-194 represent the South to North flight direction of their respective corridors [2.2.19] [2.2.16]. The routes are individually operated by an Air Force Base, which sched ule and 'own' the route. IR- 128/ 180 is "owned" by Dyess AFB while IR-1 92/194 is "owned" by Holloman AFB. The FAA requires the military to provide advance notice to other aircraft that the Military Training Routes will be used to allow for civilian traffic to de-conflict if needed. Department of Defense publication AP/ 1B defines all MTRs giving coordi nates of airway fixes, or points between segments as well as the airway width different points along the route. Additional information for these airways, including their distances from the site and widths, is included in Table 2.2.5. These Military Training Routes are also ill ustrated on F igure 2.2.6.

A Military Operation Area (MOA) is "airspace established outside Class A airspace to separate or segregate certain nonhazardous military activities from IFR Traffic and to identify for VFR traffi c where these activities are conducted." [2.2.2 1]. The nearest MOAs to the CIS facility are the Talon High East MOA, which is located north of Carlsbad, NM and the Bronco 3 MOA, which is located North of Hobbs, NM. The nearest edge of both of these MO As is greater than 25 miles from the site.

As discussed below, most of the commercial airline operations at airports in the area of the CIS Facility involve regional jets. The largest commercial planes (Boeing 737s) are flown in and out of Midland International Air and Space. A summary of the airplane operations at airports near the CIS Faci lity are provided be low. Airpo,t operation numbers have been gathered from 2 sources, first is the Air Traffic Activity Data System (AT ADS), which contains the offi cial NAS air traffic operations data available for public release. The other is GRC lnc. 's AirportlQ 5010, which is a compilation of FAA form 5010-5 Airport Master Records and Reports. ATADS gives data as far back as 1990, where A irpo1tIQ gives only the past year's data. Additionally, AT ADS only gives data for Airports that have an FAA certified Air traffic control tower, so data for some of the smaller airports has only been sourced from AirportlQ.

Artesia Municipal Airport* is a public use general aviation airport located 4 miles west of the Main Street business district or Atresia, in Eddy County, New Mexico, approximately 47 miles from the CIS Facility. The city owned airport and its 2 runways cove rs 1,440 acres. For the 12 month period ending April 05, 2017 the aiJ:port had approximately 14,050 aircraft operations, an average of 38 per day: 82 percent general aviation, and 18 percent military. During this period, 30 aircraft were based at this airport: 26 single engine, and 4 multi engine [2.2.22].

Note that Atresia Municipal Airport does not have an FAA funded air traffic control tower, and therefore does not have data reported to AT ADS.

Cavern City Air Terminal* is a public use airport in Eddy County, New Mexico, United States. It is owned by the city of Carl sbad and located five nautical miles southwest of its central business district, approximately 34 miles from the CIS Facility. The airport is served by one commercial airline. For the 12 month period ending December, 3 1, 20 16, the airport had approximately 6,900 Page 140 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROPRIETARY llqfiORMAT IOM aircraft operations, an average of 19 per day: 53 percent general aviation, 4 percent air taxi , 39 percent air carrier, and 4 percent military. During this period, 22 aircraft were based at this airport:

15 single-engine, 2 multi-engine, 2 jet, 2 helicopter, and 1 ultra-light [2.2.23). The approach pattern for Cavern City Air Terminal is approximately 14 miles North East of the airport, locating it a little more than 22 miles from the CIS Facility see Table 2.2.6 [2.2.30].

Note that Cavern City Air Terminal does not have an FAA funded air traffic control tower, and therefore does not have data reported to ATADS .

Lea County Regional Airport* is 4 miles west of Hobbs in Lea County, NM , approximately 30 miles from the CIS Facility. The airport covers 898 acres and has three runways. It is an FAA certified commercial airport served by United Airlines' affi liate with dai ly regional flights. Lea County Regional Airport is the largest of the three airports owned and operated by Lea County Government. Lea County also owns and operated two general aviation airports in Lovington and Jal, New Mexico. For the 12 month period ending April 30, 2017, the Lea County Regional Airport had approximately 12,745 aircraft operations, an average of 35 per day: 67 percent general aviation, 16 percent air taxi, 10 percent air carrier, and 7 percent military. During this period, 52 aircraft were based at this airport: 41 single-engine, 6 multi-engine, 4 jet, and 1 helicopter [2.2.24].

Average annual aircraft operations for the past 15 years is approximately 12,500, this data is illustrated in Table 2.2.7 [2.2.281. The missed approach holding pattern for Lea County Regional is approximately 19 miles South West of the airport, locating it just over 12.5 miles from the CIS Facility see Table 2.2.6 [2.2.3 1]

Note that for Lea County Regional data reported on AiportIQ does not match the data for the same time period reported on ATADS.

Lea County - Zip Franklin Memorial Airport* also known as Lovington airport is located 3 miles west of the central business district of Lovington in Lea county, NM, approximately 32 miles from the CIS Facility. For the 12-month period ending April 3, 2017 the airport had approximately 2,200 aircraft operations, all general aviation. During this period, 12 aircraft were based at this airport: 11 single engine, and 1 multi engine [2.2.25].

Note that Zip Franklin Memorial Airport does not have an FAA funded air traffic control tower, and there fore does not have data reported to ATADS.

Midland International Air and Space is located approximately midway between the Texas cities of Midland and Odessa. It is owned and operated by the City of Midland. In September 2014 it became the first US fac ility licensed by the FAA to serve both scheduled airl ine flights and commercial human spaceflight. Midland International Air and Space Port is ranked eighth in Texas for primary commercial service airports. For the 12-month period ending April 30, 2017, the airport has approximately 63,000 aircraft operations, averaging 173 per day: 43 percent general aviation, 14 percent air taxi, 18 percent air carrier, and 25 percent mi litary. During this period, 105 aircraft were based at the airport: 24 single-engine, 40 multi-engine, 39 j et and 2 helicopter. The airport has three airlines, two serving hubs w ith regional jets and one (Southwest) flyin g mainline jets (Boeing 737s) [2.2.26]. Average annual aircraft operations for the past 15 years is approximately 76,4 12, this data is presented in Table 2.2.8 [2.2.28].

Roswell International Air Center is located 5 miles south of the central business district of Roswell, Page 141 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRle.TARY l~lFORMATION in Chaves County, NM, approximately 68 miles from the C IS Facility. The former Air Force Base currently covers 5,029 acres and has 2 runways. It is also an FAA certified commercial airport but is served by American Airlines with daily regional fli ghts to Dallas-Fort Worth and Phoenix. T he airport is owned by the city of Roswell and also serves as a storage facility for retired aircraft. For the 12-month period ending December 3 1, 2016, the Roswell International Air Center had approximately 34,280 aircraft operations, an average of 94 per day: 23 percent general aviation, 18 percent air taxi, l percent air carrier, and 58 percent military. During this period, 39 aircraft were based there: 3 1 single engine, 4 multi engine, 3 jet, and 1 helicopter [2.2.271, Average annual aircraft operations for the past 15 years is approximately 49,050, this data illustrated in Table 2.2.9

[2.2.28] .

In order to assure that risks from aircraft hazards is sufficiently low, a probabilistic assessment of the nearby air transportation infrastructure as described above has been performed. NUREG-0800 Standard Review Plan, gives acceptance criteria for the probabilistic assessment to meet NRC regulations. NUREG-0800 section 3.5.1.6 states that the requirements are met if the probability of aircraft accident is less than an order of magnitude of 10-7 per year. It also provides screening criteri a which, if met, the probability is considered to be less than the 10*7 threshold by inspection.

Table 2.2.4 summarizes the data presented for each of the nearby airports, including its distance from the site, annual number of operations, as well as the SRP screening criteria. The value used for annual aircraft operations is the higher of the 15-year average from ATADS or the most recent year's value from Ai rportIQ (where both values are available). Given the distance to each of the nearby airports, none of their annual operations comes within an order of magnitude of the screening criteria. Therefore, each of the nearby airports pose a negligible hazard risk.

Table 2.2.5and Table 2.2.6 summarizes the data presented for each of the federal airways, and holding or approach patterns that are near the site. The tables include distance from the site to the nearest edge of the airway or holding/approach pattern, as well as the screening criteria. Each of the proximate federal airways, holding patterns and approach patterns are greater than the 2-statute mile SRP screening criteria. Therefore, they pose a negligi ble hazard risk.

Table 2.2.5 also summarizes the data presented for each of the adjacent Military Training Routes, including the distance from the site to the nearest edge of the route, as well as the SRP screening criteria. The nearest edge of IR- 192/ 194 is greater than 10 miles from the site, which is greater than the screening criteria of 5 statute miles. However, the centerline of IR- 128/180 is less than 2 miles from the site, which puts its full width over top of the CIS Facility. Therefore, IR- 192/194 is screened by inspection, while IR- 128/1 80 needs to be assessed following SRP Section 3.5. 1.6 III [2.2.33].

SRP Section 3.5. 1.6 III provides the following equation for determining the probability of an aircraft using an airway crashing at the site:

p = C

N

A/w Where:

C = in-flight Crash Rate per mile for aircraft using the airway Page 142 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROF'~IETAFH llqfiORMA'flOM N = Number of flights per year along the airway A= effecti ve Area of the site in square miles w = Width of the airway in miles The area of each of the important to safety structures constitutes the effective area of the site. In this case, it is conservatively taken as the out to out area of the full 10,000 cask UM AX ISFSI array plus the area of the Cask Transfer Building, A= 0.173 mi 2. The total width of the airway, as noted in Table 2.2.5, is 7 miles. And using a crash rate of C = 4* 10-9 (an order of magnitude greater than commercial aircraft), the number of flights per year that would yield a crash probability higher than P = 10-7 would be 1011 fli ghts.

The Air Force Base that controls IR- 128/180, Dyess AFB has stated that " IR-180 has not been used in years and we do not expect to fl y IR- 180 in the near future, the way it's currently laid out"

[2.2.32]. They also provided Figure 2.2.7 showing how IR- 128 is flown and how they "expect to fly it in the foreseeable future" [2.2.32]. Figure 2.2.7 illustrates the racetrack which is used as part of operations on IR- 128 and then ex ited from. This raceu*ack is north of Lovington, NM greater than 30 miles from the site. The portion of IR- 128 closest to the site is not used. Therefore, it is reasonable to assume that less than 1011 flights per year occur on these MTRs near the site, and they pose a negligible hazard risk.

2.2.4 Ground Transportation U.S. Highway 62/180, approximately 1 mile south of the proposed CIS Facility is the closest and most trafficked public road. It provides a route from the state of Texas to Carlsbad, New Mexico and poi nts further west. It is a divided highway with a maximum speed limit of 70 miles per hour in the area near the proposed CIS Facility. This, in addition to other transportation infrastructure near the site, can be seen in Figure 2.2.4. This highway is on the National Hazardous Materials Route Registry (79 FR 40844, July 14, 2014) and can be used for the transportation of radioactive waste materials to WIPP [2.2.7] (Note: as shown on Figure 2.2.5, the WIPP route is approximately 5 miles southwest of the CIS Facility. There have been instances where u-ansuranic wastes associated with WIPP have been transported along U.S. Highway 62/180 within approximately l mile of the proposed CIS Facility).

Like similar roads, commercial shipments of hazardous materials are also transported over U.S.

Highway 62/180. Such shipments could include a wide range of hazardous materials, including, but not limited to: gasoline, diesel fuel, acids, carbon dioxide (CO2), nitrogen (N2), liquid nitrogen (LN2), chlorine (Cl) gas, refrigerants, fuel gases, oxygen (0 2), explosives, and low-level radioactive materials. The State of New Mexico does not keep records of hazardous material shipments via roadways or rail. Consequently, specific types and quantities cannot be provided.

In 2015, the annual average daily traffic on U.S. Highway 62/1 80 was 5,696 vehicles per day in the vicinity of the proposed Site (near the Eddy-Lea County line) and approximately 43 percent of these vehicles were associated with commercial trucks [2.2.9]. In 2014, in the entire state of New Mexico, there were 69 Hazardous Material Incidents requi.red to be reported by 49 CFR §§ 171.15 and 171. 16 [2.2.8]. While truck shipments in the area are expected to rise over time, this highway Page 143 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY l~lFORMAT ION is not included in the plam1ing for increasing freight traffic in the "New Mexico Freight Plan"

[2.2.10].

The nearest operating railroad is an industrial railroad approximately 3.8 miles west of the proposed CIS Facility and serves the local potash mines to transport ore to the refiners. The potash ore is not a hazardo us material. From 2008 to 2012, the ann ual average of train accidents per 1,000 railroad miles was 10.4, the fata lity rate was zero and the injury rate was 0.4 [2.2.1 OJ. As with highway transport, shipments by rail could include a wide range of hazardous materials, including, but not limited to: gasoline, diesel fuel, acids, CO2, N2. LN2, Cl gas, refrigerants, fuel gases, 0 2, explosives. However, no specific records are maintained by the state of New Mexico regm*ding hazardous material shipments via rail. All transportation infrastructure can be seen in Figure 2.2.5.

2.2.5 Nuclear Facilities With regard to nuclear facilities, Figure 2.2.5 depicts existing or planned nuclear facilities in the vicinity of the Site. As shown on that Figure, all of these fac ilities would be within SO-m iles of the proposed Site. A brief description of these other nuclear facilities follows:

1. Waste Isolation Pilot Plant (WIPP): Located approximately 16 miles southwest of the proposed Site, WIPP is the nation's first underground repository permitted to safely and permanently dispose of transuranic (TR U) radioactive and mixed waste generated through defense activities and programs. WIPP, which has been operational since March 1999, stores TRU in underground salt caverns approximately 2, 150 feet deep. From the first receipt of waste in M arch 1999 through the end of 2014, approximately 90,983 cubic meters of TRU waste has been disposed of at the WIPP facility. The environmental impacts of the WIPP are described in the Waste Isolation Pilot Plant Disposal Phase Final Supplemental Environmental Impact Statement (DOE/EIS-0026-S2) [2.2. 11], as well as the Waste Isolation Pilot Plant Annual Site Environmental Report for 2014 [2.2.12].

2. National Enrichment Facility (NEF): Located approximately 38 miles southeast of the proposed Site, the NEF is used to enrich uranium for use in manufacturing nuclear fuel for commercial nuclear power reactors. NEF enriches uranium using a gas centrifuge process.

The environmental impacts of the NEF are documented in NUREG-1790 [2.2. 13].

3. Fluorine Extraction Process & Depleted Uranium De-conversion Plan (FEP/DUP):

Located approximately 23 miles northeast of the proposed Site, the FEP/DUP will de-convert depleted uranium hexafluoride (DUF6) into fluoride products for commercial resale and uranium oxides for disposal. Construction of that facil ity is expected to begin before the end of 2016. The environmental impacts of the FEP/DUP are documented in NUREG-2113 [2.214].

4. Waste Control Specialists (WCS) CIS Facility: In May 2016, WCS submitted a license application to the NRC to construct and operate a CIS Facility in Andrews County, Texas, approx imately 39 miles east of the Holtec proposed Site. The W CS CIS Faci lity would be similar to the Holtec Site, but would utilize AREVA's horizontal canister storage system (NUHOMS) at the facility. A limited number of vertical canisters supplied by NAC may also be stored. The environmental impacts of the WCS CIS Facility are documented in an ER which WCS subm itted to the NRC in May 2016 [2.2.15]. In addition, the NRC is expected to prepm*e an EIS for the WCS CIS Facility.

Page 144 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC F'~OF'~IETAFH INFO~MATIOI~

Table 2.2.1: Significant Incidents in U.S. Involving Pipelines (1997-2016) [2.2.4]

CaJend~rYea Number Fatalities. Injuries Total Cost Current Year Dollars 1997 267 10 n $110,377,793 1998 295, 21 81 $174,516,797 1999 275, 22 1DB $178,313,209

.2 000 200 3R 81 $257 *65,9*464

.2001 23.:J, 7 61 $79,006,596 2002 2.~ 12 49, $124,067,949 2003 297 12 71 $163,45,9,897 2004 3{)91 23, 56 $314 *36,2*210 2005 336 16 46 $1,416,994,582 2006 257 19 34 $1:5,7 ,117,098 2007 2&5, 15 46 $147,000,810 2000 278 a 54 $592,290,867 1

2009 275, 1J 62 $180 360 208 I . I 2010 264 19 103 $1,854,123,037 2011 237 12 51 $44705,9m 2012 2.54 10 54 $23,3 *813*285

.2013 304 a 42 $15,5 ,213,552

.2 014 301 19 94 $305,25,3,746 2015 328 10 49, $338 29,7 939 I I 2016 3{}i6 16 82 $301612864 I I

>Grand Total 51679 J,10 11301 $1,791,111,681 Page 145 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL'fEC PROPRIETARY l~lFORMATIOl'>I Table 2.2.2: Significant Incidents in New Mexico Involving Pipelines (1997-2016) [2.2.4]

C31end~n Yea 1

Number FataUties l'n juries Total Cost Cunenl Year DO:llars 1997 4 0 0 $8.575 1998 6 0 1 $411.056 1999 11 0 1 $1 ,796.066 zcmo 3 12 0 $2 D19 207 1 1 2001 6 0 5, 1481.449 2002 8 0 0 1366.976 2003 7 1 1 1730.327 2004 6 0 2 $401,852 2005 6 0 1 1478.356 2006 4 0 2 1794.1:57 2(107 6 2 0 $,1 D23842 I I 2008 1 0 2 $1 10871 684 2009 5, 0 4 $320.218 2010 2. 0 1 1133.880 2()11 5, 0 0 1726.725 2012 3, 0 1 $577.414 2013 4 0 0 $,11.295.874 2014 3 0 0 1250.297

.2015 1 0 a $,1 ,336,314 2016 1 0 0 $825,006 rGnmd Total 110 1!i 21 $1!5,06§,175 Page 146 of 689 Revision OC May 2018

A TTACHMENT 2 TO HOLTEC LETTER 5025025 HOLT EG PROPRIETARY INFOR MAT ION Table 2.2.3: Notable Significant Incidents Involving Pipelines [2.2.2]

Date R~ort L ooailo n tnalden1 oun10* llulm um evrn Diameter l ' -ure 0111,bu, oe llnl la&II 1365 N- CB-PAA*7*

1 re_.Jr 1-<out:an, Tu:>> R.u,lln 01 J:£n 1t ""'* on Bu:med ~ H 370 "1 or~ !Jt JOO It 300 II u 7t9 3c~t~ Der 9UI, w'de 1111 IO one ~ de 1. f'ou:.e~

explotvc ~ -on S Iio 1:J d5:n>yed 11)' b_.) :t ID :.-ro °I, l!Hl mn= o~ r r~, ure ~ - J GC to !DJ ft, 1CS .o,nc :

<bc- 1ge<1 9 1'1,ure:, ond J

~ 1:1~::..

1374 NTCB-PAA*Y!:*2 r~ Bco.elDn, vr'Qlnli Burned a~ 1 r co "1 DJ 4CO 1\. 30 11a 1974 N- CB.PAA*7!:*3 r cS>r FJJri1Q':llll'I, New Ru~ 01 3;4!: a "'l. an ~nt crmrco wh".11 a 300 , 12.75 4':17 M61co Morc/1 1!:It\, lgntt.c,n ~~ ClM!!c lH Clrcle, 3 l'lllll l"~.llc, a~ l ' l l = *a1111n SJ ft Cll"':e!I 1976 NTCB-PAA*H

1 C amwl;iht, Lou'~- R ~ a1 l :ll!: lt "'l, o n Bli"I ltl'CJ 3 .:ic:= -pre: a 2CO "1 ::0 770 AuVi.:t 9:"I.

, ccoo,Cf~

"r. bed wit.n nalu~ cJdcl ~ :3ttr.:~ twt: n

.JCoUl I CC ~ o-tctl rd I ~ JI'!/

1982 N-CB-PAA*!13*2 Hud,an, lcN.J s *,~1ac~ **~ 1!:C "1, en tttmt ::D e::o m , o~cll.

US4 NTC&.PAA-16-1 r e_MJ.)CU<<- RJ.Ptlft 01 l lDC 11',l'!l. an Bi.m'11 ~a u 50 "1 on; lly l5D It ~:cl 1&>1t. 30 C15 Lou : 1Jn1 ,,.,o,oe-l>cr :.Eth, ~"Off W,de turlhUI In Cite,, 95:J ft), 5 Olllllncc s ro "1.

~on a.*..er *~ ,ure ~1:1 11e-, "'1111.n 55 ft, o n o~c an:! ~) lr\,IIC~ 111,'( sac

u:,.,

~ - ll 19!!: NTCB-PAA-87*1 t:*MSco .r:ant, ~ o19:1C p,.r,i. on Bwn'11 ~ * !:CO 'I on:lc Dy i lD It OIT:ct lSCI n. 3IJ 9~

l<en:;,cty l'lpfl 2711\ ;nmo~ :oOt1 ,ong 2 IIOu,c, 3 IIO~e n c~ 01'tance SOO "1.

a~ra...irc ,r.iCI nurren>ll'!i olt'er =Clllrtt sn~

~\r' ent ac:-:tr-orccs s ~ mrec, ctJe ID , ,nokc 1nn11!J ta. h DU:.e 31$ n tt:>,n rl(Ptll~ 11:0 n o ~ctl, 3 pc:op.e ourr.ed ri.rr, ng 'tOII' l'IOu:c l:o ft lr.),n rl(Ptll~ 1200 II O~Ctl ore IIO~blWN:I 111:1 :n<<I oc:~c b..m,.

1986 NTC&-PAA-IM r.u ., L.r.c.n~r RJP!lff 01 l "DS a l"I, an 8111"1'11 ~ a ,CO "1 Dy 1l:131t l OIT:et 7CD n. 3IJ 937 l<e:n::X:ly Feor.wy :n~~ gt.ctn ber.l= 1 l'll>ll'~e tr.11er ¥d Ollmncc eoo "1.

"a,n O*..e f ~*Utt' r .rt rou~ ou.er :tructurtt , ....,

eq.J\r' ent oc:-.:tro,oe<1 l oeople 1>.n1ccs runn no tn,rr l"iOo.J:c l9D It

'nlm rupllire c,-c:,i .Lrng

~l)lt,lnllarl Sot~~rKelfc:<I

,.. l"<lt blll"I 11\i,.,lu n.w,r. gn,:,m

~ c 1n,~ octacen .:::,:, i nd :2~ 11 ffff' ,.,,.ti.re t.::SD It C°"le,tl 19S.: NTC&.PAA-,S*1 ~ ."'ew ~cr..r y Ri.!IIIU!'e a.111~.1on ei.me11 <Y'C3

400 "1 on, DY ~l)D 'I OIT:et 7:o n. 1S 570 IA.wcll 23rd, Vt' tlon wdc =1rc CS>m.,gc IO ctael o un t, Olltance 9i0 "1.

"'111m 1 to2 ..-r_.ne, up 11) 9C<l l't 0.IOffl 1'\11!:IC:, ct11,:_ i

oltef ra :1rc II t: Ol 500 II 3RO be'ftM'ld call9"C

r e oeiw.e-en 7 IO t a ,- I" .u-, ~

, tu~ .,, lam.'t ~ tu, ES i' i.r~

19'4 TCS Rtoon N~ M~~Crttl R...otin 01 7,'I! P ""* 1111 "l"c t....., orc:121.0.xrc~ ta *~ C 1l 07 P9LH0003 3it!oklltchea r Febr.wy U,111, l~l!lar i'>ectlr'Cli

~on a~r *.)irure 19S.: T~ .3 Repect No.. lA!Xl'k"OIO on:n:, R!.iptUre a.: 7:13 o. l':'i. on "n t....., are:1 11.e .xre~ 14_77 ;S , coo P9LHOO_l, Jul)' llrll, l:Ji,!:b ':OC ~ty~ .ell!-r'caed J ru 18 &

ol't!ef ra .ue a.er~ t7 !:2 ne CDrC:l 135S T.:J.a Reoon No R3!Pd City, M¥ tall.I R.1p!Ure Of £2 lnel'I ne 01 "re t _..., ilfU 48 S.xre, t1S 6 42 sso P9SH00-16 s_4.? a..m. an JU't 29111, t--.ea.r~ i.ell!-r'eae11 J rc.J 191 t,ntcn~cn r1er *1 ure a.cre!. 181! r.e-~l le1dln, ID l'l.lPIUft Jlld i'tt on J~ KC!11 36 Inc.ti Ir e 31 6 l4 o.r Page 147 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Table 2.2.4: Nearby Airport SRP Screening Screening Distance Average Criteria Airports City from Site Annual 1000 D2 (miles) Operations Operations Artesia Municipal (ATS) Artesia, NM 47 14,050* 2,209,000 Cavern City (CNM) Carlsbad, NM 34 6,900* 1,156,000 Lea Cou nty Regional (HOB) Hobbs, NM 30 12,745 900,000 Lea Co. Zip Franklin Mem (EOG) Lovington, NM 32 2,200* 1,024,000 Roswell International (ROW) Roswell, NM 68 49,045 4,624,000 M idland Intl air and space port (MAF) M idland, TX 98 76,412 9,604,000 Table 2.2.5: Nearby Federal Airway and Military Training Route SRP Screening Width Distance Distance Width Travel Right Site to nearest Screening Airways Federal/MTR to left of Direction of Side edge Criteria Centerline Center center [miles]

V-102 Federal Either 6.8 4 4 N/A 2.8 > 2 mile V-291 Federal Either 12.0 4 4 N/A 8.0 > 2 mile V-83 Federal Either 34.8 4 4 N/A 30.8 > 2 mile IR-192/ N to S 13.5 3 7 Left MTR 10.5 > 5 mile IR-194 S to N 13.5 7 3 Right IR-128/ N to S 1.8 3 4 Right MTR Over Site >Smile IR-180 Sto N 1.8 4 3 Left Note: Bolded items do not satisfy criteria and are discussd further in chapter Table 2.2.6: Nearby Airport Holding and Approach Pattern SRP Screening Holding/Approach Pattern Distance from Site [miles] Screening Criteria CNM Approach Pattern 22.76 >2 mile HOB Missed Approach Pattern 12.64 >2 mile Page 148 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IA I TFA PRAP RIFTARY l ~JFARMAT IA~d Table 2.2.7: ATADS Standard Repor t for LEA County Regional Airport 2003-2017 Itinerant Local I I I Calendar Air Air General Total State Facility Military Total Civil Military Total Year Carrier Taxi Aviation Operations 2003 NM HOB 0 3,047 8,676 167 11 ,890 6,138 468 6,606 18,496 2004 NM HOB 0 3,002 6 ,850 200 10,052 5,224 344 5,568 15,620 2005 NM HOB 0 2,277 5 ,082 77 7,436 3,660 166 3,826 11 ,262 2006 NM HOB 0 2,195 4 ,574 72 6,841 3,694 155 3,849 10,690 2007 NM HOB 0 2,237 5,468 62 7,767 4,006 82 4,088 13,810 2008 NM HOB 0 2,388 5 ,165 85 7,638 5,240 188 5,428 17,366 2009 NM HOB 0 2,136 10,327 171 12,634 6,884 390 7,274 19,908 2010 NM HOB 4 2,190 9 ,806 280 12,280 3,991 366 4,357 16,637 2011 NM HOB 2 1,944 6 ,332 137 8,415 2,011 326 2,337 10,752 2012 NM HOB 0 2,264 5 ,817 157 8,238 856 176 1,032 9,270 2013 NM HOB 2 2,341 5 ,622 100 8,065 738 90 828 8,893 2014 NM HOB 0 2,358 5 ,153 257 7,768 511 244 755 8,523 2015 NM HOB 0 1,979 5,336 399 7,714 1,196 304 1,500 9,214 2016 NM HOB 0 2,115 5 ,351 374 7,840 818 226 1,044 8,884 2017 NM HOB 0 1,870 5 ,049 157 7,076 1,097 16 1,113 8,189 Sub-Total for HOB 8 34,343 94,608 2,695 131 ,654 46,064 3,541 49,605 187,514 Sub-Total for NM 8 34,343 94,608 2,695 131 ,654 46,064 3,541 49,605 187,514 Total: 8 34,343 94,608 2,695 131 ,654 46,064 3,541 49,605 187,514 15y_r AVG 12,501 Page 149 of 689 Revision OC May 201 8

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Table 2.2.8: A TADS Standard Report for Midland International Air and Space Port 2003-2017 Itinerant Local I I Calendar Air Air General Total State Facility Military Total Civil Military Total Year Carrier Taxi Aviation Operations 2003 TX MAF 9,612 14,111 23,557 17,704 64,984 4,703 22,745 27,448 92,432 2004 TX MAF 9,603 12,264 25,137 16,555 63,559 4,149 18,401 22,550 86,109 2005 TX MAF 9,560 13,783 24,571 16,220 64,134 4 ,696 18,060 22,756 86,890 2006 TX MAF 10,309 15,615 26,352 16,197 68,473 4,463 16,563 21 ,026 89,499 2007 TX MAF 9,408 14,055 17,745 13,015 54,223 4,172 16,442 20,614 84,302 2008 TX MAF 8,613 13,827 12,608 7,747 42,795 4,129 16,369 20,498 84,037 2009 TX MAF 8,574 12,574 18,070 10,447 49,665 2,629 9,547 12,176 61 ,841 2010 TX MAF 8,196 14,935 22,290 10,587 56,008 2,792 11,766 14,558 70,566 2011 TX MAF 8,336 12,479 23,490 12,777 57,082 2,823 14,991 17,814 74,896 2012 TX MAF 7,903 13,850 25,202 9,972 56,927 2,466 10,345 12,81 1 69,738 2013 TX MAF 7,099 16,433 25,111 10,531 59,174 2,402 10,988 13,390 72,564 2014 TX MAF 8,987 15,464 27,562 10,181 62,194 3,390 11,093 14,483 76,677 2015 TX MAF 11,478 11,648 22,745 10,379 56,250 4,175 9,960 14,135 70,385 2016 TX MAF 11,033 9,370 21,423 9,878 51 ,704 1 5,471 6,733 12,204 63,908 2017 TX MAF 11,757 8,715 23,029 6,835 50,336 5,230 6,777 12,007 62,343 Sub-Total for MAF 140,468 199,123 338,892 179,025 857,508 57,690 200,780 258,470 1,146,187 Sub-Total for TX 140,468 199,123 338,892 179,025 857,508 57,690 200,780 258,470 1,146,187 Total: 140,468 199,123 338,892 179,025 857,508 57,690 200,780 258,470 1,146,187 I

15vr AVG 76.412 Page 150 of 689 Revision OC May 201 8

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATION Table 2.2.9: ATADS Standard Report for Roswell International Air Center 2003-2017 Itinerant Local I I I Calendar Air Air General Total State Facility Military Total Civil Military Total Year Carrier Taxi Aviation Operations 2003 NM ROW 398 8,579 13,861 13,394 36,232 9,741 12,181 21,922 58,154 2004 NM ROW 94 9,418 18,547 13,495 41 ,554 12,800 13,032 25,832 67,386 2005 NM ROW 222 9,379 16,714 12,433 38,748 7,802 13,233 21,035 59,783 2006 NM ROW 218 8,590 19,998 15,359 44,165 7,408 15,695 23,103 67,268 2007 NM ROW 225 8,559 14,855 11,284 34,923 6,094 18,324 24,418 66,890 2008 NM ROW 301 6,953 8,735 5,580 21 ,569 4,396 9,532 13,928 50,108 2009 NM ROW 337 6,360 12,020 11 ,178 29,895 6,005 12,826 18,831 48,726 2010 NM ROW 116 6,405 9,468 10,242 26,231 4 ,774 20,953 25,727 51,958 2011 NM ROW 268 6,999 8,922 7,496 23,685 4,064 7,924 11,988 35,673 2012 NM ROW 603 6,168 7,232 8,309 22,312 4 ,373 7,986 12,359 34,671 2013 NM ROW 519 6,006 6,498 13,329 26,352 2,339 24,384 26,723 53,075 2014 NM ROW 518 6,551 7,384 12,371 26,824 3,127 16,979 20,106 46,930 2015 NM ROW 260 5,412 6,522 8,573 20,767 2,382 12,081 14,463 35,230 2016 NM ROW 285 6,116 6,317 8,771 21,489 1,630 11 ,161 12,791 34,280 2017 NM ROW 1,652 4,718 6,593 5,252 18,215 2,301 5,030 7,331 25,546 Sub-Total for ROW 6,016 106,213 163,666 157,066 432,961 79,236 201 ,321 280,557 735,678 Sub-Total for NM 6,016 106,213 163,666 157,066 432,961 79,236 201,321 280,557 735,678 Total: 6,016 106,213 163,666 157,066 432,961 79,236 201 ,321 280,557 735,678 15}'r AVG 49,045 Page 151 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IAI TFA PRAPR IFTARY l~JFARMAT IA~d Figure 2.2.1: Industrial Facilities Within Approximately 5 Miles of the Proposed Site Page 152 of 689 Revision OC May 201 8

A TTACHMENT 2 TO HOLTEC LETTER 5025025 HQI IEC PBOPRIET A.RY lf>l f=ORMATION 1320 Nominal Diameter 1155 990

~

Cl)

, 825

"'O CV 660 CV

...CV Cl)

...CV

"'O 495 N

CV

I: 330 165 0

500 600 700 800 900 1000 1100 1200 1300 1400 1500 Maximum operating pressure (psi)

Figure 2.2.2: Hazard Area Radius as Function of Pipeline Pressure and Diameter [2.2.2)

Page 153 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PRGPRleTARY INFORMATION Figure 2.2.3: WIPP Transportation Route.

Page 154 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATION

.... --- 1

-- - *- 1 Figure 2.2.4: Transportation Infrastructure near the CIS Facility Site Page 155 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATIOM Holtec CISF (proposed) Holtec CISF (proposed) =

to WIPP 16 m iles WlPP Holtec CISF (proposed) =

to NEF 38 miles IIFP Site Holtec CISF (proposed) to IIFP Site =23 miles

NEF Holtec CISF (proposed) to WCS CISF (proposed) = 39 miles e WCS CISF (proposed)

Figure 2.2.5: Existing or Planned Nuclear Facilities in the Vicinity of the Proposed Site Page 156 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION

. /l,Jrway Fixes City

>> Victor Rootes

,:>> H~TORE CIS Facility Holding/Approach Pattern

, IR-128 IR-128 Roote Fixes

_. IR-180 IR-180 Roote Fixes S, IR-192

, IR-192 Roote Fixes IR-194 Roote Fixes Figure 2.2.6: Air Transportation Infrastructure Near the CIS Facility Page 157 of 689 Revision OC May 201 8

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I !OLTEC PROPRIETARY l~lFORMAT ION Figure 2.2.7: IR-128 Exit Racetrack Page 158 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HObTeC PROPRleT/1.RY ll'>IFORMATIOl'>I 2.3 METEOROLOGY 2.3.1 Regional Climatology The climate at the Site is typically semi-arid with generally mild temperatures, low precipitation, low humidity, and with a hig h evaporation rate. The winter weather typically has hig h pressure systems that are located in the central part of the western U.S. and low pressure systems located in north-central Mexico. In the summer, the region is typically affected by low pressure systems located over Arizona. Overall, precipitatio n is low and storms are infrequent. Winds during the spring may cause dust during construction periods; however, it is anticipated to be a minimal and temporary impact in comparison to the naturally occurring dust.

Meteorological information was obtained from various sources, including the Western Regional Climate Center (WRCC) and other sources as noted in this section. The use of the data from the WRCC and other sources are appropriate due to proximity to the proposed Site and are expected to have similar climates. The WRCC is a governmental department closely associated with the National Oceanic and Atmospheric Administration (NOAA) and the National Weather Service (NSW). The data fro m the WRCC is generall y considered to be the authoritative source of meteorological data for the reg ion (see Appendix A, Section A.2 of the ER [1.0.41 for additional details regarding the applicability of data from the WRCC).

Temperatures. Data collected over approximately the past 75 years at the Lea County Regional Airport station [2.3. 1] is summarized in Table 2.3. 1. The temperature data reported in this s ummary table includes mo nthly average values for the minimum, average, and maximum temperatures as well as the monthly extreme values for the minimum and maximum temperatures.

Additionally, annual values for these temperature parameters are included.

A site-specific 3-day average ambient temperature is defined by evaluating local weather service records for the Lea County in which the site is situated. The results are as follows:

Location: Lea Regional Airport

Records Period: 1980 - 20 17

M aximum 3-Day Average Temperature : 90.7°F Winds. Prevailing wind directions and wind speeds at the Lea County Regional Airport station are presented in Table 2.3.2 and depicted graphically in Figure 2.3.2. The average wind speed is approximately 12 miles per hour (mph) and the prevailing wind direction is from the south. Winds are typically moderate, between l mph and 19 mph blowing 84 percent of the time, with calm winds (winds less than 1.3 mph) occurring only approx imately 8 percent of the time [2.3.1].

With respect to wind gusts, the average wind speed of all of the maximum gusts is approximately 25 mph. T he prevailing wind direction for wind g usts is wind from southwest during 11 percent of the observations; however, the wind gusts are out of the south, south-southeast, and southeast during 30 percent of the observations. Typical gusts range in speed from 13 mph to 32 mph, comprising of 86 percent of the gusts. Gusts range in speed from 32 mph to 47 mph occurred during 13 percent of the observations, and less than 1 percent of the gusts observed were over 47 mph [2.3. l].

Page 159 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY llqfiORMAilOlq Mixing Heights. Mixing height is the height above the ground where the strong, vertical mixing of the atmosphere occurs. G.C. Holzworth developed mean annual morning and afternoon mixing heights for the contiguous United States [2.3.2]. The results of Holzwo1th's calculation methods for mixing heights include mean annual morning and afternoon mixing heights at the Site of approximately 1,430 feet and 6,854 feet, respectively [2.3.2]. Table 2.3.3 shows the average morning and afternoon mixing heights for Midland-Odessa, Texas, which is the nearest available area with mixing height data, located approx imately 100 miles southeast.

Tornadoes. Tornadoes are typically classified by the F-Scale classification. The F-Scale classification of tornadoes is based on the appearance of the damage that the tornado causes. The six classifications range from FO to F5 with an FO tornado having winds of 40-72 mph and an F5 tornado having winds of 261-3 18 mph [2.3.3]. Note that as of February 1, 2007, an enhanced F-scale for tornado damage went into effect in the United States. The switch to the enhanced F-scale involves:

Changing the averaging interval for wind speed estimates from the fastest quarter-mile wind speed to a maximum three-second average wind speed.

Changing the minimum tornado wind speed from 40 mph to 65 mph.

Changing the wi nd speed intervals associated with each F scale class.

The enhanced F-scale uses three-second wind gusts estimated at the point of damage based on a judgment of eight levels of damage to 28 indicators. The e nhanced F-scale has six classifications, EFO to EF5, with an EFO tornado having three-second gusts of 65-85 mph and an EF5 tornado having three-second gusts of over 200 mph [2.3.4].

Based on a United States-wide study performed on a state by state basis, the average tornado probability for any F-scale tornado for the Site is between l x l0*6 and 2x10 4 , as is presented in Figure 2.3.3 [2. 1.3]. Ninety two tomados have occurred in Eddy and Lea counties since 1954. The highest number of tornados in any given year was 15 in 1991; of which, 14 occurred over a two day period. The lowest num ber of tornado in a year has been zero, with a mean average of 1.5 tornados occurring in a year. Most tornados recorded were FO in scale and occurred in the spring

[2.3.5].

Hurricanes. The Site is located over 500 miles from the ocean ic coast. Because hurri canes lose their intensity quickly once they pass over land, impacts from a hurricane at the Site are unlikely.

Thunderstorms. Thunderstorms can occur during every month of the year, but generally occur from March through October of each year. Thunderstorms occur an average of 39 days per year in Carlsbad, New Mex ico. The seasonal averages are: 2.7 days in spring (March through May); 8.3 days in summer (June through August); 2.3 days in fall (September through November); and less than 1 day in winter (December through February) [2.3.1). Occasionally, thunderstorms are accompanied by hail [2. 1.15].

Precipitation. A summary of precipitation data collected at the Lea County Regional Airport station resulted in an annual mean average total precipitation of 10.2 inches with monthly mean average totals ranging from 0.24 inches in March to 1.9 inches in September. The monthly minimum total is 0.00 inches and the monthly maximum total is 6.2 inches. The highest daily total is 3.6 inches occurring in December of 2015. A summary of this information is presented in Table 2.3.4 and depicted graphically with monthly average total precipitation in Figure 2.3.4 [ 2.3.1].

Page 160 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOtTe:C PROPRIETARY llqfiORMAT IOM A summary of snowfall data collected at the Lea County Regional Airport station resulted in an annual mean average total precipitation of 5 .13 inches with monthly mean average totals ranging from 1.84 inches in February to 0.0 inches from May to October. The monthly minimum total is 0.00 inches and the monthly maximum total is 2 1.2 inches. The highest daily total is 10.00 inches occurring in February of 1956 [2.3. 1].

Based on the season, atmospheric pressure systems can affect temperature and cause cloud formation. Clo uds are formed when warm, moist air rises into the atmosphere and the droplets are cooled. When the droplets cool, the water fro m the air condenses into tiny droplets and forms clouds. This occurs during low pressure system. These low pressure system s typically occur during the spring and summer. Climatology data indicate the relative humidity throughout the year ranges from 45 percent to 6 1 percent in the region, with the highest humidity occurring during the early morning hours [2.1.15].

2.3.2 Local Meteorology There are no on-site weather stations, however due to the proximity of the Lea County Regional Airport weather station to the Site (approximately 30 miles away), it is reasonable to say that the data presented in Section 2.3 ..l adequately represents the on-site conditions for Local Meteorology.

Additional detai ls regarding the applicability of this data can be seen in Appendix A, Section A.2 of the ER [1.0.4].

2.3.3 Onsite Meteorological Measurement Program There are no on-site weather stations, however due to the proximity of the Lea County Regional Airport weather station to the Site (approximately 30 miles away), it is reasonable to say that the data presented in Section 2.3 ..1 adequately represents the on-site conditions for Local Meteorology.

Additional detai ls regarding the applicability of this data can be seen in Appendix A, Section A.2 of the ER [1.0.4]. After the License is issued for the CIS Facility, Holtec will establish an on-site meteorological data collection system. That system will collect, at a minimum, temperature, precipitation, and wind data.

Page 161 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION Table 2.3.1 LEA COUNTY REGIONAL AIRPORT STATION TEMPERATURE DATA (09/01/1941-06/09/2016) [2.3.1]

Average Monthly Average Monthly Minimum Maximum Average Monthly Extreme Minimum Extreme Maximum Month Temperature °F Temperature °F Temperature °F Temperature °F Temperature °F January 27.72 56.25 41.98 4.00 81.00 February 30.68 61.12 45.90 -11.00 84.00 March 35.67 67.32 51.53 14.00 86.00 April 44.32 75.05 59.69 24.00 93.00 May 53.77 84.05 68.91 28.00 103.00 June 63.7 1 92.90 78.31 51.00 107.00 July 66.73 93.62 80. 17 52.00 108.00 Au2ust 65.50 92.57 79.04 55.00 104.00 September 58.29 86.47 72.37 41.00 104.00 October 47.82 75.76 61.79 24.00 94.00 November 34.23 64.42 49.33 4.00 85.00 December 28.78 59.04 43.91 7.00 79.00 Annual 46.34 76.03 61. 19 -11.00 108.0 Note: The extreme maximum temperature was recorded in July of 2000 and again in July 2001 at l08°F and the extreme minimum temperature was recorded in February of 1951 at -11 °F.

Page 162 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLT EC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Table 2.3.2 LEA COUNTY REGIONAL AIRPORT STATION ALL WIND DATA (12/01/1948-12/31/2014) [2.3.1]

Wind Speed N NNE NE ENE E ESE SE SSE s SSW SW WSW w WNW NW NNW Total (mph) (%) (%) (%) (%) (%) ( %) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%)

1.3-4 0.1 0.1 0.2 0.1 0.2 0.2 0.2 0.2 0.3 0.2 0.2 O. l 0.1 0.1 0. 1 0.1 2.5 4-8 1 0.8 0.9 0.7 1.8 1.3 1.4 1.4 2.7 1.7 1.3 0.9 0.6 0.5 0.6 0.5 18.2 8-13 2 1.5 1.7 1.5 3 2.8 3.9 4.5 6.2 3.4 2.8 2.3 1.7 1.2 1.1 0.9 40.4 13-19 1.4 1.2 1.1 0.6 1.1 1.2 2.2 2.8 2.9 1.6 1.9 1.8 1 0.7 0.6 0.5 22.7 19-25 0.5 0.4 0.2 0. 1 0.1 0.1 0.3 0.6 0.4 0.4 0.7 0.7 0.4 0.3 0.2 0.2 5.6 25-32 0.2 0.1 0.1 0 0 0 0 0.1 0.1 0. 1 0.2 0.3 0.1 0.1 0. 1 0.1 1.7 32-39 0 0 0 0 0 0 0 0 0 0 0 0.1 0 0 0 0 0.4 39-47 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0.1 47+ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Total 5.3 4.1 4.1 3.1 6.2 5.7 7.9 9.5 12.6 7.5 7.2 6.4 3.9 3 2.7 2.3 91.5

(%)

Avg.

Wind 12.6 12.4 11.4 10.5 10.0 10.5 11.3 11.9 11.0 11.3 12.9 14.1 12.8 13.4 11.9 12.3 10.8 Speed (mph)

NOTE: Total Calm W inds (Calm Winds is defined as less than 1.3 mph) is 8.4 percent Page 163 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INf'ORMATION Table 2.3.3 AVERAGE MORNING AND A VERA GE AFTERNOON MIXING HEIGHTS [2.3.2]

Summer Autumn Annual Winter (feet) Spring (feet) (feet) (feet) (feet)

Morning 95 1 1,407 1,988 1,375 1,430 Afternoon 4, 186 8,035 9,003 6,191 6,854 Page 164 of 689 Revision OC May 2018

A TTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY IMFOR MATIOM Table 2.3.4 LEA COUNTY REGIONAL AIRPORT STATION PRECIPITATION DATA (09/01/1941-06/09/2016) [2.3.1)

Monthly Monthly Extreme Daily Monthly Maximum Average Maximum Minimum Totals Totals Totals Totals Month (Inches) (Inches) (Inches) (Inches)

January 0.00 2.09 0.31 0.68 February 0.00 1.02 0.32 0.68 March 0.00 1.41 0.24 0.52 April 0.00 2.26 0.65 1.40 May 0.00 5.02 1.43 1.72 June 0.00 3. 19 0.75 1.77 July 0.00 3.49 1.17 1.98 August 0.04 4.08 1.32 2.28 September 0.05 5.84 1.85 2. 13 October 0.00 3.81 1.52 1.73 November 0.00 1.07 0.26 0.95 December 0.00 6.21 0.56 3.63 Annual 2.8 1 18.66 10.16 3.63 Page 165 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOL.TEi:C PROPRleTARY l~lFORMATION HOBBS LEA CO AP, NEW MEXI [O (294028)

Period of Record: 09/01/1941 to 06/09/2016 110 100

\10 u.. 80 70

"' &O

~

'- 50

~ 40

,0 30

~ 20 Q. 10 s:: 0

~

I- -10

-20 Jan 1 Mar 1 Ma!::J 1 Ju l 1 Sep 1 Nov 1 Dec 31 Feb 1 Apr 1 Jun 1 Aug 1 Oct 1 Dec 1 Day of Year Re<Jional

( Extreme Max - - Ave Max ~ Ave Mi n Extreme Min] Clil'IC!t..

Centel' Figure 2.3.1: Lea County Regional Airport Station Temperature Data (09/01/1941-06/09/2016) (2.3.1]

Page 166 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMAT ION Station Hobbs New Ne xi co MPH 32* 41' 15" ti 1.3 - 4 Latitude Longitude : 103° lJ' 01" W N 4 - 8 Elevation : 3661 ft. 18% 8 - 13 13 - 19 Element 19 - 25 25 - 32 32 - 39 39 - 47 12% 47 +

9%

~ II Start Date: Dec. l, 194e Sub-interval ~lindaw:s End Date: Dec. 31, 2014 Start End

¥ of Dar,; : 24137 o f 24137

¥ ob:s:po:s:s: e257g of 57g2ee s Date: Jan. 01 Dec . 31 Hour: 00 23

~le:stern Regional Climate Center Figure 2.3.2: Lea County Regional Airport Station AH Wind Rose (12/01/1948-12/31/2014)

[2.3.1]

Page 167 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION

- ~ ...;!I LOW COLOR tOOH

4. 10-4

5. 10- 4 3* Jo-4

4. 10-4 2* 10-4 l'!I 3* lo-4 J.10-4 D 2*Jo-4 5.10-5 D 1.1()-4

), J0-5 0 5.10-5

, . 10-6 D 1-10-5

1.10-6

PER YEAR Figure 2.3.3: Tornado Probability Map [2.1.3]

Page 168 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I !OLTEC PROPRIETARY l~lFORMAT ION HOBBS LEA CO AP, NEWMEXICO (294028)

Period of Record: 09/01/1941 to 06/09/2016

.... 2 .5 -------------*------

C:

..... 2 C:

~

Q

1. 5 11'

....a.

~

(.)

A) 0,5 Q.

0 Jan Mar May Jul Sep Nov Feb Apr Jun Aug Oct Dec Oa~ of Year M'estel"n Re~iond

( Average Total Monthly Precipitation J C lir.-.:ite Centel" Figure 2.3.4: Monthly Average Total Precipitation Lea County Regional Airport Station (09/0l/1941-06/09/2016) [2.3.1]

Page 169 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PR:OPR:IETAR:Y IMFORMATIOM 2.4 SURFACE HYDROLOGY 2.4.1 Hydrologic Description The Site lies within the Pecos River Basin (see Figure 3.5. l of the ER [l.0.4]), which has a maximum basin width of 130 miles, and a drainage area of 44,535 square miles. Th ere are no surface-water bodies or surface-drainage features on the proposed CIS Facility Site. The Pecos River is the closest surface water feature to the Site. At its nearest approach, the distance from the Site to the Pecos River is 26 miles. In Lea County neither of the two maj or drainage basins, the Texas Gulf Basin in the north and east and the Pecos River Basin in the south and west, contain large-scale surface-water bodies or through-flowing drainage systems. The surface water supplies that exist are transitory and limited to quantities of runoff impounded in short drainage ways, shallow lakes, and small depressions, including various playas and lagunas. The Texas Gulf Basin contains a lake, the Llano Estacada, and the Simona Valley. The Pecos River Basin contains the Querecho Plains, the Eunice Plains, and the Antelope Ridge [2.4.1, Section 2.5.1].

The CIS Facility Site is contained within the Upper Pecos-Black watershed; however, there are no freshwater lakes, estuaries, or oceans in the vicinity of the site (Figure 2.4. 1). Local surface hydrologic features in the vicinity of the site include a cluster of four saline playas that are located in the Querecho Plain area of the west-central part of the county. These playas, which retain runoff temporarily, are referred to locally as lagunas. Laguna Plata covers the largest area, about 2 square miles. Laguna Toston, the smallest of the four with a surface area of one-quarter square mile, is completely filled with sediments; the other three all contain accumulations of elastic sediments and salts (halite, gypsum) [2.4.5; 2.4.1 , Section 2.5. l]. Surface runoff from the Site flows into Laguna Gatuna to the east and Laguna Plata to the northwest [2. 1.3]. Surface drain age at the proposed Site is contained within two local playa lakes that have no external drainage. These playas are generally dry, but retain runoff temporarily [2.1.3]. Runoff does not drain to one of the state's major rivers. Figures 2.4.2 and 2.4.3 show hydrologic features in the vicinity of the CIS Facility.

The lagunas help to create shallow saline ground-water which exists under much of the Querecho Plain. Surface water is lost through evaporation, resulting in high salinity conditions in soils associated with the playas. These conditions are not favorable for the development of viable aquatic or riparian habitats. The presence of the shallow saline water has been recognized to the extent that the New Mexico Oi l Conservation Commission Order No. R-3221, banning the surface disposal of produced water into unlined pits within the State was amended (OCC Order No. R-322 1-B, July 25, 1968) to exclude much of the area [2.4.5; 2.4.6].

Laguna Gatuna is located on the eastern boundary of the Site. Laguna Gatuna is an ephemeral pl aya that covers a surface area of 0.54 square miles, has an average depth of 10 feet, and a total shore line of 4 miles. The lake, which sits at an elevation of 3,495 feet drains a watershed that covers 170 square miles. Laguna Gatuna was the site of multiple facilities for collection and di scharge of brines that were co-produced from oil and gas wells in the entire area; fac ility permits authorized discharge of almost one million ban els of oilfield brine per month between 1969 and 1992. As a result, saturations of shallow groundwater brine have been created in a number of areas associated with the playa lakes [2.4. 1, Section 2.4.2. 1].

Page 170 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATIOM Laguna Tonto is located approximately 2.5 miles northeast of the Site. Laguna Tonto is an ephemeral playa that covers a surface area of 0.28 square miles, has an average depths of 12 feet, and has a total shore line of 2 miles. The playa, which sits at an elevation of 3,53 1 feet, drains a watershed that covers 49 square miles.

Laguna Plata is located app roximately 1.8 miles northwest of the Site. Laguna Plata is an ephemeral playa that covers a surface area of 2 sq uare mil.es, has an average depth of 14 feet, and has a total shore line of 6 miles. The playa, which sits at an elevation of 3,432 feet, drains a watershed that covers 254 square miles. Laguna Plata is the largest of the playas in the vicinity of the site w ith a total water volume of approx imately 14,593 acre-feet. Laguna Plata is the topographically lowest point in the area and alluvial groundwater appears to flow toward this site

[2.4.1, Section 2.4).

Laguna Toston is the smallest of the playas in the vicinity of the CIS Facility Site with a surface area of one-quarter mile. The playa is a major input point for potash refinery brine and water appears to drain radially away from this location [2.4. l , Section 2.4].

The U.S. Geological Survey (USGS) does not have permanent stream gages in Lea County which measure dai ly surface flows. However, peak fl ow rates have been spot measured at M onument Draw (near Monument) and Antelope Draw (near Jal). Each of these Draws can occasionally convey sizable flows. In June of 1972, a flow of 1280 cubic feet per second (CFS) (the highest recorded) occurred at Monument Draw. In July of 1994, a flow of 530 CFS (also the highest recorded) occurred at Antelope Draw. These fl ows should be considered indicative of flows that can occur at other gullies and swales in Lea County (Lea County 2016, 1999).

The proposed CIS Facility Site is not located near any fl oodplains. The Site is located in an area of Lea County designated as "Zone D". The "Zone D" designation is used for areas where there are possible but undetermined fl ood hazards, as no analysis of flood hazards has been conducted or when a community incorporates portions of another community's area where no map has been prepared [2.4.3]. A digital version of the map panel for the CIS Facility location in the National F lood Hazard Layer is presented in Figure 2.4.4 [2.4.3]. Other than the playas, the nearest surface water is the Pecos River which is west of the Site. Like most ri vers in New Mex ico, the Pecos River is described as "extremely variable from year-to-year" due to its dependence on runoff The principle use of Pecos River water is for agriculture. There are no sensitive or unique aquatic or riparian habitats or wetlands at the Site, nor is there surface water in the vicin ity that is potable

[2.1.3].

Groundwater within Lea County is provided primarily by the High Plains Aquifer composed of the Ogallala Formation. Cretaceous and Triassic rocks underlying the Ogallala Formation limit downward percolation from the Ogallala Aquifer. The region includes portions of five declared underground water basins (UWBs): Capitan, Carlsbad, Jal, Lea County, and Roswell. (A declared UWB is an area of the state proclaimed by the State Engineer to be underlain by a groundwater source having reasonably ascertainable boundaries. By such proclamation the State Engineer assumes jurisdiction over the appropriation and use of groundwater from the source.) The Jal UWB falls entirely within the Lea County region, but the other four are shared with the Lower Pecos Valley region, although only a small portion of the Lea County UWB extends into the Lower Pecos Valley region, and Lea County overlies only a small extension of the Roswell Basin [2.4.6].

Page 171 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION The CIS Facility Site is within the Capitan UWB (Figure 2.4.5) and lies within the Upper Pecos-Black Watershed which is part of the Pecos River Basin (Figure 2.4.6). The Capitan UWB covers approximately 1,100 square miles and occupies the south-central portion of Lea County. The Capitan UWB is located within a geologic province known as the Delaware Basin, a subdivision of the Permian Basin. The Capitan UWB is aerially oriented in a northwest-southeast alignment above an arc shaped section of a formation known as the Capitan Reef Complex. The Capitan aquifer occurs within dolomite and limestone strata deposited as an ancient reef. The ground-water quality of the Capitan in Lea County is very poor. Other aquifers in the Capitan UWB are found in the overlying Rustler Formation4, Santa Rosa Sandstones, and Cenozoic Alluvium. The primary uses of ground-water from the Capitan UWB are mining, oil recovery, industry, livestock, and domestic use. The towns of E unice and Jal are located within the Capitan UWB, but cu rrently tap beds of saturated Quaternary alluvium located within the Lea County UWB and Jal UWB respectively [2.4.5].

The site topography is irregular, with a slight slope toward the north, with elevations ranging between about 3,500 and 3,550 feet above mean sea level [2.4.4]. Based on a review of the USGS topographic map, the elevation at the CIS Facility Site is approximately 3,530 feet above mean sea level. Several shallow depressions are shown along the western portions of the Site. Figure 2.4.7 illustrates local topography in the area of the proposed CIS Facility Site. A topographic high is present within the central portion of the property with ephemeral washes draining from this point; one to the west into Laguna Plata and another to the east into Laguna Gatuna. Both of these drainages would be able to accept a one day severe storm total within the 7.5 inch range with excess free board space. The natural drainage of the Site is useful by providing a natural area for impoundment of excess runoff during severe storms [2.4. 1].

The Project area is classified as Apacherian-Chihuahuan mesquite upland scrub [2.4.8]. This ecosystem often occurs as invas ive upland shrublands such as those that are concentra ted in the foothills and piedmonts of the Chihuahuan Desert [2.4.7]. Substrates are typically derived from alluvium, often gravelly without a well-developed argillic or calcic soil horizon that would limit infiltration and storage of wi.nter precipitation in deeper soi l layers. Deep-rooted shrubs are able to access the deep-soil moisture that is unavailable to grasses and cacti. Water held in storage in the soil is subsequently subject to evapotranspiration. Historical periods of high temperature and low precipitation in Lea County have resulted in high demands for irrigation water and higher open water evaporation and riparian evapotranspiration [2.4.6]. Evapotranspiration at the Site is fi ve times the precipitation rate, indicating that there is little infiltration of precipitation into the subsurface. Surface drainage at the Site is contained within two local playa lakes that have no external drainage. Runoff does not drain to one of state's major rivers. Essentially all the precipitation that occurs at the Site is subject to infiltration and/or evapotranspiration.

No major surface water supplies are available in Lea County, only intermittent streams, lakes, stock ponds, and small playas that collect runoff during thunderstorms. Intermittent streams that channel runoff include Lost Draw, Sulfur Springs Draw, and Monument-Seminole Draw in the northern half of Lea County, which is part of the Texas Gulf Basin, and Landreth-Monument Draw in the southern portion of the county, which flows to the Pecos River. The Site lies within the Pecos River Basin as depicted in Figure 2.4.8, which has a maximum basin width of 130 miles, and a drainage area of 44,535 square miles. The Pecos River generally flows year-round. The main Page 172 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOL'fEC PROP~IETAFH ltqFORMAT ION""

stem of the Pecos River and its major tributaries have low flows, and the tributary streams are frequently dry. Seventy-five percent of the total annual precipitation and 60 percent of the annual flow result from intense local thunderstorms between April and September. Due to the seasonal nature of the rainfall, most surface drainage is intermittent. There are no surface-water bodies or surface-drainage features on the proposed CIS Facility Site. The intermittent surface drainages, lakes, and watersheds in Lea County are shown on Figure 2.4.8 [2.4.6].

The USGS does not have permanent stream gages in Lea County which measure daily surface flows. However, peak flow rates have been spot measured at Monument Draw (near Monument) and Antelope Draw (near Jal). Each of these Draws can occasionally convey sizable fl ows. In June of 1972, a fl ow of 1,280 cubic feet per second (cfs) (the highest recorded) occurred at M onument Draw. In July of 1994, a flow of 530 cfs (also the highest recorded) occurred at Antelope Draw.

These flows should be considered indicative of flows that can occur at other gullies and swales in Lea County [2.4.5; 2.4.6].

The proposed CIS Facility Site is not located near any floodplains. The Site is located in an area of Lea County designated as "Zone D". The "Zone D" designation is used for areas where there are possible but undetermined flood hazards, as no analysis of flood hazards has been conducted or when a community incorporates portions of another community's area where no map has been prepared [2.4.3]. A digital version of the map panel for the CIS Facility location in the National Flood Hazard Layer is presented .in Figure 2.4.9 [2.4.3].

There are no wetlands on the proposed CIS Facility Site. Wetlands in the vicinity of the CIS Facility are shown on Figure 2.4.10.

As further discussed in sections 2.4.2 and 2.4.3, the Site can be considered "flood-dry" and therefore it can be concluded that none of the facilities important to safety structures will be affected by the Site's hydrologic features. Additionally, there are no surface water bodies on the Site and groundwater resources are at depths of approximately 300 to 400 feet, therefore no population groups are affected by normal Site operations.

2.4.2 Floods Floodplains are areas of low-level ground present along ri vers, stream channels, or coastal waters subject to periodic or infrequent inundation due to rain or melting snow. Risk of flooding typically depends on local topography, the frequency of precipitation events, and the size of the watershed above the floodplain. Flood potential is evaluated by the Federal Emergency Management Agency (FEMA), which defines the 100-year fl oodplain as an area that has a one percent chance of inundation by a flood event in any given year. Federal, state, and local regulations often limit floodplain development to passive uses such as recreational and preservation activities to reduce the risks to human health and safety. Floodplain ecosystem functions include natural moderation of floods, flood storage and conveyance, groundwater recharge, nutrient cycling, water quality maintenance, and diversification of plants and animals.

The proposed Site or Lea County has no floodplain identified or mapped for Lea County, New Mexico [2.1.6, 2. 1. 7]. Elevations in Lea County vary from 2,900 feet in the southeast to 4,400 feet in the northwest. This relief provides two surface water drainage basins in the county. The Texas Gulf Basin, located in the northern portion of Lea County, and the Pecos River Basin, located in Page 173 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATION the southern portion of the county, is separated by the Mescalero Ridge and its extended escarpment [2.1.3].

In Lea County neither of the two major drainage basins, the Texas Gulf Basin in the north and east and the Pecos River Basin in the south and west, contain large-scale surface-water bodies or through-flowing drainage systems. The surface water supplies that exist are transitory and limited to quantities of runoff impounded in short drainage ways, shallow lakes, and small depressions, including various pla yas and lagunas [2. 1.3].

The topography of the Site shows a high point located on the southern border of the Site and gentle slopes leading to the two drainages (Laguna Plata and Laguna Ga.tuna). Both of these drainages would be able to accept a one day severe storm total within the 7.5 inch range with excess free board space. The natural drainage of the Site is useful by providing a natural area for impoundment of excess runoff during severe storms [2. 1.3].

A site-specific flood analysis of the maximum precipitation event was prepared. The objective of this study was to determine the amount of flooding that would occur at the project site (as seen in Figure 2.4. 11) with 7.5 inches of rain during a 24-hour period using publicly available GIS data.

The boundary of the site (defined as Area of Interest (AOI)) was provided. All other GIS data for the analysis were identified, derived, and/or acquired from publicly available data sources. This data included a Digital Elevation Model (DEM) of the AOI, one foot contours of the area (derived from the DEM), hydrologic unit boundary for the 12-digit sub-watersheds (HUC-12), and the NRCS soils present in the AOI [2.4.9; 2.4.10; 2.4.11). Also derived from the DEM was a Triangular Interpolated Network (TIN) layer used in the polygon volume calculations. All data were projected into the NAD83 , UTM Zone 13N coordina te system.

The flooding analysis was conducted with ESRI ArcGIS for Desktop software, version 10.2.2, with 3D and Spatial Analyst extensions. The HUC-12 sub-watersheds layer was assessed for proximity to the site, and two sub-watersheds were ide ntified as relevant basins (i.e., Laguna Grande and Laguna Plata Watersheds). The Laguna Ga.tuna and Laguna Plata wetlands both were the downslope point of catchment for their respective watersheds. Acreage was calculated for each of these watersheds, and the watersheds were buffered to eliminate edge effects of contour creation. Two DEMs (east and west, corresponding to Laguna Grande and Laguna Plata, respectively) were extracted from the buffered layers and contours were created at one foot intervals.

The NRCS soils layer was clipped to the watershed boundaries. The soil attributes of concern, Depth to Restrictive Layer ( depth to impermeable bedrock in centimeters, "Dep2ResLyr") and Saturated Hydraulic Conductivity (Ksat in µm /second) were extracted and consolidated into one layer. The Ksat values were used from the top 0-80 inch active soil zone. The infiltration level (Ksat) was converted into inches of water absorbed per 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, and the Dep2ResLyr converted to inches. The restrictive depth was then halved to add conservatism, and 7.5 inches was subtracted from this value. Area where saturation and run-off occurred within the 24-hour/7.5 inch rain event were calculated for these soil types, normalized for feet, and multiplied by the Page 174 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION acreage for the respective watersheds, yielding acre-feet of runoff that were converted to cubic feet of runoff. These values were 23,379,663.14 ft 3 (Laguna Gatuna eastern wetland ibasin) and 15,508,872.72 ft3 (Laguna Plata western wetland basin). These volumes were used to determine the level of flooding in each watershed.

A TIN was created from watershed' s DEM. This provided a 3D functional surface representing elevations over the watershed and was used as an input for polygon volume calculation. From the contour layers, polygons were created in an ascending order of elevations from the lowest level in each laguna. The Polygon Volume tool was run iteratively on these polygons, calculating the volume between the polygon and the TIN surface. Based on the watershed and hydrologic modeling the results of the analysis show the volume of fl ooding in the eastern Laguna Gatuna would rise 5 feet from 3,500 feet to an elevation of 3,505 feet. The volume of flooding in the western Laguna Plata would rise 2 feet from 3,427 feet to an elevation of 3,429 feet. The Project site is bisected by the two sub-watersheds. The lowest elevation of the Project site on the west side is 3,501 feet which is 72 feet above the modeled flood elevation, and the east side is 3,523 feet which is 18 feet above the modeled fl ood elevation. In summary, this analysis indicates that the Project site will not flood during a 24-hour/7.5 inch rain event even with 50% reduction in the soil saturation capacity/depth to restriction which was added into this model as a conservative measure.

It should be noted that the model assumes that the playas were dry prior to the 24-hour/7 .5 inch rain event.

2.4.3 Probable Maximum Flood (PMF)

Because there are no significant bodies of water or rivers within 50 miles of the Site, the only plausible flooding hazard to the Site is from stormwater runoff during rain events. To estimate the potential effects of rainfall-induced stormwater runoff, Holtec reviewed precipitation data for the area spanning more than 50-years (see Paragraph 3.6.1.7 of the ER [1.0.4]), as well as other available data developed for other nuclear facilities in the area. The highest daily precipitation in the area was 3.6 inches, which occurred in December of 2015 [1.0.4].

The topography of the CIS Facility Site is irregular, with a s light slope toward the north. A topographic high is present within the central portion of the property with ephemeral washes draining from this point; one to the west into Laguna Plata and another to the east into Laguna Gatuna. Based on a review of the USGS topographic map, the elevation at the Site is approximately 3,530 feet above mean sea level. Several shallow depressions are shown along the western portions of the Site. The Site is not within the 100-year and 500-year floodplains. Table 2.4. 1 provides estimates of the 24-hour 100-year rain event for the Hobbs, New Mexico.

As discussed in Section 2.4.2, drainages on the Site would be able to accept a one day severe storm total within the 7.5 inch range with excess free board space. Because the Site's drainage areas can handle a greater max imum flood height than what the PMF has been determined to be, the site can be considered to be ":flood-dry".

Page 175 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRleT/1.RY lf>lf=ORM.'\TION-Per Table 2.3. 1 of the HI-STORM UMAX FSAR [1.0.6], the HI-STORM UMAX System is able to withstand a maximum flood height of 125 ft. Therefore, all ITS components of the system can be considered safe from flooding concerns.

With regard to the potential for surface erosion from flooding at the Site, as discussed in Section 4.3 of the ER [1.0.4], soils at the Site are considered to be only slightly suscepti ble to water erosion.

2.4.4 Potential Dam Failures (Seismically-Induced)

The nearest dams are Brantley Dam, approximately 38 miles, and Aval on Darn, approximately 3 1 miles from the proposed Site. Both dams are at an elevation more than 500 feet below the Site. As a result of the large distances to the nearest bodies of water, these bodies of water do not present a credible disruptive event for the proposed Site.

2.4.5 Probable Maximum Surge and Seiche Flooding There are no significant bodies of water or rivers within 50 miles of the Site and seiche flooding is excluded as a potential flood hazard.

2.4.6 Probable Maximum Tsunami Flooding The Site is approximately 500 miles from any coastal area and tsunamis are excluded as a potential flood hazard.

2.4.7 Ice Flooding The mean annual snowfall is 5. 1 inches recorded at the Hobbs weather station. The max imum recorded snow accumulation for Hobbs, NM, is 12.2 inches, and a 100-year, 2-day snowfall is 12. 1 inches [2.4. 14). The Site is not subject to flooding caused by ice jams. In the winter, during those periods when the playas are retaining temporary runoff, freezing of the retained water can occur.

2.4.8 Flood Protection Requirements Because the flooding analyses do not indicate that the Site would be subject to flooding, there are no flood protection requirements.

2.4.9 Environmental Acceptance of Effluents As stated in Chapter 14, the canister storage system does not create any radioactive materials or have any radioactive waste treatment system and thus provides assurance that there are no radioactive effluents from the spent fuel storage system. Additionally, surface drainage at the proposed Site is contained within two local playa lakes that have no external drainage. Evapo-transpiration at the Site is fi ve times the precipitation rate, indicating that there is little infiltration of precipita tion into the subsurface. The near surface water table is approximately 35-50 feet deep, where present and is likely controlled by the water level in the playa lakes. Therefore, there is little to no risk of effluents of any kind being accepted by the environment.

Page 176 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION Table 2.4.1: Estimates of the 24-hour 100-year Rain Event for the Hobbs, New Mexico

[2.4.13]

Mean Lower Limit Upper Limit Location (90 % Confidence (90% Confidence (90% Confidence Interval) Interval) Interval)

Hobbs 4030 6.43 inches 5.73 inches 7.03 inches Page 177 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMAT ION Larie Sat u,e p

Tatum i

ll .c ~

i'",

ij

t

~ '

~. '1 I

,.I I

2 ii,

! .A. Explanation

9 ..,._ Stream (dashed Elevallon (ft mst) j N where intermittent) 0 < 4,000

..} 0 Lake 0 4.000 - 6,000

~. 0 7.25 14 .5 City

.. Milas

~ [:'.:] County

~ (jJ Water planning region LEA COUNTY v REGIONAL WATER PLAN 2016 f Regional Map

"'--------------------------------- Figure 3-1 Figure 2.4.1: Regional Map [2.4.6)

Page 178 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMATIOM Holtec Hi-Store Facility 006 005 004 001 006 005 009 012 07 008 007 008 01 017 016 020S ..,.. o 32E 020 019 020 030 029 028 026 025 030 034

- Ral - Streams/Canals - Major Roads Access Roacl D Le);es/Pleyas C] NM To'Mlsh1p1

- Existing Plpe~ne LJ ro., Secwns

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..:;=-=-- --====---!iilH 2

Hot1ec Footprt'lt Figure 2.4.2: Location of Hydrologic Features in the Vicinity of the CIS Facility Site [2.4.2]

Page 179 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Figure 2.4.3: Lakes/Playas in the Vicinity of the CIS Facility [2.4.4)

Page 180 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLT EC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION FEMA's National Flood Hm.anl Layer (Offldal)

N..iL (cllck to exp1tnd]

LOMRs 0 ffflactlVe LOMAa FIRM Plnels D

Cn;,55-Ser:tlons Flood Hazerd BOund1111il!S Umlt Unes SFHA / Flood Zone P.t\N~

Bounda,y JSOfl_g!!.250 Other Boundaries e ff.:IIJl".2010 Flood Hazard zones a 1 % Annual Chance flood Hazard

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Flood Hazard Area with Reduced

!>eta from Flood lnsurellCII! Rate Maps (FIRMs) wh- available dlgltally. N- NFHL FIRMt!ltl!! Print epp avallable: G.8ml http://tlnyurl.com/j4xwp5e USGS 1111!! Nadonal Map: Orthal magery I Nlll:lonel Gecspatlal-I ntil!lllgenCI!! AQl!!flcy ( NGA); Delta Sbt:I! Un~lty; Esr1 I Print here l nm!!illd:

http://tlnyurl.oom/j4xwp5e Support: F'EMAMepSpeclelfstOrlskmepcds.com I USGS 'n'le Nattonel Map: Ortholmegery Figure 2.4.4: FEMA's National Flood Hazard Layer for the CIS Facility Site [2.4.3]

Page 181 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLT EG PROPRIETARY l~lFORMATION Source: NM0SE.20l4a and 2014c Roswell

~

/;

~

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~

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~

z Capitan 0

u,

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~ __ Stream (dashed NMOSE-declared NMOSE groundwater

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where In term lltent) groundwater basin model i' N [ ; , Lake Ocapllan ~ Carlsbad

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[2.4.6]

Page 182 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC F'~OF'~IETAFH INFO~MATIOI~

Ie

"'~

!t, Mustang Draw

~

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,A. Explanation Source: USGS,2014c an d2014d

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!, N

USGS stream gage t!:il County

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c ~ Watershed REGIONAL WATER PLAN 2016 u

M_a.jo_r_s_u_rf_a_c_e_o_r_a_in_a_g_e_s_,_s_t_r_e_a_m_G_a_g_e_s_,_R_e_s_e_rv_o_ir_s_,_a_n_d_L_a_k_e_s..

Figure 5-7 Figure 2.4.6: Major Surface Drainages, Stream Gages, Reservoirs, and Lakes

[2.4.6]

Page 183 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATIOM Figure 2.4.7: General Topography around the Proposed CIS Facility Site [2.4.4]

Page 184 of 689 Revision OC May 2018

A TTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMA'flOrq Upper Pecos *Long A rroy

~

a e

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~

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~

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~.

~

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- stream (dashed where Intermittent) i:;, Lake (iJ Water planning region

~

\~~ Rlver basin C3 Watershed REGIONAL WATER PLAN 2016 LEA COUNTY

"~

0

~

Major Sutface Drainages, St ream Gages, Reservoirs, and Lakes Figure 5-7 Figure 2.4.8: Major Surface Drainages, Stream Gages, Reservoirs, a nd Lakes

[2.4.6]

Page 185 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLT EC LETTER 5025025 I IAI TFA PRAPR IFTARY INFARMAT IAN FEMA"s Natlonal Flood Hazard Layer (Oftldal)

N"'L (clkk ID apt1nd)

LOHRs D Eff'llctlVe LOMAs FIRM Pllnels 0

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Fut\lr@ Oandltlons 1 qc. Annual Chence F1ood Hazard Area with Reduced oat.a from Flood Insurance Rate Maps { FIRMs) wl'I- avallable dlgltally. New NFHL FIRMette Print app 1Y1llable: Q.8ml http://tlnyurl.com/j,Cxwp5e USGS The Nlltion11l Map: Orthal magery I National Geospatllll-Intelllgence AQency {NGA); Deb ~ University; Esrl I Print llere Instead:

l'lttp://tl11y11rl.com/j4xwpSe Support: FENAMapSpeclalfst@rtskmapcds.mm I USGS The National Map: Ortl'lolmagery Figure 2.4.9: FEMA' s National Flood Hazard Layer for the CIS Facility Site [2.4.3]

Page 186 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Wetland Types Estuarine and Marine Deepwater Estuarine and Marine Wetland Freshwater Emergent Wetland Freshwater Forested/Shrub Wetland Freshwater Pond 1..1ke Other Figure 2.4.10: Wetlands in the vicinity of the CIS Facility Site [2.4.12]

Page 187 of 689 Revision OC May 201 8

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROPRIETARY INFORMAT ION 2.5 SUBSURFACE HYDROLOGY The Site is located in the Capitan Underground W ater Basin (UWB) as shown in Figure 2.5.1

[2.5.l]. A declared groundwater basin is an area of the state proclaimed by the State Engineer to be underlying a groundwater source having reasonably ascertainable boundaries. By such proclamation, the State Engineer assumes jurisdiction over the appropriation and use of groundwater from the source. The Capitan UWB covers approximately 73 1,500 acres in the south-central portion of Lea County. It is located within a geologic province known as the Delaware Basin, a subdivision of the Permian Basin. The Capitan UWB is oriented in a northwest-southeast alignment above an arc-shaped section of a formation known as the Capitan Reef Complex. The Capitan aquifer occurs within dolomite and limestone strata deposited as an ancient reef. The groundwater quality of the Capitan in Lea County is very poor, with total dissolved solids ranging from 10,065 to 165,000 milligrams per liter (mg/L).

Other aquifers in the Capitan UWB are found in the overlying Rustler Formation, Santa Rosa Sandstone, Ogallala Formation, and Cenozoic alluvium and are important sources of groundwater in the Capitan UWB. The depth to the top of the Rustler Formation ranges from 900 to 1,100 feet.

Potable groundwater is available from three geologic units in southern Lea County; the Triassic Dockum shale, the Tertiary Ogallala, and Quaternary all uvium [2.5.2]. No potable groundwater is known to exist in the immediate vicinity of the Site. Shallow groundwater is present in a number of locations in the area, but water quality and quantity are marginal at best and most, if not all, shallow wells that have been drilled in the area are either abandoned or not currently in use. Potable water for the area is generall y obtained from potash company pipelines that convey water to area potash refineries from the Ogallala High Plains aquifer on the caprock area of eastern Lea County.

At present, water is generally obtained from these pipelines for other area users.

Much of the shallow groundwater near the Site has been directly or indirectly influenced by brine discharges from potash refining or oil and gas production. Potash mines have discharged thousands of acre-feet of near-saturated refinery process brine to Laguna P lata and to Laguna T oston for many years. But discharges ceased in Laguna Pl ata in the mid-l 980s and in Laguna Toston by 2001. Laguna G atuna was the site of multiple facilities for collection and discharge of brines that were co-produced from oil and gas wells in the entire area; facility permits authorized discharge of almost one mi llion barrels of oilfield brine per month between 1969 and 1992. As a result, saturations of shallow groundwater brine have been created in a number of areas associated with the playa lakes [2. 1.3].

Evapo-transpiration at the Site is five times the precipitation rate, indicating that there is little infiltration of precipitation into the subsurface. There are numerous low permeability layers between the surface and the expected groundwater level [2.1.3]. Because of the depth of groundwater, excavation during construction would not reach the groundwater. Groundwater at the Site would also not likely be impacted by any potential releases; therefore, groundwater would be unaffected by the proposed activities. The near surface water table appears to be 35-50 feet deep, where present, and is likely controlled by the water level in the playa lakes. No groundwater was encountered in the test boring on the west side of the Site in the vicinity where the ISFSI would be located [2. 1.3]. Consequently, no impacts from the near surface water table would be expected. Additional information regarding groundwater can be found in Sections 3.5.2 and 4.5 of the ER [ l.0.4].

Page 188 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY llqfiORMAT IOlq Well drilling was conducted at the Site in 2007. Two wells, ELEA-1 and ELEA-2 were drilled on the Site to identify the depth and character of water-bearing rocks. The goals of the drilling investigation were to identify the potential for thin groundwater saturation in lower alluvium perched on the Triassic shale, or deeper groundwater saturation in the Triassic shale. Locations of these wells and other wells in the vicinity are shown on the well location map in Figure 2.5.2.

Piezometer ELEA-1. A small amount of water was initially detected in the well; however the water has steadily declined to within a few inches of the bottom of the well and is attributed to the small amount of bentonite hydration water that was placed in the well to seal the upper annulus during completion. Based on the data obtained from ELEA-1 , no shallow groundwater saturation is present at the top of the Triassic shale at the location [2. 1.3].

Piezometer ELEA-2. Water level in this well rose slowly over several days to a static depth of 34 feet below land surface (3,497 feet above mean sea level). The water-bearing zone in this well consists of either fractures or tight sandy zones between the depths of 85 and 100 feet; water in this zone is under artesian head of 50 feet. Laboratory analyses of water samples from the well indicate that the water is high!y mineralized brine [2. 1.3].

From the data collected from the onsite drilling, shallow alluvium is likely non water-bearing at the Site. Groundwater saturation in the Triassic shale appears to be limited to small a mounts of highly mineralized water likely associated with the brine in Laguna Gatuna, where the brine is 3,500 feet above mean sea le vel [2. 1.3].

Additional well drilling was conducted at the ISFSI site in Fall of 2017. Three monitoring wells were drilled next to borings numbered Bl O1, B 106, and B 107 during the geotechnical field survey to determine the groundwater depth and elevation. The locations of these monitoring wells are shown in Figure 2.1.8. Figures 2.5.3 through 2.5.5 show Subsurface Profiles of the four soil and rock layers that were tested (details of these layers are further explained in Section 2.6.1 ).

Monitoring well B 101 (MW) was screened at the Santa Rosa foundation) while wells BI 06 (MW) and B 107 (MW) were screened at the Chinle Foundation. Groundwater was encountered from elevations 3272 to 3282 and 3430 to 3437 at wells B 101 (MW) and B 107 (MW), respectively. No groundwater was found in well B 106 (MW) after water was removed after drilling and waJI installation . These measurements, along with the measurements present from aforem entioned ELEA-2, were analyzed and tabulated in Table 2.5.1.

After field testing, it was determined that the measurement provided by well B 101 (MW) is indicati ve of the primary groundwater aquifer at the site, whereas well B 107 (MW) and ELEA-2 indicate the presence of isolated pockets of water in discontinuous aquifers above the lower permeability zones in the Chinle layer [2. 1.241. Therefore, the primary groundwater table depth is approximately 253 to 263 feet below the ground surface at the ISFSI site.

Based on this information presented in this section and the fact that there are no radioactive effluents from the proposed spent fuel storage system, it can be concluded that no buildup of radionuclides will occur in the subsurface hydrologic syste m.

Page 189 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IAI TFA PRAPR IFTARY INFARMAT IAN Table 2.5.1: Groundwater Elevation Data from Monitoring Wells [2.1.24]

Monitoring W ell Number 8 101 (MW) 81 06 (MW) B107 (MW) ELEA-2 Depth Elevation Depth Elevation Depth Elevation Depth Elevation 1

Sanded and Screened lnterval 3157.78 - 3357.08 - 3447.56 - 3480.49 -

377.7 - 414.4 174.3 - 203 82.4 - 107.5 53 - 98 3121.08 3328.38 3422.46 3435.49 10/1512017 NA NA 199.5 3331.9 102.6 3427.4 NM NM 10/16'2017 NA NA 199.5 3331.9 102.0 3428.0 NM NM 10/18.2017 NA NA 199 5 3331 .9 100.8 3429.2 NM NM 10/19'2017 NA NA 199 5 3331 9 100 5 3429.5 NM NM Water Level Measurements 10/24 '2017 NA NA 199 4 3332 0 98.0 3432.0 NM NM 10/262017 263.7 3271 8 NM NM NM NM NM NM 10/31 '2017 253.4 3282.1 NE NE 100.0 3430.0 NM NM 11/1/2017 253.4 3282.1 NE NE 99.6 3430.4 37.6 3495.9 11/16 '2017 253.6 3281.9 NE NE 93.1 3436.9 37.7 3495.8 Notes:

1. The sanded and screened interval corresponds to the upper and lower limits of the sanded zone.

2. Depth refers to depth below the ground surface.

3. Elevations are based on the North American Vertical Datum of 1988 (NAVD88).

4. "NA" indicates Not Applicable. Monitoring well was not installed by those dates.

5. "NM"indicates Not Measured.

6. "NE" indicates Not Encountered

7. B107(MW) was bailed dry after 10/2412017 water level measurement.

8 Data for B 106(MW ) from Oct15 to Oct24 indicate water levels below bottom of screen section, within the silt trap. These readings indicate groundwater at this 9 ELEA-2 sanded and screened interval information 1s based on the Drillhole Log ELEA-2 from the GNEP Eddy Lea Siting Study (2007).

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A TTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMAT IOM Oclobor 6, 2016 1:288,89S

- Special Cond111on .Aleas 27S 5S 11 ml 275 S.5 11 km Declare d Ut1dtNground Witt(N B as ins Cap11an Carlsb:aid Lea Count:,

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATIOM

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~ I r-CALI01E

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~ 2..._ DIAMETER PVC RSSER PFE 1 PROF1.ES N#J BailNG LOCAllONS ARE ~\'N W FIG. 2 31-;?i

2. SEE DETAILED Sl.6SI.R'ACE l'ROl'1..ESFOR AOOITIOIW.

0 50 100 ORI.UNG NI) SAl,lf\JNG N'OR>&4TION _ 3t,0

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Camden,-~ Prqea 1703345 l>ecenD!r2017 Ag 3 Figure 2.5.3: Subsurface Profile A [2. 1.24]

Page 193 of 689 Revision OC May 201 8

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEG PROPRIETARY INFORMATIOM 3550

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I Ill 3'50 3425 CHINLE CHIN\£ -

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NOTES:

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~ GROllO WATER l£VB. MEASlRBl IN

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Csnden, New Jeney Prqect 17033<!5 Decermer 2017 F,g.4 Figure 2.5.4: Subsurface Profile B [2.1.24]

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION 35111 35111

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Csnden, New Jeney Prqea 1703345 Cece..- 2017 F,g. 5 Figure 2.5.5: Subsurface Profile C [2.1.24)

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ATTACHMENT 2 TO HOL TEC LETTER 5025025 HObTeC PROPRleT/1.RY ll'>IFORMATIOl'>I 2.6 GEOLOGY AND SEISMOLOGY This section identifies the geological and seismological characteristics of the Site and its vicinity.

The location for the proposed Site, and sites in the vicinity including the WIPP (located 16 miles southwest), and the NEF (located 38 miles southeast), have been thoroughly studied in recent years in preparation for construction of other facilities. Data are available from these investigations in the form of various reports [2.1.3, 2. l.24, 2.6. 1, 2.6.2]. T hese documents and related material provide a substantial database and description of regional and site-specific geological conditions at the proposed Site.

2.6.1 Basic Geologic and Seismic Information The Site is located in the northern portion of the Delaware Basin, a northerly-trending, southward plunging asymmetrical trough with structural relief of greater than 20,000 feet on top of the Precambrian basement rock. The Basin was formed by early Pennsylvanian time, followed by major structural adjustment from Late Pennsylvanian to Early Permian time. During the Triassic period, the area was uplifted, resulting in deposition of elastic continental shales (redbeds).

Continuing uplift resulted in erosion and/or nondeposition until the middle to late Cenozoic period, when regional eastward tilting completed structural development of the basin as it exists today.

Shallow subsurface structure at the Site consists of gently east sloping beds of Triassic age redbeds, dipping two degrees to the east. Faulting has not occurred in the northern Delaware Basin in the area of the Site. The regional geology suggests that there have been no recent, dramatic changes in geologic processes and rates in the vicinity of the Site [2.1.3].

During most of the Permian period, the Delaware Basin was the site of a deep marine canyon that extended across southeastern New Mexico and west Texas. Major structural elements of the Delaware Basin area are shown in Figure 2.6.1. The major structures of the basin include the Guadalupe Mountains on the west side, the Central Basin P latform on the east side, and the Capitan Reef Complex on the west and north sides of the basin. The reef created steep slopes toward the basin and the thickness of sediments grows precipitously toward the center of the basin from the margin of the reef. The Central Basin Platform forms an abrupt eastern terminus to the Delaware Basin; it is a steeply fault-bound uplift of basement rocks that grew through the early and middle Paleozoic period such that most of the pre-Permian sedimentary section is missing from its apex.

Great thickness of organic-rich marine deposits in the basin and the presence of abrupt structures in the Capitan Reef Complex and Central Basin Platform combined to produce a prolific oil and gas province. These areas ha ve been the focus of intense petroleum exploration and development activities since approximate ly 1920. Surficial geology and subsurface structure across the Delaware Basi n are depicted in the maps and cross section in Figures 2.6.2 through 2.6.4.

Thickness of sediments in the basin exceeds 20,000 feet, and Permian strata alone account for more than 13,000 feet of sedimentary materials [2. l.3].

The geologic formations of concern beneath the Site comprise, from oldest to youngest,. consist of Permian-aged rocks (Wolfcamp series, Leonard series, Guadalupe series, Ochoa series); Triass ic-aged rocks (Dockum Group); and Tertiary and Quaternary rocks (Lower Gatuna Formation, Upper Gatuna Formation); and alluvium. A stratigraphic column for the above units in provided in Figure 2.6.5.

Page 196 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMAT IOM The entire Site is underlain by Triassic bedrock consisting of shale, siltstone, and minor, fine-grained, poorly sorted sandstone. Most of the proposed operational area is relatively flat and the shale bedrock is covered by a laterally extensive veneer of 25 feet of Quaternary pediment deposits consisting of well sorted eolian sand and sandy-gravelly materials near the bedrock inte rface. The Mescalero Caliche unit is near the surface and is about 10 feet thick at the Site.

Most of the proposed operational area is relatively flat ranging from 3,520 feet above mean sea level (AMSL) on the northern end to 3,535 feet AMSL on the southern end. The surficial geology consists of Quaternary Pediment deposits (25 feet thick) overlying Triassic-age shale bedrock. The different soil/geologic layers are described as follows:

Surface Soil: sandy and well-drained (0 to 2 feet below grade);

Mescalero Caliche: well developed, naturally cemented calcium carbonate, laterally extensive, tightly bound and erosion resistant (2 to 12 feet below grade);

Quaternary Sands: well sorted eolian sand and sandy-gravelly materials near the bedrock interface (12 to 25 feet below grade);

Dockum Group: Triassic-age, predominantly shale, siltstone, and minor, fine-grained, poorly sorted sandstone (25 to greater than 100 feet below grade).

To determine the subsurface profile at the CIS Facility, a geotechnical survey was conducted. Nine borings, labeled B 101 through B 109, were drilled throughout the area: seven at the ISFSI pad, one along the haul path (Bl08), and one at the cask transfer building (B l09). The location of each of these borings can be found in Figure 2. 1.8. A summary of the boring exploration data including drilling, sampling, and field test notes, is located in Table 2.6. l . Subsurface profiles produced based on the subsurface exploration results are located in Figures 2.5.4 through 2.5.6, with more detailed subsurface profiles located in Figures 2.6.6 through 2.6.8. In addition, boring logs were developed to provide deta ils of the subsurface geology e ncountered during the testin g process.

These boring logs can be found in Appendix C of the referenced geotechnical report [2. 1.241.

Subsurface profiles were then produced based on the subsurface exploration results. These profiles are located in Figures 2.5.4 through 2.5.6, while more detailed subsurface profiles are located in Figures 2.6.6 through 2.6.8. In addition, boring logs were developed to provide detail s of the subsurface geology encountered during the testing process. These boring logs can be found in Appendix C in the attached GEi geotechnical rep At the ISFSI location (B 101-B 107), five primary subterranean layers were observed, Figures 2.6.6 through 2.6.8:

Top Soil layer, which consists of clayey sand with gravel on the south corners or lean clay with sand in the center and north corners of the ISFSI site.

Caliche layer, which consists of silty sand with gravel for all borings, along with additional layers of narrowly graded gravel with sand and widely graded sand with silt and gravel for the northwest and southwest corners, respectively.

Residual layer, which consists of various layers of clayey sand and sandy lean clay at all borings, except the northeast corner, which only included clayey sand . The center has an additional layer of clayey sand with gravel.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRleT/1.RY lf>lf=ORM.'\TIGN

Ch inle layer, which consists of various layers of Jean clay, sandy lean clay, lean clay with sand, and clayey sand. Mudstone was encountered at this layer for all borings.

Santa Rosa layer, which consists of various layers of mudstone and sandstone. Only borings BlOl and B105 at the southern corners encountered thi s layer.

These borings describe the sub grade and under-grade space makeup of Spaces B, C, and D beneath the JSFSI pad in Figure 4.3. 1.

At the haul path (B 108), four primary subterranean layers were tested:

Top Soi l layer which consists of clayey sand.

Caliche layer which consists of silty sand with gravel.

Residual layer which consists of various layers of clayey sand, sandy lean clay, and clayey sand with gravel.

Ch inle layer wh ich consists of vario us layers of lean clay with sand, and then sandy lean clay before the end of boring.

At the CTF site (B 109), fo ur primary subterranean layers were tested:

Top Soi l layer which cons ists of lean clay with sand and sandy lean clay with gravel.

Caliche layer which consists of clayey sand and sandy lean clay layers.

Residual layer which consists of various layers of sandy lean clay, clayey sand, and lean clay with sand.

Chinle layer which consists of various layers of lean clay, sandy lean clay, lean clay with sand, and clayey sand. Mudstone was encountered at this layer.

Soil properties, such as grain size, specific gravity, density, Atterberg limits, shear velocity, and water content were determined and arc tabulated in Tables 2.6.2 through 2.6.4. The graphical Atterberg limit results and shear wave velocities are shown in Figures 2.6.9 and 2.6.10, respectively. All of the testing deliverables are defined in the geotechnical report l2.1.24] and are summarized in Tables 2.6.2 a nd 2.6.3 below. Table 2.6.5 provides locations of applicable data in the geotechnical report [2. 1.241.

The Top Soi l layer ranges from 3 to 4 inches deep, but was 8. 1 feet thick at the CTF. The soil consists of varying loose-to-medium dense amounts of sand and clay. Next, the Mescalero Caliche layer ranges from 4.4 to 13.5 feet thick. The soil consists of varying dense-to-very dense amounts of sand and gravel with silt, with unit weights between 84.5 to 94.2 pounds per cubic foot. Finall y, the Residual Soil layer ranges from 17 to 28 feet thick. T he soil consists of varying very hard or very dense amounts of clayey sand or sandy clay with traces of gravel, with unit weights between 98.6 to 126.4 pounds per cubic foot [2.1.24].

The Chinle Formation layer is the first bedrock layer encountered, from a depth of 27.5 to 40.5 feet. The rock consists of varying layers of lean clay or clayey sand , classified from the SPT N-values as very dense soil to soft rock. Lastly, the Santa Rosa Formation is the last tested bedrock layer, where samples were collected at depths of 401 and 222 feet from two separate borings. The rock consists of varying ranges of fine-to-coarse grained sandstone, with minor reddish-brown Page 198 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROPRIETARY INFORMAT ION siltstones and conglomerate. Details of the soil and rock layers are included in Section 5.2 of the geotechnical report [2.1.24].

Monitoring wells were drilled next to borings Bl O1, B 106, and B 107 to determine the groundwater elevation at the ISFSI site. Laboratory testing was conduc ted on the soil and rock extracted from these borings. As stated in Section 2.5, the primary groundwater table is at 253-263 feet below grade. Excavation to a depth of 25 feet below grade is expected for facility construction; thus, the construction activity will not be in contact with the groundwater table.

2.6.2 Vibratory Ground Motion Earthquakes of low to moderate magnitude have been documented within a 200 mile radius of the Site. The vast majority of the earthquake activity is located southeast of the Site in west Texas, and west/northwest of the Site in central New Mexico. The U.S. Geological Survey (USGS) earthquake database was used to query historical earthquakes within a 200 mile radius of the Site

[2.6.3]. Results of the search of the 200 mile radius yielded a total of 244 historical eaJthquakes with magnitude 2.5 or greate r between 1900 and the most recent update of the database in 201 6.

The results indicate the closest earthquake to the Site was 24 miles southwest with a magnitude of

3. 1 that occurred on March 18, 2012. Two earthquakes with magnitudes greater than 5.0 were recorded within 200 miles of the Site. An earthquake with magnitude 6.5 occurred on August 16, 1931, located 140 miles southwest of the Site; and an eaJthquake with magnitude 5.7 occurred on April 14, 1995, located 165 miles south of the Site. The Eunice earthquake of January 2, 1992, located 39 miles east of the Site had a magnitude of 4.6. The results of the USGS earthquake search are plotted on a regional map in Figure 2.6. l l .

There are three sei.smic source zones within a 200 mi.le radius of the Site: the northern and southern regions of the Southern Basin and Range - Rio Grande rift zone located west and southwest of the Site; and the Central Basin Platform zone located east of the Site. The most active seismic area within 200 miles of Site is the Central Basin Platform east of the Site. Large magnitude earthquakes are not occurring or have not occurred within the recent geologic past along the Central Basin platform due to the absence of Quaternary faults. The seismicity in west Texas, southeast of the Site, is hypothesized as be ing a result of fluid pressure build-up from fluid injection, and consequential reduction in effective stress across pre-existing fractures and associated decrease in frictional resistance to sliding. Similarly, recent records (1998 through 2005) from the WIPP seismic monitoring network indicate that the strongest events recorded annually in 1999, 2000, and 2002 through 2005 (typically of 2.5 to 4.0 magnitude during this time period) have been located about 50 miles west of the Site. This seismic activity is suspected to be induced by injection of waste water from natural gas production into deep well or wells [2. 1.3].

A review of the seismic risk was based on USGS Geologic Hazards Science Center's 2009 Earthquake Probability Mapping [2.6.4], which generates maps that show the probability of a magnitude 5.0 or higher earthquake within a 30-mile radius of any location within the next 50 years. On a scale of 0.00 (the lowest probability of earthquake) to 1.00 (the highest probabi lity),

all Proj ect facilities are withi n the low probability range of 0.01 to 0.02 as shown in Figure 2.6.12.

Earthquake probability is do minated by seismic activity within the Central Basin Platform south and east of the Site.

Probabilistic ground motion for the Site was determined using information from the USGS [2.6.5].

Figure 2.6.13 is a probabilistic ground motion map of the Site, illustrating peak horizontal Page 199 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOL'fEC PROPRIETARY INFORMAT ION acceleration with a 2 percent probability of exceedance in 50 years (2,500 year return interval).

The Peak Horizonta l Ground Acceleration (PGA) value of 0.04 of the acceleration due to gravity (g) to 0.06g estimated by the regional USGS algorithm is similar to values suggested by several site-specific studies for nearby locations. The Geological Characterization Report (GC R) for the WIPP Site [2.6.1] determined acceleration of :S0.06g for a return interval of 1,000 years, and :SO. l g for a return interval of 10,000 years (WIPP is located approximately 16 miles southwest of the Site); the results of the GC R were reviewed and confinned by Sanford et al. [2.6.5]), which estimated a maximum expected acceleration of O.l g for the WIPP, and again in the Safety Evaluation Report for the WIPP [2.6.6], which describes the GCR results as conservative. The seismic hazard for the Natio nal Enrichment Faci lity (NEF) uranium enrichment fac ility predicts 0.15g for a return interval of 10,000 years [2.6.2]. The NEF facility is about 38 miles southeast of the Site [2. 1.3].

Quaternary-age faulting (exhibiting movement in the past 1.6 million years) is not present in the vicinity of the Site. The nearest Quaternary-age fault is located 85 miles southwest of the Site

[2.6.7]. Little is known about this fault except that it is a normal fault, 3.6 miles in length, and has a slip rate of less than 0.01 in/yr. The Guadalupe fault forms a scarp on unconsolidated Quaternary deposits at the western base of the Guadalupe Mountains in the Basin and Range physiographic province. The same USGS database shows numerous other Quaternary-age faults within a 200-mile radius of the Site, located to the west and southwest, most of which are at the distal end of the radius and are near the Rio Grande Rift of central New Mexico. Figure 2.6.14 is a map of New Mexico and West Texas showing Quaternary-age faulting as cataloged by the USGS, and as down-loaded from the database referenced above. The database contains locations and information on faults and associated folds that have been active during the Quaternary.

In all, there are a total of 27 Quaternary faults or fault zones within a 200-mile radius of the Site.

A total of four "capable" faults were identified, the closest being the Guadalupe fault (85 miles to the southwest). A "capable" fault is one that has exhibited one or more of the following characteristics (10 CPR 100 [2.6.10] Appendix A.III, Definitions):

Movement at or near the ground surface at least once within the past 35,000 years or movement of a recurring nature within the past 500,000 years.

M acro-seismicity instrumentally dete1mined with records of sufficient precision to demonstrate a direct relationship with the fault.

A structural relationship to a capable fault according to the previous two characteristics such that movement o n one could be reasonably expected to be accompanied by movement on the other.

For the purposes of this assessment, capable faults were identified based solely upo n the first characteristic above.

2.6.3 Surface Faulting There are no surface faults at the Site. Tectonic activity in the Delaware Basin is characterized by slow uplift relative to surro unding areas which has resulted in erosion and dissolution of rocks in the Basin. Faulting has not occurred in the northern Delaware Basin in the area of the Site. The regiona l geology suggests that there have been no recent, dramatic changes in geologic processes and rates in the vicinity of the Site [2. 1.3].

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATIOM 2.6.4 Stability of Subsurface Materials The entire Site is underlain by Triassic bedrock consisting of shale, siltstone, and minor, fi ne-grained, poorly sorted sandstone. Most of the proposed operational area is relatively flat and the shale bedrock is covered by a laterally extensive veneer of 25 feet of Quaternary pediment deposits consisting of well sorted eoli an sand and sandy-gravelly materials near the bedrock inte rface. The Mescalero Caliche unit is near the surface and is about 10 feet thick at the Site.

Comparison of conditions at the Site with those conditions favorable to karst development indicates that conditions at the Site are not conducive to karst development. No thick sections of soluble rock are present at or near land surface; the shallowest soluble bedrock materials are gypsum and halite beds in the Rustler Formation, which is located at least 1,100 feet below land surface at the Site. Additionally, rainfall rates in the area are low. Mescalero caliche is soluble and situated at or near land surface; however this unit is no more than 10 feet in thickness. Local dissolution of this unit may have resulted in the development of a number of small shallow depressions in the area; however this is not regarded as an active or significant karst process at the Site [2.1.3].

During site reconnaissance, detailed inspection of the areas around the margins of Laguna Gatuna and tributary drai nages was performed to identify any tension cracks, disrupted soils, tilting, or other evidence of rapid earth displacement. No tension cracks or other evidence of dis placement was observed. Additionally, older cultural features in the area were inspected to identify evidence of tilting, offset, or displacement that could indicate recent land movement. A number of oil wells were drilled along the west flank of Laguna Gatuna beginning in the early l 940' s. Most of the wells were abandoned by 1975 and well monuments were installed; several of the well monuments were identified during site reconnaissance. None of the monuments displayed evidence of tilting that might be associated with local earth moveme nts [2. 1.3].

A halite preservation and stability assessment entitled, Report on Evaporite Stability in the Vicinity ofthe Proposed GNEP Site, Lea County, NM was performed for the Site as part of the GNEP siting study [2. 1.3]. This study was conducted in order assess existing data on the continuity and stability of evaporites under the Site, with special attention to data within, or adjacent to the boundaries of nearby lakes or playas. The main data sources for the project area include potash exploration drillholes and oil and gas drillholes.

Lithologic logs from potash exploration and geophysical logs from oil and gas exploration around the Site in southwestern Lea County, New Mexico, provide evidence of the extent and stability of evaporites and their possible relationship to the formation of playas in the vic inity.

An elevation map on the uppermost evaporite-bearing bed (top of Permian Rustler Formation) shows continuity across the area. General northeast slopes are revealed, with some flattened slopes associated with Laguna Plata. There are no indications of lowering of the surface by dissolution; the top of Rustler under most of Laguna Plata is actually elevated above the general trend. The surface varies locally due to variable reporting for potash drillholes of the first encounter with the uppermost sulfate bed of the Rustler.

There are no surface, drillhole, or mining indications that subsidence and collapse chimneys occur at the Site or surrounding area. These features are associated with the front of the Capitan reef, which is south of the Site, and with a hydraulic environme nt that is not known to ex ist a t the Site.

Page 201 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATIOM Geophysical logs indicate that halite in the Rustler persists across the Site area. Dissolution from above to create lows on the uppermost Rustler is not a practical process. There is neither s ubsurface drillhole data nor surface features indicating a dissolution front in the vicinity of the Site. There is no evidence for either past or continuing natural processes that would cause Site instability due to halite dissolution in the near future [2.1.3].

With regard to potential future drilling on the Site, Holtec has an agreement [2.6.9] with Intrepid Mining LLC (Intrepid) such that Holtec controls the mineral rights on the Site and Intrepid will not conduct any potash mining on the Site. Additionally, any future oil drilling or fracking beneath the Site would occur at greater than 5,000 feet depth, which ensures there would be no subsidence concerns [2.1.8].

Based on the data from the borings and analyses, the soils at the site are not susceptible to liquefaction. The soils encountered at the site were evaluated for liquefaction potential usi ng the methods described in Youd, et al., 2001 [2.6.1 21 as prescribed by Regulatory Guide 1.198 [2.6.11 ].

Corrected N-values greater than 30 blows per foot are too dense to liquefy in an earthquake of any size, and are therefore classified as non-Iiquefiable. In addition, soils above the groundwater table are not susceptible to l iquefaction [2.6. 12].

2.6.5 Slope Stability The site terrain ranges in elevation from 3,520 to 3,540 feet above mean sea-level sloping gently downward from south to north. Most of the site is fl at with slopes ranging from Oto 3 percent, as shown in Figure 2.6.15. Therefore, there is no risk from slope instability (i.e. landslides) in the vicinity of the Site.

2.6.6 Construction Excavation During the construction of Phase 1 of the HI-STORE CISF, there will be multiple areas where excavation will be required to accommodate and install the underground faci lities; specifically, the Can ister Transfer Facilities (CTF) which are located in the Cask Transfer Building (CTB), and the UMAX field. ln both cases, the expected total excavation depth is approximately twenty-five (25) feet.

According to the geotechnical borings, there are two layers of subsurface material that will be encountered during construction excavations. The native caliche layer, which is approximately 12 feet in depth from top of existing grade, and the native residual soil layer, which makes up approximately 13 feet of depth for the remaining required excavation depth for site faci lities. In no instance is it expected that construction excavations wi ll encounter the native Chinle layer.

In order to accommodate construction veh icle access and industry wide safety standards, it is expected that construction practices will utilize a minimum 1: l slope around the extents of the excavation pits. This method will create - 124,000 cubic yards (CY) of caliche spoils and - 121,500 CY of residual soil spoils; some of which (-24,000 CY) w ill be utilized to backfill the excavation area. It should be noted that the residual soil layer will be utilized for the backfill material as it meets the minimum density and shear wave velocity requirements that are required for Space B, referenced in Figure 4. 3 .1.

Once the areas have been excavated, the supporting soil will be prepared to receive the reinforced concrete Support Foundation Pad (SFP). The residual soil surfaces shall be proofrolled b y a heavy vibrating compactor, prior to the placement of compacted fill or foundations. Careful observation Page 202 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMATIOM shall be made by a professional engineer licensed in New M exico or their approved representative during proof rolling in order to identify any areas of soft, yielding soils that may require over-excavatio n and replacement. Once the subsurface has been prepared and compacted, the supporting residual soil fill (Space C) shall be confirmed to have reached a compaction of 95 percent (minimum) of the modified Proctor maximum dry density (in accordance with ASTM D1557). The compaction s hould be conducted at or c lose to the op timum moisture content indicated by the mod ified Proctor test procedure (ASTM D 1557).

U po n completion of subgrade preparation/compaction, placement o f the reinforced concrete S upport Foundation Pad (SFP) and UMAX Cavity Enclos ure Containers (CECs), backfilling of Spaces A and B (Figure 4 .3. 1) will commence. Space A will consist of a Controlled Low Strength M aterial (CLSM) or lean concrete that has a minimum compressive strength and density of 1,000 psi and 120 pcf, respectively, as referenced in Table 4.3.3. S ince the backfilling process is iterative, as the fill materials are brought back up to finished grade, the sloped areas of the excavation pit that make up Space B of the UMAX lateral subgrade, will be composed of the aforementio ned residual soil. Again , it is expected that for Phase 1 of the HI-STORE CISF, and all subsequent phases, -24,000 CY of this residual soil will be required to fill out the Space B portion of the excavated area.

Page 203 of 689 Revision OC May 2018

ATTACHME NT 2 TO HOLT EC LETTE R 5025025 HOLTEC PROPR IETARY INFORMATION Table 2.6.1: Boring Exploration Data [2.1.24]

As-Drilled Coordin ates Borin g B orin g Ground S urface Dr illing, Sampl in g , and Dep th Purpose Number N orth ing (feet) E astin g (feet) E levation (feet ) Field Test N otes (1)

(feet)

Bulk Sampling, SPT, Rock 6101 571 ,880.4 731 ,795.0 3535.5 400.6 Characterize soil and rock for ISFSI Pad.

Corina. Packer T estina 8 101A 571 ,899.0 731 ,n9.8 NM 30.9 SPT Hammer energy measurement.

81018 571 ,906.7 731 ,791 .6 3535.1 4 14.4 Not sampled Installed monitoring well B101 (MW).

Bulk Sampling., SPT, Rock 8102 572,097.9 731 ,5852 3531 .7 112.0 Characterize soa and rock for ISFSI Pad.

Coring Installed inctinometer casing for crosshole seismic 8102A 572,088.4 731 ,581.4 3531 .4 107.9 Not sampled velocity tesling.

lnsta.lled inctinometer casing for crosshole seismic 8 103 572,091 .3 731 ,567.4 3531.2 107.6 Not sampled velocitv testinQ.

Installed inctinometer casing for crosshole seismic 8 104 572,094.6 731 ,552.0 3531 .6 107.8 Not sampled velor.itv testina.

Bulk Sampling, SPT, Rock 8105 571 ,879.9 731 ,356.8 3535.0 221.7 Characterize soil and rock for ISFSI Pad.

Coring, PackerTesting 8 105A 571 ,865.2 731 ,338.5 3534.9 30.4 SPT Hammer energy measurement.

SPT, Rock Coring, Packer 8106 572,280.0 731 ,356.3 3530.6 152.0 Characterize soa and rock for ISFSI Pad.

Testina 8106A 572,270.0 731 ,364.2 3531 .4 203.0 Not sampled lnsta.lled monitoring well B106(MW).

Bulk Sampling, SPT, Rock 8107 572,282.3 731 ,792.4 3529.6 102.0 Characterize soH and rock for ISFSI Pad.

Corinq, Packer Testinq 8107A 572,282.4 731 ,782.1 3530.0 107.5 Not sampled lnsta.lled monitoring well 8107(MW).

6 108 571 ,6602 731,344.9 3536.7 60.9 SPT Characterize soil for HHP.

Bulk Sampling, SPT, Rock 8 109 570,6812 730,n3.3 3539.6 102.0 Characterize soil and rock for CTB.

Corina PackerTestina Notes:

1. Modified California samples were collected as appropriate in SPT borings.

2. Northing and Easting are based on the Modified U.S. State Plane of 1983 (NAD83), New Mexico East Zone 3001 .

3. Elevations are based on the North American Vertical Dall.Im of 1988 (NAVD88).

4. "SPT' indicates Standard Penetration Test.

5. "NM" indicates not measured.

Page 204 of 689 Revision OC May 2 01 8

ATTACHMENT 2 TO HOLT EC LETTER 5025025 I IAI TFA PRAPR IFTARY l~JFARM ATIA~d Table 2.6.2: Soil Index Properties [2.1.24]

Samol* ld..-.tifi~lion !rw>>x Pr.,...niH Unit W.,...ht Grain Sin Tuts ~f'Defll Um_its Tuts Total Ory Boring S-.ple s~ Formation Watv Water G~*I Sand Fin.s Wattr Liquid Pl.ostic Pl.lsticity S1>1tcific W ater Unit Unit N umti.r Numb<< 0.pth Cont..-.1 Content Content Limit Limit lndu Gravity Content W.;ght W*ight 8 101 MCI 100 -

(ft) 11.0 Resldu.11Soil

'"I

- '"I- '")- '"l l"I

- '"'-- - - - - '"I 15.8 (ocfl (odl 8 101 ,~2 200 - 21.0 Resdu.a1Soil - - - - - - - - - 11 4 - -

BIOi 8 101 MC3 S11 30.0 35.0 .

- 30.4 Restdwil Sool JCl.8 Chlile 8.7 0.0 3.11 1111.4

-- -- -- -- -- 15.4 12&.4 IOIU BIOi 8 101 S13 S15 45.0 .

55.0 -

411.8 5cU Cnnle Clw\le 150 130 0.0 0.0

'411.8 35.2 53.2

!14.8 8 101 S1Q 75.0 . 76.2 CIW\le 10.'4 10.2 0.0 30.6 69.4 - 33 16 17 - - - -

8 101 8 101 S20 S22 80.0 .

IIOO .

81.3 111.4 CMJ.

Chink?

10.'4 108 14 2 0.0 00 111.4 2Q.3 BO.II 707 8 101 8 102 S23 GI 1150 .

0 .0 .

1111.8 10.0 Chir>le C.3.-:he 15.11 1311 00 42 1 57 II

- 5.0

- 40 NP 20 i.P 20 NP 2.({1 8 102 8 102 S 1315-17")

S14 30.0 350 .

. 32.0 JCl.3 Cnnie CIW\le 13.11 11g 8.6 0.0 27.11 72.4 2.78 8 102 S15 400 . 4 1.4 CIW\le 8.0 II.II 00 14 .7 85.3 - - - - - - -

8 102 S111 450 . 45.11 Chinle 14 .11 - - - - - - - - 2.81 - - -

8 105 MCI 100 . 11.0 CucN - - - - - - - - - - 111.0 - -

8 105 MC2 20.0 . 20.11 Resdu.al Soil - - - *- - - - - - - 10.3 - -

8 105 SQ 25.0 - 2&.8 Res~ISOIII 11.5 -- -- .. -- -- -- -- -- , 74 - - -

8 105 1,<<;3 40.0 . 4 1.0 Ch.nle - - - 15.8 124.2 107.3 8 105 8 105 S14 S15 50.0 .

55.0 .

51.4 56.4 CIW\le CIW\le 15.7 15.0

'2.11 0.0 48.8 5 1.2

-- -- -- -- 2.81 8 100 S5 10.0 . 12.0 ~ 12.7 130 4g.2 42.0 8.8 - 43 34 II - - - -

8 100 8 100 S7<~24"l sg 15.0 .

200 .

17.0 Rtildual Soil 21.11 RHldu.11 Soil 11.5 1111 10.7 g2 0.3 00 80.2 383 111.5 1117

-- 40 40 15 12 25 28 8 10&

8 10&

S10 S13 225 .

30.0 .

24.5 Resdu.31 Sod 31.1 Cn.nle 10.8 11.0 11.2 11.Q 0.0 0.0 55.11 34.3

44. 1 115.7

-- 41 40 1"'

18 27 22 8 107 8 107 GI S7 00 150 .

. 10.0 CucN 111.11 ReS<dual Soil 83 00 IIO I 311 II 10g NP 42

... p 20 NP 22 2.115 8 107 S13 30.0 . 3 2.0 Ct\lnle - 11 II 0.0 10.5 811.5 12.1 45 18 27 - - - -

8 107 8 107 S15 S17 400 .

50.0 .

42 .0 51.3 Chnle

~

-- 1011 13.3 00 0.0 318 42.7 118.2 57.3 Ill 5 14.11 41 40 20 21 21 111 8 109 MCI 10.0 - 11.0 c.xh<t - - - - - - - - - - 13.3 04.2 83.2 8 108 l.~2 40.0 . '40 .11 Chinle - - - -- - - - - - - 14.7 123.11 IDS 1 8 108

..~,

S14 45.0 . 47 .0 Cnnle 55 1"'. I o.o 47.0 53.0 - - - - - - - -

8 109 100 . 11.0 Caiche - - - -

- - - - - - 15.11 84.5 72.g Notes:

8 109 l.1C2 20.0 . 20.3 RHldu..11 Soil - - - - - - - - - 7.5 118.11 111.7 1 . * -

lndicaws test w.as not .ass,gr,ed or perfonned.

2. "NP" llldlc.1les the sample is nonplaslic.

3. TClUI Unu Weignt and Dry Um W egttts from modified c.3l:rnmi.: t ~ -

4 "ft" lndic.a:H ffft.

5. "pd' lncficalas pounds per cublC fool.

II MC : Modified cali'omi.a 5.aff'ple; S : St.nd.lrd SPT, G : BIA w,npi.

Page 205 of 689 Revision OC May 201 8

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATION Table 2.6.3: Rock Core Test Results [2.1.24]

Samole Iden m cat,on To tal Dry Unconfined Test Water Unit Unit Compressive St rain at Elastic Boring Sample Sample Depth Formation No. Content Weight Weight Strength Failure Modulus Number Number (ft)

(%) (pcf) (pcf) (ksf) (%) (ksf)

B107 C6 84.0 - 85.0 Chinle UC-1 15.2 126.5 109.8 17.4 0.75 161 2.727 B107 C6 84.0 - 85.0 Chinle UC-2 16.8 136.9 117.2 5.3 0.90 900 B107 C4 73.9 - 74.6 Chinle UC-3 15.4 137.8 119.5 25.7 0.80 4.545 B101 C28 226.3 - 226.7 Santa Rosa NA NM 159 NM 293 1.50 28.800 B101 C31 244.5 - 244.9 Santa Rosa NA NM 163 NM 938 0.45 227,500 B101 C39 283.4 - 283.8 Santa Rosa NA NM 160 NM 696 0.74 128,300 B101 C45 309.8 - 310.2 Santa Rosa NA NM 156 NM 699 0.62 95.040 B101 C48 324.5 - 325.9 Santa Rosa NA NM 163 NM 594 0.60 124,560 8 101 C55 360.7 - 361.4 Santa Rosa NA NM 157 NM 766 0.56 181,440 B101 C63 399.8 - 400.3 Santa Rosa NA NM 164 NM 1003 0.50 263.520 Notes:

1. "ft" Indicates feet.

2. "per' Indicates pounds per cubic foot.

3. "ksf' indicates kips per square foot

4. NM indicates not measured.

5. NA indicated not applicable.

6. Strain at failure for UC-1 adjusted to remove initial seating strain Page 206 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMAT ION Table 2.6.4: Shear Wave Velocities [2.1.24]

Measurement Shear Wave Depth Formation Elevation Velocity (ft) (ft) (ft/sec) 2 3529.4 1092 Caliche 5 3526.4 1057 Caliche 10 3521 .4 1019 Cafiche 15 3516.4 1087 Residual Soil 20 3511 .4 1906 Residual Soil 25 3506.4 1703 Residual Soil 30 3501.4 2005 Residual Soil 35 3496.4 1243 Chinle 40 3491.4 1500 Chinle 45 3486.4 1588 Chinle 50 3481.4 1637 Chinle 55 3476.4 2041 Chinle 60 3471.4 2274 Chinle 65 3466.4 2240 Chinle 70 3461.4 1867 Chinle 75 3456.4 1849 Chinle 80 3451.4 1831 Chinle 85 3446.4 1877 Chinle 90 3441.4 1812 Chinle 95 3436.4 2220 Chinle 100 3431.4 2539 Chinle 105 3426.4 2761 Chinle Note: Shear wave velocities were measured by crosshole testing at 8102A, 8103, and 8 104.

Page 207 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Table 2.6.5: Testing Deliverable and Reference in SAR and Geotechnical Report [2.1.24]

Deliverable Reference Lab Testing Procedures Table 2.6. 1. Boring Exploration Data No. and Locations of Borings Figure 2.1.8. Boring Location Plan Method of Sample Collection Table 2.6. l . Boring Exploration Data Section 3.2. In-Situ Soil Testing in GEI Report Types of Field & Lab Testing Section 4. 1. Geotechnical Laboratory Testing of Soil and Rock in GEI Report [2.1.24]

Soil Properties Grain Size Analysis in Attachment H in GEI Grain Size Classification Report [2.1. 24]

Table 2.6.2. Soil Index Properties Figure 2.6.9. Atterberg Limit Results Atterberg Limits Atterberg (Liquid and Plastic) Limits m Attachment H in GEI Report [2.1.24]

>-------------------+

Table 2.6.2. Soil Index Properties Table 2.6.3. Rock Core Test Results Water Content Water Content Measurement (Soil) m Attachment Hin GEI Report[2. l .241 f-------------------4 Table 2.6.2. Soil index Properties Table 2.6.3. Rock Core Test Results Unit Weight Unit Weigh of Soil in Attachment H in GEI Report f2. l.24]

Table 2.6.2. Soil index Properties Specific Gravity Specific Gravity Measurement in Attachment H in GEl Rep01t l2. l.24J

+

Particle Size Analysis in Attachment J in GEi Soil Classification Report in GEi Report [2. 1.24]

+--- Un con_fined Compression Test in Attachment I Shear Strength in GEI Report [2. l.24) 1-- - -

Table 2.6.2. Soil index Properties Shear lYoung's] Modulus Compressive Strength and Elastic Moduli of Rock in Attachment Kin GEi Report [2. 1.24]

Table 2.6.2. Soil Index Properties Poisson's Ratio Compressive Strength and Elastic Moduli of Rock in Attachment Kin GEi Report [2.1.241 Page 208 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY l~JFORMATION Figure 2.6.10. Shear Wave Velocities Seismic Wave Velocities Table 2.6.4. Shear Wave Ve locities Boring Logs in Attachment C in GEi Report Blow Count

[2. 1.24]

Groundwater Table 2.5.1. Groundwater Elevation Data from Groundwater El.

Monitoring Wells Page 209 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INEORM4T IOU IM 11!i ,.n 1) 1 I I

,.......11,1\,.............. a.-..

..... .... u...~

c..a...* , .... ..............,.* Uf'(.H,1111 NlilUl-.a tea.. Ml<<!t ....... l.. .

~

t

....,,.....~

A.4d il "'f"- '11*1ff

.......,. u,-.,. . .. v......,,*

H I c~-.u.1t

{

l'l ~~7('

\\ ,l' \ d

- --~-" - - -,.-- ..

Figure 2.6.1: Major Regional Geological Structures near the Site (2.1.3]

Page 210 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRleT/1.RY lf>lf=ORM.'\TIGN CISF SfTE a-ye.,-, ..

\,

HIO

.s {J .,1,,-

j

] ~ ---- {-;

/ ....

/ . ,,

C/SF SITE s.w.... *""~~ 10n RoJ"°IGocb~ Six;<<,< '111~.9

~ WIPPSITE A ....., T. ~!I.

R.~L ll.llE.

l..._Clll ll'Clb9k ..c9on Figure 2.6.2: Geologic Cross Section through the Capitan Reef Area, Eddy and Lea Counties, NM (2.1.3]

Page 211 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY l~IFORMATION Madll,-, Iran N I.I Ou..81.1 of c;.dqJy and Mn111rlh.. 2001 f *5!).QOQ) ~ 11¥ ol ,._,..Uwoo CISF Site

&pliJoat/Qo AJ ......... ~ - I I O ~

PIIIIICiCM',,tl L.-..vt'te -SPIit* dl!)cllica (h a - I r<J..ai l'IWH t el 1111 r1' ......, a (!'iC.0911 Ec.l,M\IVA pc<<:"U..C 4C,CQC:t

( HCIOCAIM l>ll'i:W'l*-J P---ORll'-"ttllld!laj)aa (Hdocw,*olowwPII I -)

0111*.UWA COCDIU (1'10!*

ll)l°"""Pltl_.*I ll'CLdet OacUIII Fon-'~ Gtl uu,etO,,.-f*Op \.ttdl,dtd

( ~ ~-CJ !Mc.all O.-.,u..,.,._~....,...-1 red *l'.ll*IINS J:ucr*

0 j

Figure 2.6.3: Surficial Geology in the Vicinity of the Site [2.1.3]

Page 212 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION CISF Site E4Sl o--,.ivrun t_,..

~

---=-~~--==::..:..::.:~-....--.......

~ , . . . .II;

,....-n.1.-.1. .......

---~*-- ............

~816 c.,,

Bas - - - - - - - - ---0as; *

?br'l'l Figure 2.6.4: Regional Surficial Geology a nd Generalized Cross Section Through the Site

[2.1.3]

Page 213 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025

"""190L'fEC PROPRIETARY INFORMAT ION

,S ystem Delawarn Basin Str:atlanaphy Pedime.nrs, Valley Flfls Upper Gatuna Fm.

.l,ow9J!' Gatima Formation THt:lary 09aJl'ala Doclcum G,oup Rustler FormatJon, Bell Canyon Formation z

II'(

!i a::

I.I.I D.

Brushy Canyon Fom,atlon Black Lime-st.one Beds Hueco/Abo*

Figure 2.6.5: Permian to Quaternary-aged Stratigraphy of the Delaware Basin [2.1.3]

Page 214 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATION 8~8 -

a I

a

..** I I

L

~DUA!.

....... _J 0:1 I

8

- .. :a>"

L OU W-. IIA 11e, r

... ..... """'~

&""11, l}ft,

-*.-.... -* ....~

te:IN, I* '

.t:n ,e,s

DI; ,. .

......-roRECIU Fr"..lll! 1

-c,,~

II

_--- GEI .__

--Lt-*C:...,C,_N_

~--*

Figure 2.6.6: Phase 1 Detailed Subsurface Profile A [2.1.24]

1-'""'='-"'=""'-t-- - - - - - - -- t Page 215 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HObTeC PROPRleT/1.RY ll'>IFORMATIOl'>I

- 8 G ..

Cl.~

.a I

,, ~

..*.. Cl,I.ICHI:

"'?" ]Lt f

I ti au-.*

/ 9U gJl,t L_

-...... _J 1

L---

1u , 1*

9 ...

I l,

c.....-u Qt

(..

l, i .. ........

'Z

..... nrr

.. iz

~

P. .....

--..... s 13Jll. ff :'"JI,

...,..,_- _,~,_

"9'-

a.<

- ~ "'"""',l"..t..

Q.'t. 1-I ffll

... ... - 11aoi.

~,118.

....INfll"S

- ~ ft a)'I.

11 12)1, _ ,.,,.

&AH'TAllt08A II

-- HtCTI)R£ c.aF Pl'aHO I LU ~O 1---.,.,.._,,..,..

c.._ _ ___,.

__ _ GEi

, _ _-i.~-------- - - - - -

Figure 2.6.7: Phase 1 Detailed Subsurface Profile B [2.1.24]

Page 216 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HAI TFC: P~APRIFTARY l~JFARMAT IAN 3560

............ n 2i TOP SOL

' j . -=~ _

211 J7 CAUCHE 42

= f--LII; r ._1 &I 121 47 I -j~

,m 100,4'

\

APPROXIMATE BOTTOM RESIDUAL ll!i 1008

'45

( ,/ IJG<lr 37 eo ea I la:JIT

,ma-ELEVAllOH OF CAHtSTBl Ml/Ir L ,,5 ___ 171

_J 100<T TRN<SFER Pr A~ CASX TRN<SFER !U.OING SOIL MO 101/V" - RESDJAL ~'(---

110 APPROXIMATE 1al!5" MOl10"

~ SOIL 100,;4-l(nl5"'

IIOTTOM aEVAllCN CJ:" l.MAX ISFSI I 3500 127- -

eo 70 3500

!6

~*

183110" I !

108 13$

CHINlE gs 111111r

,sz.,r CHIJ.LE Q Ill ICD5'"

150/10" ,o:1r !.

ti

...ti t$1,V- 1SVIO" UJ 347$

1al!5" IOO<T tln'5" M&1r ICD5'"

1.91110" 100/5" 347$

UJ

~ P,t'fmr, ~

~

178.7 93'< 73% on, ar. !Xi-~ ~ ~

...~ ~

llO'!,~

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Camden, t4ew ~ Prqed 17033-45 Decenmer 2017 F",g. 8 Figure 2.6.8: Phase 1 Detailed Subsurface Profile C [2.1.24]

Page 217 of 689 Revision OC May 201 8

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION 60

-* I/

0 6101 S19 ~~

,$/

7 50 -II t.6101 S23 x 6106S5 I /

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0 10 20 30 40 50 60 70 80 90 100 110 120 Liquid Limit HI-STORE CISF Phase 1 Site CharactenzabOn A TTER6ERG LIMITS RESUL TS Lea County. New MeXJCO Honec International GEi . <.or>\I ,,.nu.

Camden, New Jersey Project 1703345 December 2017 Fig. 9 Figure 2.6.9: Phase 1 Atterberg Limit Results [2.1.24]

Page 218 of 689 Revision OC May 201 8

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL'fEC PROPRIETARY INFORMAT ION Shear Wave Veloc1t1es 3540 8102 Stmbgmphy B. 3532 3!10 3520 B . 3518 3510 *

B . 3501 3500

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~ 3'4~0

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000 1500 2000 3000 Shear Wo*we Vekx:ity (feet/sec) 1 Stutar w~* WiOQ:les - . mtas.urttd by crosshote tesllllg at B102A. B103. and 8 104.

2. SH T.1bl* IHonhur w.1ve v91ocity measuremen:s HI-STORE CISF Phase 1 Srte Charactenzabon SHEAR WAVE VELOCITIES Le3 County, New Meiuco Holtec lntemationaJ Comden, New Jersey Prqect 1703345 December 2017 Fig. 1 Figure 2.6.10: Phase 1 Shear Wave Velocity Results [2.1.24]

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION

.\ ll11'1o I

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nrm Page 220 of 689 Revision OC May 2018

A TTACHM ENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY lf>lf=ORMATION U.S. Geological Survey 2009 PSHA Model Site: -103.71 d E 32.58 33' 30' 1.00 0.90 0.80 33' 00' - 0.60

- 0.50

- 0.40

- 0.30 0.25 0.20 0.15 32' 30' 0.12

- 0.10

- 0.08 0.06 0.04 0.03 0.02 32' 00' 0.01 0.00 OdNeti km 0 50 31 - 30' 0

-105' 30' -105' 00' -104' 30' -104* 00' -103' 30' -103' 00' -102' 30' -102* 00' Figure 2.6.12: Probability of earthquake with Magnitude greater than 5.0 within SO years and 30 miles of the site [2.6.4]

Page 221 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL'f~C PROPRIETARY l~lFORMAT IOl'>I 160 34 ' *----......,----.. . 1. .- ----..,...L-------- - 34*

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- 50 40 33* 30 20 18 16 14 12 32* 10 8

6

-tos* - 104* - 103* - 102*

I 4 2

0 Figure 2.6.13: Peak Ground Acceleration (percent of gravity) (2,500 year return interval)

[2.6.4]

Page 222 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEG PROPRIETARY lf>lf=ORM ATIOl'>I t'

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- - bfAT!OlllNfERNA.OONALOO~RY EOOY lEACNERC3Y Al.llANCE PROJECT l EACOONTY, NEW MEXICO a '"OJfCT LOCATION 0 100 M11..E RADIUS .a.REA 2tl~ t.a"'IIMMfll'wtO'e 8ttfJINIO ~c,,,, M1: *U !JS.-

~ 11* ~ _.,.,..,....

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.... ~ m ur,. ' h . , _....... 1ttJ1-..lr-\llt J,all',** ""' "'"' ~......., , , l,f';H "111,U...N~ If t Figure 2.6.14: Quaternary faults within 200-mile radius of the site [2.6.8]

Page 223 of 689 Revision OC May 2018

A TTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLT EG PROPRleTARY IMFORMATIQN TO *,ro_~i>_._____..._ _ro_

~,o ~II

~ - 1~

~'iilb:ll~OOi:@3~~~m>~~~~~~

Figure 2.6.15: Elevation Contours at the Site Page 224 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMAT IOM 2.7 SITE SPECIFIC DATA FOR THERMAL AND STRUCTURAL ANALYSES The site characterization effort, summarized in this chapter, enables a conservative set of parameters important to thermal and structural analyses to be established. These parameters are summarized in Table 2. 7 .1 a nd are used in Chapter 5 (Structural) and Chapter 6 (Thermal). The ambient temperature in Table 2. 7. l is based on the meteorological data for the site with a small margin added for conservatis m.

The 10,000-year return earthquake, adopted as the Desig n Basis Earthquake (DBE) for the HI-STORE facility, is bounded by the classical Reg. Guide 1.60 response spectmm with its ZPAs denoted in Table 2.7. 1. Likewise, the assumed bounding tornado missiles considered for the Site are based on the regulatory guidance and a national standard [2.7.1, 2.7.2]. These are the same missiles considered for the HI-STORM FW MPC Storage System in Docket 72- 1032 and the HI-STORM UMAX Canister Storage System in Docket 72-1040.

Page 225 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRleTARY ll'>IFORMATIOl'>I Table 2.7.1 SITE SPECIFIC DATA FOR THERMAL AND STRUCTURAL ANALYSIS Conservatively assumed Parameter value for analysis based on Comment site data Normal Ambient Temperature Bo unding Annual Average 62

(°F) at the Site Conservatively assumed to Normal Soil Temperature (°F) 62 be equal to the Normal Ambient Temperature This temperature is based on 3-day average ambient temperature defined by Off-Normal Ambient 91 evaluating local weather Temperature (°F) service records for the Lea County in which the Site is situated This temperature value is Extreme Accident Level the extreme maximum 108 Ambie nt Temperature (°F) ambient temperature recorded at the Site This temperature is based on 3-day average ambient temperature defined by Reference temperature for short 0 (min) and 91 (max) evaluating local weather term operations (°F) service records for the Lea County in which the Site is situated Extreme Minimum Ambient This temperature value is Temperature recorded in the See Table 2.3. 1 used in the stress analysis of region (°F) the site specific ancillaries Extreme Maximum Ambient This temperature value is Temperature recorded in the See Table 2.3. 1 used in the stress analysis of region (°F) the site specific ancillaries Site Elevation (feet above mean 3,520 (min) to 3,540 (max) sea level)

Design Basis Earthquake (DBE)

ZP As in the two horizontal (X See Table 4.3.3 and Y) and vertical (Z) directions Design Basis Missiles and their Data is bounding for the See Table 2.7 .2 incident velocity Contiguous United States Page 226 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION TABLE 2.7.2; TORNADO GENERA TED MISSILES Missile Description Mass (kg) Velocity (mph)

Automobile 1800 126 Rigid solid steel cylinder(8 125 126 in. diameter)

Solid sphere (1 in. diameter) 0.22 126 Page 227 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATIOM 2.8 SAFETY-RELEVANT ENVIRONMENTAL DETERMINATIONS The geotechnical information on the proposed HI-STORE CIS Facility presented in this chapter may be summarized in the following points:

The fac ility will be located in one of the most spar sely populated areas in the continental United States. The nearest population centers are the cities of Carlsbad (32 miles away) and Hobbs (34 miles away).

The topography of the land is relatively fl at lending to effective intrusion detection by camera surveillance.

T he water table is sufficiently below the bottom of the subterranean HI-STORM UMAX syste m to preclude the possibility of any ground water intrusion in the storage cavity spaces.

The land is fallow with limited vegetation to support cattle herds.

The annual rainfall is meager requiring a modest water drainage infrastructure.

The tornadic activity in the region is infrequent. The strength of the tornadoes is bounded by the national meteorological tomadic data which has been used to define the Design Basis Missi les for both the HI-STORM FW system and the HI-STORM UMAX system.

Therefore, the storage system's ability to wit hstand the site specific tornados is axiomatically satisfied.

There are no active volcanoes in the area.

The area has a stable tectonic plate profile. As a result, the 10,000 year-return earthquake for the site is quite modest and well below the range for which HI-STORM UMAX as licensed in Docket 72- 1040.

T here are no chemical plants in the area that would spew aggressive species into the environment. As a result, the ambient air is non-aggressive and a long service life of the stored stainless steel canisters can be predicted with confidence.

T here is no air force base or a major civilian airport in the vicinity of the site and the area is ostensibly not used for any aerial training exercises by the US military.

The local area has a well-developed rail road infrastructure. The length of additional rail spur required for the site in less than 10 miles.

By agreement with the applicable third parties, the oil drilling and phosphate extraction activities have been proscribed at and around the s ite.

The above considerations lead to the conclusion that the proposed Site is suitable for its intended purpose.

Page 228 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLT EG PROPRIETARY INFORMAT IOM 2.9 REGULATORY COMPLIANCE Pursuant to the guidance provided in NUREG-1567, the foregoing material in this Chapter provides:

1. A complete description of the Geography and Demography of the Site as mandated by 10 CFR 72.24, 72.90, 72.96, 72.98, and 72.100;

11. A complete identification and description of key characteristics of Nearby Facilities as mandated by 10 CFR 72.24, 72.40, 72.90, 72.94, 72.96, 72.98, 72.100, and 72.122; 111. A complete description of the Meteorology and Surface Hydrology of the Site as mandated by 10 CFR 72.24, 72.40, 72.90, 72.92, 72.98, and 72.122; 1v. A complete description of the Subsurface Hydrology of the Site as mandated by 10 CFR 72.24, 72.98, and 72.122;

v. A complete description of the Geology and Seismology of the Site as mandated by 10 CFR 72.24, 72.40, 72.90, 72.92, 72.98, 72. 102, and 72. 122; Therefore, it can be concluded that this SAR provides adequate description and safety assessment of the site which this ISFSI Facility is to be located, in accordance with 10 CFR 72.24(a).

Additionall y, it can be concluded that the proposed site complies with the criteria of 10 CFR 72 Subpart E, as required by 10 CFR 72.40(a)(2).

Page 229 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMAT ION CHAPTER 3: OPERA TIONS AT THE HI-STORE CIS FACILITY*

3.0 INTRODUCTION

This chapter describes the activities and operations antecedent to safely emplacing a loaded canister in the HI-STORM UMAX VVM at the HI-STORE CIS facility. Chapter 9 of the HI-STORM UMAX FSAR [1.0.6] and the HI-STORM FW FSAR [1.3.7) describe the operations carried out at a nuclear plant to implement on-site dry storage. While fuel loading operations are not a part of the activities at the HI-STORE CIS facility, a n informational description is provided herein for reference. As the narrative in this chapter explains, the systems and operations required to effectuate transfer of canisters to the HI-STORM UMAX at HI-STORE meet the intent of 10CFR72.122 in fu ll measure.

In particular, it is shown that the loading operations are characterized by a number of defense-in-depth measures, described in Chapter 4 and evaluated in Chapter 15, that are intended to preclude a handling accident or ALARA transgression. The defense-in-depth measures include:

All lifting and handling devices comply with ANSI 14.6 [1.2.4) with the added requirement that the weakening effect of temperature on the strength of the lifting device is included.

The standard lifting a nd handling devices, such as the Vertical Cask Transporter (VCT) comply with the added structural margin requirements set down in Chapter 4 of this SAR.

The VCT, a key piece of equipment in heavy load handling evolutions, is equipped with a redundant drop protection features.

The kinematic stability of the loaded equipment for every stability-vulnerable handling evolution under the site's Design Basis Ea1thquake (DBE) has been established by appropriate analysis.

All lifting and handling devices are designed to mafotain the CG of the lifted SSC aligned with the lift point at all times thus precluding an unstable lift.

Custom engineered shielding accessories are utilized to meet ALARA goals.

The gantry crane employed at the faci lity is designed to be single fai lure proof in compliance with ASME NOG- 1 [3.0.1].

All operations will be performed in accordance with written and QA validated procedures.

The HI-STORE CIS facility is a "start clean, stay clean" facility. This means the arriving package from the sender plant site has been assayed and declared to be free of any external contamination.

All references are placed within square brackets in this report and arc compiled in Chapter 19 in this report.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY l~lFORMATION

The HI-STORE facility is a zero effluent site; no liquid or gaseous effluents are a pa.it of any operation at the facility.

Even though not required to maintain stability during the site' s DBE, the HI-TRAC CS transfer cask is secured by anchor bolts during all operations involving transfer of the loaded canister.

The information presented i n this chapter along with the technical basis of the system design described in the canister's FSAR in its host 10CFR72 docket will be used to develop detailed operating procedures. In prepat'ing the procedures, the conditions of the license and technical specifications, equipment-specific operating instructions, as well as the information in this chapter will be utilized to ensure that the short-term operations shall be carried out with utmost safety and ALARA.

The following generic criteria shall be used to determine whether the operating procedures developed pursuant to the guidance in this chapter are acceptable for use:

All heavy load handling instructions are in keeping with the guidance in industry standards and Holtec's Rigging Manual.

The procedures are in conformance with this SAR and its CoC.

The procedures are in conformance with the canister's native FSAR (HI-STORM FW System FSAR for MPC-89 and MPC-37) [l.3.7).

The operational steps are ALARA.

T he procedures contain provisions for documenting successful execution of all safety significant steps for archival reference.

Procedures contain provisions for classroom and hands-on training and for a Holtec-approved personnel qualification process to ensure that all operations personnel are adequately trained.

The procedures are sufficiently detailed and artic ulated to enable craft labor to execute them in literal compliance with their content.

Written procedures are required to be developed or modified to account for such items as handling and storage of systems, structures and components (SSCs) identified as impo1tant-to-safety, heavy load handling, specialized instrument calibration, special nuclear material accountability, fuel handling procedures, training, equipment, and process qualifications. The HI-STORE CIS facility management organization shall implement controls to ensure that all critical set points (e.g., Lift Weights) do not exceed the design limit of the specific equipment.

Control of the operation shall be performed in accordance with Holtec's Quality Assurance (QA) program to ensure critical ste ps are not overlooked and the canister has been confirmed to meet all requirements of the license before being released for on-site storage under 10CFR72.

The organization of the material and contents in th is chapter foll ows the guidelines of NUREG-1567 [1.0.3).

Page 231 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HObTeC PROPRleT/1.RY ll'>IFORMATIOl'>I

3.1 DESCRIPTION

OF OPERATIONS Operations related to the loading and closure of the canisters of spent fuel to be stored at HI-STORE are performed at the originating nuclear power plant. Spent fuel operations at the originating power plant are performed in accordance with the originating plant Owner's 10CFR50 license, any 10CFR72 site-specific and generic licenses, as well as the Technical Specification of the storage system. Transport of the spent fuel from the plant to HI-STORE is performed in accordance with the requirements of 10CFR7 l [1.3.2] and 49CFR1 7 1, 172, 173, 174, and 177 [3. 1.2, 3. 1.3, 10.3.1, 3. 1.4, 3. 1.5]. The HI-STORE facil ity will be designed to receive fuel from any licensed canister-based transportation cask. Storage of the spent fuel at HI-STORE is subject to the requirements of the HI-STORE CIS facility license issued pursuant to the regulations of 10CFR72. Compliance with 10CFR72 regulations [1.0.5] begins when the transportation cask enters the Cask Transfer Building (CTB).

The operations that are performed at HI-STORE include the following:

Receipt and inspectio n of incoming transportation casks with canisters containing spent nuclear fuel.

Transfer of canisters from transportation cask to the HI-TRAC CS transfer cask in the Canister Transfer Facility (CTF).

Transfer of the HI-TRAC CS to the HI-STORM UMAX at the subterranean ISFSI.

Surveillance of HI-STORM UMAX system.

Security of HI-STORE.

Health Physics at HI-STORE.

Maintenance at HI-STORE.

Removal of canisters from HI-STORE.

Inventory documentation management.

Principal operations at the HI-STORE CIS facility involve activities pertaining to handling, transfer and placement of canisters in the facility's VVMs. Future removal of canisters for off-site shipment will involve the reverse of the loading operations. During storage at the HI-STORE fac ility, several supporting activities are required including monitoring of the storage systems and periodic mainte nance of onsite equipment. Holtec International will implement detailed procedures for operating, inspecting, and testing the HI-STORE CIS facility SSCs in accordance with configuration-controlled written procedures similar to the ones employed at its existing user's ISFSis. These procedures will ensure that the spent fuel handling and storage operations are in accordance with the HI-STORE SAR and the Company's Nuclear Safety and QA programs.

The fo llowing description provides an overview of the operational process for the spent fuel storage fac ility systems. Detailed step-by-step operations are descri bed in Chapter 10.

Page 232 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY llqfiORMA'f'IOlq 3.1.1 Operations at Originating Nuclear Power Plant The spent fuel operations at the originating nuclear powe r plant and the transpo1t of the loaded canisters to the HI-STORE facility are not a part of HI-STORE operations. The description provided in this subsection is for information only; for a detailed description the reader should consult the canister's host FSAR such as HI-STORM UMAX FSAR (1.0.6).

Typically, an empty canister is placed inside a transfer cask. The canister and transfer cask are placed into the spent fuel pool where the canister is loaded with spent fuel. T he canister exterior is prevented from direct contact with potentially contaminated spent fuel pool water by means of a slightly-pressurized clean water annulus with an inflatable top seal. Once the fuel is loaded, the canister lid is placed on the canister and the transfer cask is removed from the spent fuel pool. The canister lid is seal welded to the canister and the canister is drained and dried. The canister is then backfilled wi th inert helium gas and the drain and fill ports are welded closed and leak tested. The closure ring is installed and seal welded, thereby sealing the canister. The outer surfaces of the transfer cask and the accessible areas of the canister are then checked for surface contamination and decontaminated, if necessary.

Most sealed canisters are placed in dry storage at the nuclear power plant.

At the time of transport, the sealed canister is recovered from storage into the transfer cask and placed in a transportation cask. The transportation cask, containing the loaded canister, is sealed using a bolted top closure lid. The transportation cask annulus is evacuated and backfilled with helium. The closure lid seals are leak tested and the transportation cask is placed horizontally on a transport frame secured to a transport vehicle. The transportation cask is fitted with impact li miters, tie-downs and a personnel batTier to protect person nel from coming in direct contact with the cask body. The transportation cask is then shipped to HI-STORE.

3.1.2 Operations Between the Originating Nuclear Power Plant and HI-STORE The HI-STORE facility is designed to receive spent fue l waste packages shipped by rail car.

Prior to shipment, the originating nuclear power plant must verify that cask storage document packages are included with the transportation cask. These document packages should contain information such as the cask's CCRs, any 10CFR72.48 documentation, aging ma nagement records and documentation of the fuel contents of the cask. These document packages will be checked once again when the cask arrives at the HI-STORE site. During transportation, the transportation cask provides a part 71-compliant containment for the canister that is qualified to withstand all applicable licensing basis accidents (10CFR71.73). The package (transportation cask and impact limiters) is licensed in accordance with the requirements of 10CFR7 l ,

"Packaging and Transportation of Radioactive Material", and complies with the requirements of 49CFR1 71 , "General Information, Regulations, and Definitions", 49CFR172, "Hazardous Materials Tables and Hazardous Materials Communications Regulations", 49CFR173, "Shippers

- General Requirements for Shipments and Packages", 49CFR1 74, "Carriage by Rail", and 49CFR177, "Carriage by Pub lic Highway" [3.1.2, 3. 1.3, 10.3.1 , 3.1.4, 3. l.5].

3.1.3 Operations Between the Railroad Mainline and HI-STORE To reach the HI-STORE site, the transportation rail car is transferred to a newly consu*ucted rail spur located along State Highway 243, where the transportation casks remain on the rai l car and are transported approximately 5 miles east to the HI-STORE CIS facility.

Page 233 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY llqfiORMATIOlq 3.1.4 Operations at HI-STORE This section provides a summary overview of the canister hand ling and normal storage operations at HI-STORE CIS facility. A more detailed description is provided in Chapter 10.

Radiation exposure to facility workers and the general public will be maintained as low as reasonably achievable (ALARA) during all operations in accordance with the facility's radiation protection program described in Chapter 11. Table 11.3.1 of Chapter 11 provides detailed estimates of expected durations and dose to facility workers for all canister handling operations.

3.1.4.1 Receipt and Inspection of Incoming Transportation Cask and Canister During spent fuel transportation, the sealed canister is contained within the transportation cask, which is mounted horizontal1y on a rail car or heavy haul trailer. Impact limiters are mounted on both ends of the transportation cask and a personnel barrier covers the transportation cask between the impact limiters. A tie-down secures the cask to the transport vehicle. Figure 3.1.1 pictorially illustrates the cask handling operations.

When the transportation cask arrives at the HI-STORE CIS facility, the transportation cask is visually inspected for any outward indications of damage or degradation prior to entry into the Protected Area (PA). Canister records are reviewed to certify that the canister meets the material considerations of Chapter 17 and the receipt inspection requirements of Chapter 9 to ensure the canister continues to meet the no-credible-leakage criteria to which it has been certified in the HI-STORM UMAX docket f l.0.6]. Additionally, a review of the transportation documentation package, which includes verification that a pre-shipment inspection was performed and acceptable, is mandatory prior to receiving a transportation cask into the security vehicle trap.

After initial receipt approval, the cask is moved into the security vehicle trap for physical inspection by security personnel to ensure no unauthorized devices or materials ente r the PA.

When security clearance is complete, the shipment proceeds into the PA and into the CTB (Figure 3. 1.2) where the personnel banier and tie-down are removed. The transportation cask, in accordance with the Part 7 1 requirements, is surveyed for dose rates and contamination levels.

The dose rate from the cask on arrival at the HI-STORE CIS facility must be in reasonable accord with the measured dose rate at the originating plant. An excessive discrepancy would warrant a root cause evaluation under Holtec's quality program and appropriate notification to the USNRC.

3.1.4.2 Transfer of Canister from Transportation Cask to HI-TRAC CS The steps for transferring the sealed canister from the transportation cask to the HI-TRAC CS all occur within the CTB. Using the CTB crane, the transportation cask is lifted from the rail car horizontally and placed onto a tilt frame suitable for the transportation cask being handled. The tilt frame fully supports the cask in the horizontal orientation and allows for cask tilting between the vertical and horizontal orientations. With the transportation cask in the horizontal orientation (fully supported by the tilt frame), the impact limiters are removed and placed aside. The transportation cask closure lid penetration cover is removed and the annu lus gas is sampled to confirm the continued effectiveness of the canister's confinement barrier. Following successful testing of the annulus gas, a canister leakage test is performed. The transportation cask is then tilted to vertical, lifted from the tilting frame and placed in the Canister Transfer Facility (CTF).

An alignment plate is used to concentrically align the HI-TRAC CS to the transportation cask.

Page 234 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 rtOL'fEC PROPRIETARY INFORMATION The alignment plate provides shielding to personnel performing the canister transfer and allows access for examination of the canister exterior shell surface.

After the cask is installed in the CTF, the closure lid is removed and a cask seal surface protector is installed on the transportation cask's closure lid seal surface to protect it from da mage. If necessary, any canister shipping spacers are removed. W ith the canister lid exposed, a contamination survey is taken on the accessible areas of the canister lid to verify that the canister is free of removable contamination. The MPC lifting attachment is then connected to the lid.

Temporary shielding may be positioned as required to maintain worker dose ALARA.

The HI-TRAC CS is then placed on the CTF alignment plate with its bottom doors open. The CTF anchor studs are secured to the HI-TRAC CS bottom flange to assure the cask 's seismic stability during the canister transfer process. The MPC lifting device extension is attached to the overhead crane, lowered through the HI-TRAC CS body using the CTB crane, and connected to the MPC lift attachment. The MPC is lifted into the HI-TRAC CS and the HI-TRAC CS shield gates are closed. With the canister is resting on the shield gates, the MPC lifting device extension is disconnected from the MPC lift attachment. T he loaded HI-TRAC CS is then lifted and placed at a location on the floor that is readily accessible to the VCT. It is at this time that the HI-TRAC CS will be surveyed for dose measurements.

3.1.4.3 Placement of the Canisters into the Vertical Ventilated Modules (VVMs)

The HI-TRAC CS loading is now complete and ready for transport to the designated HI-STORM UMAX VVM on the storage pad. In preparation for receiving the loaded canister, the designated VVM's CEC lid is removed and the Divider Shell is installed in the CEC. The VCT lifts the HI-TRAC CS and moves it out of the CTB. The cask is then moved to the appropriate HI-STORM UMAX location by the VCT. The HI-TRAC CS is positioned and lowered onto the ISFSI pad over the CEC to be loaded. Once it is lowered on the pad, the HI-TRAC CS is secured to the CEC in similar ma nner as at the CTF. The VCT releases from the HI-TRAC CS lifting trunnions and raises the top lift beam. The MPC lifting device extension connects the MPC lift attachment to the VCT through the VCT's top lift beam. The VCT's top lift beam is raised to tension the canister lift slings and raise the canister slightly. The HI-TRAC CS shield gates are opened and the VCTs top lift beam is lowered to lower the canister into the CEC. This continues until the canister is fully seated in the CEC. The MPC lift device extension releases from the VCT's top lift beam. The VCT reconnects to the HI-TRAC CS lifting trunnions. The HI-TRAC CS shield gates are closed and the securing anchor studs and nuts a.re removed. HI-TRAC CS is lifted and removed from the HI-STORM UMAX location. The MPC lift attachment is unbolted from the canister lid and removed from the CEC. If necessary, the CEC-to-lid seals are installed and the HI-STORM UMAX Closure Lid is installed. The lid rigging is removed and the CEC lid vent screen is installed. Once the rigging is removed and the closure lid is installed, the VVM will be surveyed for dose measurements.

3.1.4.4 Surveillance of the HI-STORM UMAX Storage Systems While in storage, the proper monitoring of the HI-STORM UMAX storage systems is subject to surveillance guided by written procedures. The temperature of the exiting air from the VVMs provides a telltale indication of compliance with the Technical Specifications. In addition, the cask air vent covers are visually inspected for blockages. An overall site observation Page 235 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOL'fEC PROFR:IE'fAR:'1' INFORMATION surveillance is also performed on a periodic basis to monitor for adverse conditions such as the accumulation of site debris around the air vents, tearing of the vent screens and the like .

Dose rates associated with individual storage systems are measured. This is to ensure adequate shielding of the canister so that radiation exposure to the general public is minimized and occupational doses to personnel working in the vicinity of the storage casks are maintained ALARA. Radiation doses emitted from the storage casks are measured by thermoluminescent dosimeters (TLDs) located at the protected area (PA) and owner controlled area (OCA) boundaries to ensure doses are within 10CFR20. l301 and 10CFR72.104 or 40CFR19 l limits.

3.1.4.5 Security Operations Security personnel coordinate security related functions that include performing continual surveillance for intruders, responding to intrusion alarms, processing visitors and workers to HI-STORE, searching packages and vehicles, issuing badges to workers, coordinating with local law enforcement agencies, and coordination with appropriate site and off-site emergency response personnel. Security personnel are also responsible for identifying and assessing off-normal and emergency events during off-shift hours of HI-STORE operation. Details for the security personnel are discussed in the HI-STORE Physical Security Plan [3.1.1].

3.1.4.6 Health Physics Operations The health physics (HP) personnel are responsible for measuring, monitoring and recording aH radiological aspects of the HI-STORE facil ity. These include: taking radiation dose and contamination surveys on incoming spent fuel shipments, monitoring individual radiological exposure, issuing, monitoring and maintaining personnel dosimetry, evaluating off-site radiological conditions, placarding and establishing radiological working conditions, reporting on radiological conditions to appropriate authorities and maintenance of radiological survey equipment. In order to uphold the HI-STORE philosophy of "Start Clean/Stay C lean" HP personnel ensure that contamination levels on the canis ters of incoming shipments meet site requirements. Canisters exceeding the limits will be returned to the originating power plant for dispositioning.

During the transfer process, HP personnel monitor doses to ensure that workers are not exposed to unnecessary radiation. In the event high dose rates are detected, temporary shielding, in the form of lead blankets, neutron shielding, portable shield walls, etc., are used to maintain ALARA. HP Personnel perform dose rate surveillances of the loaded storage cask to ensure requirements are met.

In addition to surveillance activities, the HP department monitors onsite and offsite radiation levels to ensure worker and offsite doses are in accordance with regulatory requirements. The HP department is also responsible for calibrating radiation protection instrumentation.

3.1.4.7 Maintenance Operations Because of their passive nature, the HI-STORM UMAX storage system requires little maintenance over the lifetime of HI-STORE. Typical maintenance tasks may involve occasional replacement and recalibration of temperature monitoring instrumentation, repair of coatings, repair of damaged screens, and general removal of dirt and debris.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL'fEC PROPRIETARY l~lFORMATIOl'>I Periodic maintenance is required on the overhead bridge crane, service cranes, transfer equipment, HI-TRAC CS and transportation casks. Maintenance of SSCs, which are classified as important-to-safety, ensure that they are safe and reliable throughout the life of HI-STORE per 10CFR72.1 22(t). Work on these items will only occur when the equipment being maintained is in the unloaded condition.

Maintenance may also be required on the following components: the heavy haul tractor/trailer (if used), rail car and locomotive (if used), cask transporter, security systems, temperature and radiation monitoring systems, diesel generator, electrical systems, fire protection systems, building HVAC and site infrastructure. The CTB and Storage Building provide the facility to perform maintenance activities. Vehicles may be moved off-site to specialized facilities that are better suited to perform such activities.

Full details of the maintenance requirements are given in Chapter 10. Additional information on the Aging Management of HI-STORE SSCs can be found in Chapter 18.

3.1.4.8 Transfer of Canisters from HI-STORE Offsite The HI-STORE CIS fac ility is an interim storage facility. At some point in the future, canisters may be required to be moved offsite. When such a day arrives, a 10CFR71 licensed transportation cask will transport the canisters offsite to another facility. Transfer operations will utilize the CTB to transfer the canisters from HI-TRAC CS to the transportation casks. Once loaded in a transportation cask, the spent fuel canister will be shipped to the designated facility.

To accomplish this, the steps for installing the canister in the VVM are basically reversed, resulting in a loaded transportation cask ready for transport.

3.1.4.9 Sequence of Operations Diagrams illustrating the sequence of operations for canister receipt, transfer, and placement into storage is shown in Figure 3. 1.1 for the HI-STORM UMAX storage system.

The number of personnel and the time required for the various operations are provided in Table 11.3.1 . This table is used to develop the occupational exposures discussed in Chapter 11.

3.1.5 Identification of Subjects for Safety Analysis 3.1.5.1 Criticality Prevention Only canisters that have been determined to have no credible leakage shall be stored at the HI-STORE CIS facility. The determination that the canister's confi nement boundary is intact and effecti ve to prevent intrusion of any fluids including water is performed at both the plant of origin and upon its arrival at HI-STORE. Thus, while the canister is qualified to remain subcritical even in the presence of water by virtue of its fix ed basket geometry and fi xed neutron absorbers installed in the canister's Fuel Basket, the guaranteed absence of water inside the canister at the HI-STORE CIS facility makes any loss of criticality safety non-credible.

Therefore, no additional criticality prevention measures are needed.

3.1.5.2 Chemical Safety The HI-STORE CIS facility does not use any chemicals (even water) in its canister handling and storage operations. Therefore, there are no chemical hazards associated with the operation of HI-STORE CIS facility.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY l~IFGRMATIObl 3.1.5.3 Operation Shutdown Modes During storage, there are no operational shutdown modes associated with the HI-STORM UMAX Storage System since the system is passive and relies on natural air circulation for cooling. During canister transfer, the transfer process may be shut down at the end of the day, resuming again on a following day. A discontinuance in the transfer operation is permitted only if:

All SSCs are in a mechanically secured state,

No nuclear components are in the lifted condition

The ventilation fl ow of air around the canister is uninhibited, and

The radiation dose around the cask and canister is ALARA.

In summary, all operational shutdown modes at HI-STORE are safe shutdown modes due to the design features of the faci lity and operational controls imposed through operating procedures.

3.1.5.4 Instrumentation Due to the totally passive nature of the storage casks, there is no need for any instrumentation to perform safety functions. Temperature monitors are utilized as a means to monitor the cask temperature during storage. Area radiation monitors are used to measure radiation levels in the CTB during canister transfer operations. Portable radiation monitors are used to measure radiation levels during the canister transfer process. HI-STORE operators are equipped with personnel dosimeters whenever they are in the PA. The radiation dose will be monitored at the perimeters of the PA and OCA. Pursuant to the criteria in NUREG/CR-6407 [l.2.2], the temperature and radiation monitors are classified as Not-Important-to-Safety.

3.1.5.5 Maintenance Techniques Maintenance operations on the equipment and systems don't involve any special techniques that would require a safety analysis.

Preventative maintenance is performed on a regular basis on the overhead transfer crane, canister lifting equipment, cask transporter, heavy haul tractor/trailers, radiation detection and monitoring equipment, cask temperature monitoring equipment, security equipment, fire detection and suppression equipment, etc. Maintenance is performed in accordance with 10CFR72.122(f),

ANSI N l 4.6 [l.2.4], and manufacturer's requirements.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY l~lFORMAT ION

a. Trans1>ortation cask is received and b. Lifting equipment is installed and inspected at the Cask Transfer Building; transportation cask is removed from the personnel barrier and transportation tie-down transport vehicle are removed

c. Transportation cask is moved and placed in the tilt frame d. Impact limiters are removed from the transportation cask Figure 3.1.1: Cask Handling Summary Illustrations Page 239 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PR:OPRIETAR't INFO~MATIOr:J

e. Canister is tested for integrity f. Canister bolts are remo ved

h. Transportation cask is placed in the

g. Lift yoke is attached and transportation CTF cask is tilted to ve rtical Figure 3.1.1: Cask Handling Summary Illustrations (Continued)

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION

i. Closure lid is removed; seal surface j. HI-TRAC CS is placed over CTF protector, CTF alignment plate and MPC Lift Attachment are installed I. Canister is raised into HI-TRAC CS

k. MPC Lifting Device Extension is attached to MPC Lift Attachment Figure 3.1.1: Cask Handling Summary Illustrations (Continued)

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC F'~OF'~IETAFH INFO~MATIOI~

m. Shield gates are closed and HI-TRAC CS is n. HI-TRAC CS is placed for transfer to VCT removed from over the CTF

p. CEC lid is removed and divider shell is

o. VCT engages HI-TRAC CS installed Figure 3.1.1: Cask Handling Summary Illustrations (Continued)

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PR:OPR:IETAR:Y IMFORMATIOM

q. HI-TRAC CS is brought to the CEC r. HI-TRAC is placed on CEC and MPC lifting attachments are connected to the VCT

\

t. Canister is fully lowered into the CEC

s. HI-TRAC shield gates arc opened Figure 3.1.1: Cask Handling Summary Illustrations (Continued)

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY llqfiORMATIOlq

v. Shield gates arc closed and HJ.

TRAC CS is removed from the CEC

u. MPC lifting extension disconnected and raised

w. MPC lifting attachment removed x. HI-STORM UMAX Lid installed Figure 3.1.1: Cask Handling Summary Illustrations (Continued)

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRli!TARY INFORMAIIQN (b)(4)

Figure 3.1.2: Cask Transfer Building (CTB) General Layout Page 245 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORM ATION 3.2 SPENT FUEL AND HIGH-LEVEL WASTE HANDLING SYSTEMS 3.2.1 Spent Fuel Canister Receipt, Handling, and Transfer An operational description of the systems used for the receipt and transfer of spent fuel canisters is provided in the foll owing paragraphs. Special features of these systems to ensure safe handling of the spent fuel canisters are also described.

3.2.1.1 Spent Fuel Canister Receipt 3.2. 1.1.1 Functional Description The transportation casks and impact limiters comprise the system in which the spent nuclear fuel canisters are contained when they arrive at HI-STORE. The transportation cask system protects the enclosed spent fuel canister from physical damage, provides shielding, and allows sufficient cooling of the canister while in transit to HI-STORE.

3.2.1.1.2 Safety Features Safety features of the transport system include the impact limiters, which help protect the spent fuel inside the transportation cask during transportation. F urthermore, the design features of the transportation cask, which provides gamma and neutron shielding, conductive and radiant cooling, criticality control, and structural strength to protect the spent fuel canister. A tamper-proof device on the cask provides indication of an unauthorized attempt to obtain access to the cask. These safety features are full y described in the HI-STAR transportation cask SAR [1.3.6].

3.2.1.2 Spent Fuel Canister Handling 3.2.1.2. 1 Functional Description The cask handling crane performs handling fun ctions inside the CTB for the transportation cask and the HI-TRAC CS. The MPC lift attachment and MPC lifting device extension connect to the overhead crane for MPC lifting and lowering in the CTB.

Cask handling components include the transportation cask and transfer cask, transport cask horizontal lift beam, lift yokes, ti lt frame, VCT, cask handling crane and HI-TRAC CS lift links.

The HI-TRAC CS lift links connect the VCT to the HI-TRAC CS lifting trunnions.

The canister handling components consist of the MPC lift attachment and MPC lifting device extension.

3.2.1.2.2 Safety Features Safety features of the cask handling crane include single-failure-proof designs for preventing uncontrolled lowering of the load upon failure of any single component, limit switches for prevention of hook travel beyond safe operating positions, and provisions for lowering a load in the event of an overload trip. The crane is classified as ASME NOG- 1 Type 1 [3.0.1]. A Type 1 crane is defined as a crane that is designed and constructed to remain in place and support a critical load during and after a seismic event and has single-failure proof features such that any credible fai lure of a single component will not result in the loss of capability to stop and/or hold the critical load. Design requirements for the crane include testing, inspection, and maintenance activities in accordance with 10CFR72. 122(t) which, are also performed per the QA Program Page 246 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION described in Chapter 12. Strict adherence to the design , testing, inspection, and ma intenance criteria as noted above ensure adequate safety margins are provided to prevent damage to the transportation cask, canister, or storage cask during normal, off-normal, and accident conditions.

Discussion on design criteria and the subsequent evaluations for these SSCs are found in Chapters 4 and 5, respectively. The crane design include limit switches for prevention of gantry, trolley, and hook travel beyond safe operating positions, limits on gantry, trolley, and hook travel speeds, and provisions for lowering a load in the event of an overload trip. Periodic inspection and testing will be performed to keep the cranes certified to ASME NOG-1 [3.0. 1].

Safety features of the HI-TRAC CS handling components include single-failure-proof lift capacity or equivalent safety factor as described in this SAR.

The loaded HI-TRAC CS is restrained during all aspects of canister handling either by the VCT and/or the anchor studs or by the wide base of the HI-TRAC CS during switching from the cask handling crane to the VCT. Evaluation shows that the HI-TRAC CS cannot topple over during an earthquake.

Safety features associated with the VCT include redundant drop protection systems designed to withstand drops that could result from a failure associated with the transporter lift components.

The transporter is des igned with hydraulic counter-balance valves and anti-drop mechanical locking mechanisms which automatically engage on the loss of hydraulic pressure. Markings on the lift boom and an indictor on the operating console gi ve indication of the lifted height. HI-TRAC CS lifting attachments are designed and tested in accordance with ANSI N 14.6 [( 1.2.4].

The safety features of the canister handling components, slings and MPC lifting attachments, are their redundancy and the req uired enhanced stress safety margins as described in the HI-STORM UMAX FSAR [1.0.6].

3.2.1.3 Spent Fuel Canister Transfer 3.2. 1.3. 1 Functional Description The HI-TRAC CS is used for transfer of the spent fuel canister between the transportation cask and the CEC. The HI-TRAC CS protects the spent fuel canister from physical damage and provides radiation shielding to personnel.

3.2.1.3.2 Safety Features The HI-TRAC CS provides radiation shielding when carrying a canister loaded with spent fuel.

The HI-TRAC CS lifting trunnions are designed to the single-failure proof requirements of NUREG-0612 [1.2.7] so that a load drop event involving the HI-TRAC CS is non-credible.

As described in Subsection 1.2.4, the HI-TRAC CS consists of a radially-connected pair of concentric steel shells filled with high density concrete. Two lifting trunnions and two rotation trunnions are provided for HI-TRAC CS handling. The HI-TRAC CS has a pair of thick movable shield gates at the bottom to allow raising the canister into the transfer cask, lowering of the canister into the storage or transpo1tation cask, or to support the canister weight and provide shielding while in the HI-TRAC CS. T he shield gates slide in steel guide rails along each side of the HI-TRAC CS. Steel pins or bolts are used to prevent inadvertent opening of the doors.

The HI-TRAC CS features a top steel ring that prevents the canister from being lifted above the top of the cask thus insuring that the canister remains within the radiation protected envelope of Page 247 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL'fEC PROPRIETARY INFORMAT ION the transfer cask. A lifting yoke provided with the HI-TRAC CS is used to interface with the cask handling crane. The VCT features lift links which connect the HI-TRAC CS trunnions to the VCT top beam for handling with the VCT.

3.2.2 Spent Fuel Canister Storage Spent fuel storage consists of the HI-STORM UMAX storage system, which includes spent fuel canisters placed in the steel Canister Enclosure Cavity (CEC) below ground in the HI-STORM UMAX ISFSI. The storage system is entirely passive by design and is completely autonomous (i.e., it requires no support systems for its operation).

Surveillance of the HI-STORM VVM assembly to ensure its continued effectiveness involves the following principal activities:

l. Check for intrusion of fore ign objects that may impair the system's thermal pe rformance during normal operations and in the wake of an extreme environmental phenomenon.

2. Check for corrosion damage to the steel parts, namely the CECs (oldest or most vulnerable VVM shall be inspected).

3. Check for structural damage to the ISFSI after an earthquake.

4. Perform the heat removal operability surveillance as specified in the Technical Specifications.

5. Perform ISFSI Security Operations in accordance with the site's security plan.

Routine maintenance on the HI-STORM UMAX System will typically be limited to cleaning and touch-up painting of the exposed steel surfaces, repair, and replacement of damaged vent screens, and removal of vent blockages (e.g., leaves, debris), if any. The heat removal system operability surveillance should be performed after any event that may have an impact on the safe functioning of the HI-STORM UMAX system. These include, but are not limited to, wind storms, snow storms, fire inside the ISFSI, seismic activity, and/or observed animal, bird, or insect infestations. The responses to these conditions involve first assessing the dose impact to perform the corrective action (inspect the HI-STORM VVM cavity, clear the debris, check for any structural damage of the ISFSI pad, and/or replace damaged vent screens); perform the corrective action; and verify that the system is operable (check ventilation flow paths and radiation blockage capability). In the unlikely event of significant damage to the ISFSI , possibly from a Beyond-the-Design Basis earthquake, the situation may warrant removal a nd visual inspection of the canister, and repair or replacement of the damaged ISFSI areas.

The storage system performs its functions under normal conditions as discussed in Chapter 10 and off-n01mal and accident level conditions as discussed in Chapter 15. Limits of operation associated with various normal and off-normal conditions are contained in Chapter 16.

Surveillance requirements are also contained in Chapter 16.

3.2.2.1 Safety Features Safety features include a passive dry storage system design and administrative controls. T he canister is enclosed in the cavity of the HI-STORM UMAX storage system, which protects the canister from severe natural phenomena (such as tornado-driven missiles), provides required shielding of the canister, and flow paths for natural convection cooling. Because of its Page 248 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEG PROPRIETARY IMFORM4TIQN underground disposition, the canister stored inside HI-STORM UMAX cannot tip-over. Safety features are discussed in greater detail in the HI-STORM UMAX FSAR [1.0.6].

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATIOf~

3.3 OTHER OPERATING SYSTEMS The storage casks are passive and require no other operating systems for safe storage of the spent fuel once they are placed into storage. The HI-STORE operating systems are described in this chapter and Chapter 10.

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ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC F'f':013RIETAR:Y INFORMATION 3.4 OPERATION SUPPORT SYSTEMS 3.4.1 Instrumentation and Control Systems Regulation 10CFR72. 122(i) requires that instrumentation and control systems be provided to monitor systems that are classified as Important to Safety. The operation of HI-STORE is passive and self-contained and therefore does not require control systems to ensure the safe operation of the system. However, temperatures of the air exiting the YYMs may be monitored to provide a means for assessing thermal performance of the storage casks. The temperature monitors are eq uipped with data recorders and alarms located in the Security Building. The temperature monitors are not required for safety and therefore are not subjected to important to safety criteria.

Radiation monitoring is provided to ensure doses remain ALARA and is discussed in Chapter

11. Radiation monitoring is not required to support systems that are classified as Important to Safety.

In the event of an earthquake, Holtec wi ll contact the National Earthquake Information Center, Golden, CO to acquire seismic data for a post-earthquake performance evaluation.

No other instrumentation or control systems are necessary or are utilized. Therefore, the requirements of 10CFR72.122(i) are satisfied.

3.4.2 System and Component Spares Spare temperature monitoring devices are maintained at the site. However, these devices are not req uired to maintain safe conditions at the HI-STORE faci lity. No other instrumentation spares are required.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION 3.5 CONTROL ROOM AND CONTROL AREA Regulation 10 CFR72.122(j) requires the control room or control area to be designed to ensme that HI-STORE is safely operated, monitored, and controlled for off-normal or accident conditions. This requirement is not applicable to HI-STORE because the spent fuel storage system is a passive system and hence does not require a control room to ensure safe operation.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY l~JFORMATION 3.6 ANALYTICAL SAMPLING No sampling is required for the safe operation of HI-STORE or to ensme that operations are within prescribed limits. Sampling of the gas inside the transportation cask is performed prior to venting and opening the cask in the CTB. Evaluation of the gas sample determines if the gas can be released to the atmosphere or if it must be filtered and the appropriate radiological protection needed when removing the transportation cask closure. Since the sampling is not required for nuclear safety of the facility, it is not classified as Important-to-Safety.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INf'ORMATION 3.7 POOL AND POOL FACILITY SYSTEMS The HI-STORE facility does not need a pool for storage or transfer operations. Canisters are received, transferred and stored in the dry condition.

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ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION 3.8 REGULATORY COMPLIANCE The operational steps required to place a loaded canister into a HI-STORM UMAX VVM cavity have been described in this chapter. The steps to remove a canister from a loaded VVM, which are essentially reverse of the steps in the loading sequence, have also been provided. These loading steps are sufficiently detailed to lead to the conclusion that the guidelines of safety and ALARA set down in NUREG-1567 [1.0.3] are full y satisfied. In particular, it can be concluded that:

1. T here are no radiation streaming paths from the canister during its transfer operation.

11. T he handling operations occur near grade level thus eliminating the need for ladders/platforms and improving the human factors aspects.

111. There are no exterior freestanding structures in the canister transfer operations and thus there is no risk of uncontrolled load movement under a (hypothetical) extreme environmental event such as tornado or high winds.

iv. The ventilation paths to passively cool the canister using ambient air during the transfer operation is maintained at all times thus protecting the fuel cladding from overheating and eliminating any thermally guided time limit on the duration for implementing the transfer steps.

v. All heavy load hand ling is carried out by ha nd ling devices that are equipped with redundant load drop protection features.

v1. Each storage cavity is independently accessible. Installation or removal of any canister does not have to contend with other stored canister s.

vu. Because the canister insertion (and withdrawal) occurs in the vertical configuration with ample lateral clearances, there is no risk of scratching or gouging of the canister's external surface (Confinement Boundary). Thus the ASME Section III Class 1 prohibition against damage to the pressure retaining boundary is maintained.

It is thus concluded that the HI-STORM UMAX ISFSI is engineered to meet the safety and ALARA imperatives contemplated in 10CFR72 [1.0.5] in full measures.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC F'~OF'RIETARY INFORMAT ION CHAPTER 4: DESIGN CRITERIA FOR THE HI-STORE CIS SYSTEMS, STRUCTURES AND COMPONENTS*

4.0 INTRODUCTION

This chapter contains safety-relevant information on the HI-STORE CIS facility in the following topical areas:

a. Spent fuel or other high-level radioactive waste containers (canisters) authorized to be stored,

b. Classification of structures, systems and components (SSCs) according to their importance

- to-safety, and

c. Design criteria and design bases for the HI-STORE CIS facility and associated SSCs during all operational modes, including normal and off-normal operations, Short Term Operations, accident conditions and extreme natural phenomena events.

Unlike the generic HI-STORM UMAX system, the Short-Term Operations at the HI-STORE facility do not involve any activity related to loading fuel into canisters: the canisters arrive at the HI-STORE CIS facility in a NRC-certified transport cask such as HI-STAR 190 (NRC docket #

71-9373). The Short Term Operations begin at the point the transport package is received at the site and end at the point the canister is placed in a HI-STORM VVM for interim storage.

As stated in Chapter 1, the HI-STORM UMAX system (NRC Docket# 72- 1040) [l.0.6] is the sole storage system designated to be employed at the HI-STORE CIS facility. As the canisters certified for use in the HI-STORM UMAX system are qualified in the HI-STORM FW system (NRC Docket # 72-1032) [ 1.3.7], there is a direct nexus between the site specific safety analyses for HI-STORE CIS facility and the analyses that undergird the general certification in [l.0.6] and [l.3.7].

As documented in this chapter, the .l oadings and conditions for which the HI-STORM UMAX VVM and its canisters are certified in [1.0.6] substantially exceed their counterparts for the HI-STORE CIS faci lity. This safety analysis reports mandates that only those canisters that are authorized for storage in HI-STORM UMAX under its general certification can be stored at the HI-STORE CIS facility. Furthermore, even among the population of canisters authorized by the HI-STORM UMAX CoC, only those that meet the heat load limit of the transport cask can be transported to the site will be available for storage at the site. Because the transport cask has a much lower heat load capacity than the HI-STORM UMAX venti] ated storage system, the limitation imposed by the transport cask winnows the number of canisters eligible for storage at the HI-STORE CIS fac ility significantly. It is evident that those canisters that meet the heat load limitation of the transport cask, because of the greater innate heat rejection capacity of ventilated syste ms, will be subject to a less severe thermal state at the HI-STORE CIS facility than that permitted under ISG-1 1 Rev. 3 [4.0.1] under long term storage.

The HI-STORE facility must be qualified to withstand all credible environmental or operation-related loadings without exceeding its applicable safety limits. To make this safety determination,

All references are placed within square brackets in this report and are compiled in Chapter 19 of this report.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY l~lFORMATION the credible loadings under all normal, off-normal and faulted states are compared with those that have been qualified in the HI-STORM UMAX FSAR [1.0.6]. Any load that is found to exceed the pre-certified li mit in the HI-STORM UMAX FSAR [1.0.6] is so identified in this chapter for further analysis.

As noted subsequently in this chapter, the site specific env ironmental and accident loads are fewer in number and less severe than those treated in the HI-STORM UMAX FSAR [1.0.6]. This statement applies to the Design Basis Earthquake (DBE) also where the 10,000-year return earthquake is shown to be bounded by the DBE for which the HI-STORM UMAX system is pre-certified. Much of the safety analysis material in this chapter pertains to confirming that each HI-STORE site specific loading is bounded by its counterpart treated in the Hl-STORM UMAX FSAR.

Many of the Design Criteria pertaining to the loadings and components common to the HI-STORM UMAX and the HI-STORE CIS systems, such as the MPC and VVM, are incorporated by reference in this SAR, as appropriate, to the HI-STORM UMAX FSAR [1.0.6]. To facilitate convenient access to the referenced material, a list of HI-STORM UMAX FSAR sections germane to this chapter is provided in Table 4.0.1.

Page 257 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLT EC LETTER 5025025 I IOLT EG PROPRIETARY INFORMATIOM TABLE 4.0.1: HI-STORM UMAX FSAR MATERIAL INCORPORATED IN THIS FSAR BY REFERENCE Location in HI- Subject of the Location in HI-STORM Justification STORE SAR Reference UMAX FSAR [1.0.6]

Subsection 4.1 .1 Spent Fuel to be stored Section 2.1, with exceptions MPCs to be stored at HI-STORE site are limited to as described in Subsection those included in the HI-STORM UMAX FSAR Subsection 4.3.1 MPCs to be stored 4. 1 of this SAR [1.0.6]; exceptions for maximum heat loads and backfill pressure imposed by transport cask are made, but are bounded by HI-STORM UMAX FSAR requirements.

Subsection 4.3.2 Design criteria for HI- Section 2.2, with exceptions Design criteria for HI-STORM UMAX VVM and STORM UMAX VVM as described in Subsection ISFSI are bounded by HI-STORM UMAX FSAR, and ISFSI 4.3.2.1 of this SAR except as noted.

Table 4.3.1 MPC Internal Design Section 2.3.2.1 Due to the lower heat load limit of the transport Pressure cask, the associated internal MPC pressure shall always be less than the MPC design basis pressure in the HI-STORM UMAX FSAR [1.0.6]

Table 4.3.1 High Winds Section 2.3.2.7 The wind conditions at the ELEA site are bounded by the HI-STORM UMAX FSAR Design Basis Wind.

Table 4.3. 1 Design Basis Flood Section 2.4.7 The Design Basis Flood used to qualify the VVM in the HI-STORM UMAX FSAR exceeds the most severe projection of flood at the ELEA site.

MPC (including fuel) HI-STORM UMAX FSAR temperature limits Subsection 4.3.1 Table 2.3.7 adopted.

temperature limits Page 258 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATION Subsection 4 .3.2 VVM temperature limits Table 2.3.7 HI-STORM UMAX FSAR temperature limits adopted.

Page 259 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION 4.1 MATERIALS TO BE STORED 4.1.1 Spent Fuel Canisters The SNF-bearing canisters that will be stored at the HI-STORE CIS facility are limited to those included in the HI-STORM UMAX FSAR [1.0.6]. No canister that is not included in the HI-STORM UMAX FSAR can be stored at the HI-STORE CIS Facility. Therefore all canisters (and the SNF specified as acceptable for storage in said canisters) to be stored at the facility are incorporated by reference herein, as follows:

Authorized contents are incorporated by reference from Section 2.1 of the HI-STORM UMAX FSAR [1.0.6], with the following exceptions:

1. Maximum permissible heat loads specified in Subsection 2. 1.9 of the HI-STORM UMAX FSAR [1.0.6], are replaced by more restrictive heat load imposed by the transport cask heat load requirements;

11. The helium backfill pressure options of Tables 2.1.8 and 2.1.9 of the HI-STORM UMAX FSAR [ 1.0.6], which relate to the establishment of the permissible aggregrate heat load, are supplanted by the requirements of this chapter.

Canisters to be stored at the HI-STORE CIS Facility must meet the max imum heat loads shown in Tables 4.1.1 and 4.1.2 of this SAR, in accordance with the regional loading patterns shown in Figures 4. 1. l and 4.1 .2 of this SAR (item i).

Requirements for the helium backfill of all canisters to be stored at the HI-STORE CIS ar e in Table

4. 1.3 and 4.1.4 of this SAR (item ii). Although canisters will not be backfi lled at site, received canisters will be verified to meet these helium backfill requirements as a condition of acceptance.

4.1.2 High Level Radioactive Waste This SAR does not consider safety analysis of any canister that is not certified in the HI-STORM UMAX docket [1 .0.6]. Accordingly, it does not at the present time include any canister containing non-fissile High Level Radioactive Waste at the HI-STORE CIS facility.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC F'R013RIETAR:Y INFORMATION Table 4.1.1: Maximum Decay Heat Load for MPC-37 (PWR Fuel Assembl.y)

Maximum Decay Heat Region Total Heat Load for Pattern Load per Assembly (kW)

(Note 1) Each Pattern (kW)

(Note 2) 1 0.38 1 2 1.7 31.82 3 0.50 l 0.42 2 2 1.54 32.02 3 0.61 1 0.61 3 2 1.23 32.09 3 0.74 1 0.74 4 2 1.05 32.06 3 0.8 1 0.8 5 2 0.95 32.04 3 0.84 1 0.95 6 2 0.84 31.43 3 0.8 Note 1: For basket region numbering scheme refer to Figure 4.1 .1 Note 2: These maximum fuel storage location decay heat limits must account for decay heat from both the fuel assembly and non-fuel hardware.

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A TTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATIOM Table 4.1.2: Maximum Decay Heat Load MPC-89 (BWR Fuel Assembly)

Maximum Decay Heat Region Total Heat Load for Pattern Load per Location (kW)

(Note 1) Each Pattern (kW)

(Note 2) l 0. 15 1 2 0.62 32. 15 3 0.15 1 0.18 2 2 0.58 32.02 3 0.18 1 0.27 3 2 0.47 32.03 3 0.27 1 0.32 4 2 0.41 32.08 3 0.32 1 0.35 5 2 0.37 31.95 3 0.35 Note 1: For basket region numbering scheme refer to Figure 4.1.2.

Note 2: These maximum fuel storage location decay heat limits must account for decay heat from both the fuel assembly and non-fuel hardware.

Page 262 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION Table 4.1.3: MPC Backfill Pressure Requirements (Note 1)

MPC Type Pressure Range MPC-37 2: 39.0 p sig and S 46.0 psig MPC-89 2: 39 .0 p sig and S 4 7 .5 psig Note 1: Helium used for backfill of MPC shall have a purity of 2:99.995%. The pressure range is based on a reference temperature of 70°F.

Table 4.1.4: MPC Backfill Pressure Requirements for Sub-Design Basis Heat Load (Note 1)

MPC Type Pressure Range (Note 2)

MPC-37 2: 39.0 p sig and S 50.0 psig MPC-89 2: 39.0 p sig and S 50.0 psig Note 1: Sub-Design Basis Heat Load is defined as 80% of the des ign basis heat load in every storage location defined in Tables 4.1.1 and 4.1.2 for MPC-37 and MPC-89 respectively.

Note 2: Helium used for backfill of MPC shall have a purity of >99.995%. The pressure range is based on a reference temperature of 70°F.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY l~lFORMAT ION 3-1 3-2 3-3 3-4 2-1 2-2 2-3 3-5 3-6 2-4 1-1 1-2 1-3 2-S 3-7 3-8 2-6 1-4 1-5 1-6 2-7 3-9 3-10 2-8 1-7 1-8 1-9 2-9 3-11 3-12 2-10 2-11 2-12 3-13 3-14 3-15 3-16 Legend Region- Figure 4.1.1: MPC-37 Regional-Cell Identification Cell ID Page 264 of 689 Revision OC May 2018

A TTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY l~l FOR MATION 3-1 3-2 3-3 3-4 3-5 3-6 2-1 3-7 3-8 3-9 3-10 3-11 2-2 2-3 2-4 2-5 2-6 3-12 3-13 3-14 2-7 2-8 2-9 2-10 2-11 2-12 2-13 3-15 3-16 3-17 2-14 2-15 1-1 1-2 1-3 2-16 2-17 3-18 3-19 3-20 2-18 2-19 2-20 1-4 1-5 1-6 2-21 2-22 2-23 3-21 3-22 3-23 2-24 2-25 1-7 1-8 1-9 2-26 2-27 3-24 3-25 3-26 2-28 2-29 2-30 2-31 2-32 2-33 2-34 3-27 3-28 3-29 2-35 2-36 2-37 2-38 2-39 3-30 3-31 3-32 3-33 3-34 2-40 3-35 3-36 3-37 Legend Region-3-38 3-39 3-40 CeUID Figure 4.1.2: MPC-89 Regional-Cell Identification Page 265 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEG PROPRIETARY l~lFORMATION 4.2 CLASSIFICATION OF STRUCTURES, SYSTEMS, AND COMPONENTS The systems, structures and components (SSCs) for the HI-STORE CIS facility are designed and analyzed to ensure that they wi ll perform their intended functions under normal , off-normal, and accident conditions to meet all regulatory requirements delineated in 10 CFR Part 72 [ 1.0.5]. These intended functions include:

1. Providing radionuclide confinement/containment

11. Enabling heat rejection from cask components and contents to maintain their temperatures within specified regulatory limits 111. Attenuating emission of radiation to acceptable levels iv. Maintaining sub-criticality of fissile contents References [4.2.1) & [4.2.2) provide the guidelines to determine the Important to Safety significance category in accordance with NUREG/CR-6407 [1.2.2] which are:

Category A: The failure or malfunction of a structure, component, or system could directly result in a condition adversely affecting public health and safety.

Category B: The failure or malfunction of a structure, component, or system could indirectly (i.e., in conjunction with the failure of another item) result in a condition adversely affecting public health and safety.

Category C: The failure or malfunction of a system, structure or component (SSC) that would have some effect on the packaging, but would not significantly reduce the effectiveness of the packaging and would not be likely to create a situation adversely affecting public health and safety.

Not-Important-to-Safety: T he failure or malfunction of an SSC would not reduce the effectiveness of the system or packaging and would not create a situation adversely affecting public health and safety.

Thus each SSC that constitutes the HI-STORE CIS facility is classified into one of above four categories depending on the severity of consequence in the event of its failure or malfunction due to a credible adverse event.

Chapter 1 contains the description of the SSCs that comprise the HI-STORE CIS facility. The SSCs in Table 4.2.1 can be subdivided in two types, namely

i. Those that are designed and built to meet the requirements of the HI-STORE CIS facility or are assembled at the site (HI-STORE Specific or "HS")

11. Those that are pre-qualified and delivered to the site pursuant to the safety requirements in the HI-STORM UMAX docket and arrive at the site ready-for-deployment (UMAX Generic or "UG")

Page 266 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION The ITS category for UG SSCs is defined by their classification in their native docket, principally the HI-STORM UMAX docket [1.0.6]. Those SSCs whose safety classification is not defined in other dockets (HS SSCs) are classified using [4.2.1] & [4.2.2]. Table 4.2.1 provides a compilation of the ITS classification information on all of the principal SSCs that are envisaged to be used at the HI-STORE CIS facility including both the "HS" and "UG" types; the latter directly excerpted from the HI-STORM UMAX FSAR [1.0.6] or a referenced docket therein, such as HI-STORM 100 FSAR [1.3.3].

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A TTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFOR MAT ION Table 4.2.1 ITS Classification of SSCs that Comprise the HI-STORE CIS Facility Name of SSC Function ITS Source for Type ITS (Note 1) (See Section 1.3) Classification determination Cavity Cavity E nclosure Container; ITS-C UG [1.0.6]

Enclosure defines the Canister's storage space Container (CEC)

CEC Closure A removable heavy structure placed ITS-C UG Lid atop the HI-STORM UMAX CEC that blocks sky shine from the stored Canister.

CEC Divider A removable insulated shell that ITS-C VG Shell surrounds the stored Canister Supp01t Supports the HI-STORM VMAX ITS-C VG Foundation VVM Pad (SFP)

ISFSI pad Defi nes the top surface of the VVM ITS-C UG CLSM (see Occup ies the subterranean space NITS VG Glossary) between the CECs SNF Canisters Provide a leak-tight confi nement ITS-A UG [1.3.7]

and criticality control to stored fuel HI-TRAC CS Serves to facilitate ALARA transfer ITS-A HS [l.0.5], [4.2.l ],

of the Canister between the [4.2.2], [1.2.2]

transport cask and the HI-STORM UMAX VVM cavity HI-TRAC CS Means for attaching HI-TRAC CS ITS-A HS Lift Yoke to CTB Crane for loaded or unloaded relocation within the CTB.

Cask Transfer Provides weather protection and NITS HS Building climate control for canister transfer (CTB)

Page 268 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLT EG PROPRIETARY INFORMAT IOM Table 4.2.1 ITS Classification of SSCs that Comprise the HI-STORE CIS Facility Name of SSC Function ITS Source for Type ITS (Note 1) (See Section 1.3) Classification determination CTB Crane Used to move, upend and down-end ITS-A [Note 2] HS [ 1.0.5], [4.2.1],

the transport cask (loaded an [4.2.2], [l.2.2]

unloaded); remove the transport cask impact limiters; move and position HI-TRAC CS (loaded and unloaded); handling of other equipment CTB Slab Provide support for all canister ITS-C HS receipt and loading operations within the CTB Canister Underground ventilated structure ITS-C HS Transfer used to effectuate transfer of Facility (CTF) canister from the transport cask to the HI-TRAC CS (and reverse operation, if required)

ID-STAR 190 Cask in which SNF canisters are ITS-A UG [l.3.6]

Transport received Cask Transport Serves to lift HI-STAR 190 ITS-A HS [ 1.0.5], [4.2.1],

Cask transport cask (using CTB crane) [4.2.2], [1.2.2]

Horizontal Lift Beam Transport Serves to upend/downend HI- ITS-C HS Cask Tilt STAR 190 transport cask Frame Transport Means to connect HI-STAR 190 ITS-A HS Cask Lift Transport Cask to CTB crane for Yoke movement within the CTB Vertical Cask Principal means to translocate the ITS-A UG [ 1.3.71 Transporter HI-TRAC CS and to effectuate (Note 3)

(VCT) Canister transfer to the HI-STORM UMAXVVM Page 269 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROF'~IETAFH llqfiORMA'FIOM Table 4.2.1 ITS Classification of SSCs that Comprise the HI-STORE CIS Facility Name of SSC Function ITS Source for Type ITS (Note 1) (See Section 1.3) Classification determination MPC Lift Means of attaching rigging to MPC ITS-A HS [l.0.5], [4.2.l],

Attachment for download into VVM [4.2.2], [1.2.2]

MPC Lifting Means of attaching MPC Lift ITS-A HS Device Attachment to VCT for download Extension ofMPC into VVM Special Lifting components used to connect ITS-A HS Lifting the cask or canister to the CTB Devices crane or the VCT lift points Note 1: The ancillaries used at the HI-STORE CIS facility are limited to those needed to transfer the arriving canisters into the HI-STORM VVMs. Thus, some ancillaries described in the HI-STORM UMAX FSAR [L0.6], like the Forced Helium Drying System used to dry the canister internals), are not included :in this table.

Note 2: The Cask crane's main girder and vertical columns are ITS-category A; the main hoist, auxiliary hoist and other e lectrical systems are treated as 'augmented quality" under Holtec 's QA program.

Note 3: The VCT is ITS-A because of the Overhead beam. Other components are as listed below (See Figure 4.5.1):

VCT Component I.D. ITS Category Cask restraint system NITS Cask restra:int strap ITS-B Control systems NITS Engine and drive systems NITS Hydraulic system NITS Jacks (lift cylinders) NITS Lifting towers (structure) ITS-A MPC downloader system ITS-B Overhead beam ITS-A Tracks NITS Vehicle frame NITS Load Drop Protection System ITS-B Page 270 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEG PROPRleT/1.RY IMFORMATIQN 4.3 DESIGN CRITERIA FOR SSCS IMPORTANT TO SAFETY 4.3.1 Multi-Purpose Canisters (MPCs)

The MPCs that will be stored at the HI-STORE CIS are limited to those included in the HI-STORM UMAX FSAR [1.0.6].

4.3.1.1 Structural The MPCs to be received and loaded at the HI-STORE CIS facility are comprised of a fuel basket within a welded enclosure vessel. As the only canisters certified for storage in the HI-STORE CIS facility are those qualified in the HI-STORM UMAX FSAR [1.0.6], the structural design criteria for the MPCs is incorporated by reference to Section 2.0.2 of [ 1.0.6].

4.3.1.2 Thermal The thermal design criteria for the MPCs (including the design temperature limits of Table 2.3.7) are incorporated by reference from Section 2.0.3 (MPC Design Criteria), of the HI-STORM UMAX FSAR [ 1.0.6]. The portion of Section 2.0.3 of Reference [ 1.0.6] related to maximum permissible heat loads and he lium backfill is not incorporated by reference, as it has been replaced with the information presented in Section 4.1.1 of this SAR.

4.3.1.3 Shielding The site boundary dose requirement for the syste ms (including canisters) stored at HI-STORE is provided in Section 4.4. Compliance to the requirements (see Table 4.4. 3) is demonstrated in Chapter 11.

4.3.1.4 Confinement The MPC provides for confinement of all radioactive materials for all design basis, off-normal and postulated accident conditions. As the only canisters certified for storage in the HI-STORE CIS facility are those qualified in the HI-STORM UMAX FSAR [1.0.6], the confinement criteria for the MPCs is incorporated by reference from Section 2.0.6 of [1.0.6].

4.3.1.5 Criticality Control Criticality control is maintained by the geometric spacing of the fuel assembles and the spatially distributed B-10 isotope in the Metamic-HT basket within the canister. As the only canisters certified for storage in the HI-STORE CIS facility are those qualified in the HI-STORM UMAX FSAR [ 1.0.6], the criticality control criteria for the MPCs is incorporated by reference to Section 2.0.5 of [1.0.6].

4.3.2 VVM Components and ISFSI Structures The design criteria of the HI-STORM UMAX VVM components and ISFSI structures described in Chapter 2 of the HI-STORM UMAX FSAR [l.0.6] are largely applicable to the HI-STORE CIS. The criteria of [1.0.6] that bound the HI-STORE CIS design, and are therefore excluded from Page 271 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC F'~OPRIE I ARV INFORMATION further consideration in this SAR, are outlined in Table 4.3.1. Environmental conditions and constraints that differ from those bounded by [1.0.6], although minor in nature, are described in Table 4.3 .2 and evaluated herein. W ith the following exceptions, all subsections of the HI-STORM UMAX FSAR are relevant to the HI-STORE CIS evaluation :

1 Criteria related to the HI-TRAC VW system. The ID-TRAC VW system is supplanted by the HI-TRAC CS system in this application, with the design criteria for the HI-TRAC CS system described herein.

2 Service conditions related to the used of Forced Helium Drying (FHD) described in Paragraph 2.3.3.5 of the HI-STORM UMAX FSAR. As the HI-STORE CIS facility accepts only pre-packaged canisters, operations related to internal canister drying are not applicable.

Information consistent with the regulatory requirements related to shielding, thermal performance, confinement, radiological, and operational considerations is also provided. The licensing drawing of the HI-STORM UMAX design variant used in the HI-STORE CIS application is included in Section 1.5 of this SAR. The licensing drawing provides information on the necessary critical characteristics that define the HI-STORE CIS UMAX system for this application.

4.3.2.1 Structural The applicable loads, affected parts under each loading condition, and the applicable structural acceptance criteria related to the HI-STORM UMAX VVM and ISFSI structures that are compiled in Sectio n 2.0 of [1.0.6] provide a complete framework for the required qualifying safet y analyses in this SAR. The VVM storage system at the HI-STORE CIS ISFSI will be functionally identical to that certified in the HI-STORM UMAX docket. The conservative approach of basing the HI-STORE CIS design on the certified HI-STORM UMAX desig n is supported by the following:

l. The subgrade and under-grade soil properties at the HI-STORE CIS site are uniformly better than those assumed for the general certification of the HI-STORM UMAX system.

These properties can lbe fo und in the geotechnical investigation completed December 201 7

[2. 1.24]. HI-STORE Bearing Capacity and Settlement Calculation report HI-2188 143

[4.3.5) deta il s the methodology used to compute the bearing capacity at the site. This calculation confoms the required bearing capacity is met for the soil underneath the planned construction.

2. The top-of-pad earthquake spectra corresponding to a 10,000-year earthquake at the HI-STORE CIS site is enveloped by that assumed for the HI-STORM UMAX in its general certification. (Subsection 4.3.6 and Table 4.3.3 provide a summary of the applicable seismic loadings for the HI-STORE CIS facility).

3. The long-term settlement at the HI-STORE CIS ISFSI is computed in [4.3.5] to be less than that assumed in the certification of the HI-STORM UMAX. The methodology fo llowed is stated in the calculation itself. As stated in item 1, above, soil properties at the HI-STORE CIS site are more favorable than those assumed in the HI-STORM UMAX system certification [2. 1.24].

Page 272 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY lt>JFORMATIQt:,I

4. The load combinations for the VVM and ISFSI structure at the HI-STORE CIS are consistent with those identified in the HI-STORM UMAX evaluation. Load combinations that are bounded by the HI-STORM UMAX evaluation, and therefore excluded from further evaluation in this application, are listed in Table 4.3.1.

4.3.2.2 Thermal The design temperatures for the VVM components and ISFSI structures are incorporated by reference from Table 2.3.7 of Reference [l.0.6].

4.3.2.3 Shielding The site boundary dose requirement for the HI-STORM UMAX ISFSI at HI-STORE is provided in Section 4.4. Compliance to the requirements (see Table 4.4.3) is demonstrated in Chapter 11.

4.3.2.4 Confinement The VVM and ISFSI structures do not perform any confinement function. Confinement during storage is provided by the SNF storage canisters which are protected from leak by an all- welded stainless steel confinement vessel and are certified in their native docket as subject to a non-credible risk of leakage, see C hapter 9.

4.3.2.5 Criticality Control The VVM components and ISFSI structures do not perform any criticality control function.

Criticality control is maintained during storage by the internal configuration of the SNF storage canisters, as described in Chapter 8.

4.3.3 HI-TRAC CS The HI-TRAC provides physical protection and radiation shielding of the MPC contents during the extraction of a loaded canister from the transport cask and its subsequent transfer to the HI-STORM UMAX VVM. The design characteristics of the HI-TRAC CS are presented in Chapter

l. The HI-TRAC CS plays a central role in the Short Term Operations that are carried out to translocate the Canister from an a1Tiving transport package to its designated HI-STORM UMAX storage cavity.

4.3.3.1 Structural The HI-TRAC CS u*ansfer cask includes both structural and non-structural radiation shielding components that are classified as important-to-safety. The structural steel components of the HI-TRAC CS are designed to meet the stress limits of Section III, Subsection NF, of the ASME Code

[4.5.1] for all operating modes. The embedded trunnions for lifting and handling of the transfer cask are designed in accordance with the requirements of NUREG-0612 (1.2.7] for interfacing lift points.

Page 273 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025

"""190L'fEC PROPRIETARY INFORMAT ION Table 4.3.4 lists the loading scenarios for HI-TRAC CS for which its structural qualification must be performed.

4.3.3.2 Thermal The HI-TRAC CS cask must reject the canister's decay heat to the environment during the normal short term operations and accident scenarios, which are established by considering the operations described in Chapter 10. T he thermall y-significant loadings are listed in Table 4.3.5. The permissible temperature limits for all steel and concrete used in short-term operation SSCs used at HI-STORE, including HI-TRAC CS, are provided in Table 4.4. 1.

4.3.3.3 Shielding The HI-TRAC transfer cask provides shielding to maintain occupational exposures ALARA in accordance with 10CFR20 [7.4. 1]. The HI-TRAC calculated dose rates for a set of reference conditions are reported in Chapter 7. These dose rates are used to estimate the oc,cupational exposure to the work crew for the Short-Term Operations.

Section 4.4 provides dose limits applicable to the HI-STORE CIS facil ity.

4.3.3.4 Confinement The HI-TRAC CS transfer cask does not perform any confinement function.

4.3.3.5 Criticality Control The HI-TRAC CS transfer cask does not provide any criticality control function.

4.3.4 HI-STAR 190 As discussed in Chapter 3, the HI-STAR 190 transport cask, used to deliver the loaded Canister to the CTB, participates in the Short Term Operations, albeit to a limited extent. The safety analysis of HI-STAR 190 as a transport package under 10CFR7 1 regulations is documented in [l.3.6]. In order to insure that the transport condition loads that underlie the transport certification of HI-STAR 190 are not exceeded, the Short Term Operations in the CTB are configured such that:

1. The handling of the cask is always carried out using single failure proof devices and systems;

11. As an additional defense-in-depth, the cask remains equipped with its impact limiters during its hand Iing fro m the rail car and the free fall height of the cask is maintained below its certified limit in its Part 7 1 docket; 111. The cask is kept free of any wrappings that may inhibit its heat rejection function during short term operations; 1v. In this subsection, HI-STAR l90's safety function as a canister containment device to the requirements of Pa rt 72 is set down as a set of design criteria.

4.3.4.1 Structural Page 274 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMATIOM The structural qualification of HI-STAR 190 to the loadings of 10CFR71 .71 (normal condition) and 10CFR7 l.73 (accident condition) in [1.3.6] are clearly much more severe than those encountered during its handling in the CTB. Nevertheless, certain structural requirements are unique to the operations in the CTB that are unique to the Short Term Operations. Table 4.3.6 contains the structurally significant loadings on the HI-STAR 190 cask in the Cask Transfer Building. Acceptance criteria are provided in Section 4.4.

4.3.4.2 Thermal The thermally-significant loadings on HI-STAR 190 that warrant safety demonstration are summarized in Table 4.3.6. The permissible temperature limits for all steel weldments in casks and structures used at HI-STORE, provided in Table 4.4.4, are applicable to the HI-STAR 190.

4.3.4.3 Shielding HI-STAR 190 is designed to meet the dose attenuation requirements of 10CFR71 [l.3.2] which far exceed those expected of on-site transfer casks. However, HI-STAR 190's contribution to meeting the dose limits of Part 72, set down in Subsection 4.4 herein , is considered in demonstrating compliance.

4.3.4.4 Confinement The confinement function of the canister is unaffected by the function of HI-STAR 190.

4.3.4.5 Criticality Control HI-STAR 190 does not participate in the criticality contro l function.

4.3.5 Canister Transfer Facility (CTF)

The HI-STORE CTF is an underground structure used to effectuate transfer of the SNF canister from the transport cask (HI-STAR 190) to the transfer cask (HI-TRAC CS).

4.3.5.1 Structural The CTF includes both structural and non-structural radiation shielding components that are classified as important-to-safety. The structural steel components of the CTF are designed to meet the stress limits of Section III, Subsection NF, of the ASM E Code [4.5.1] for normal, off-normal and accident conditions, as applicable. The CTF reinforced concrete structures shall meet the applicable strength requirements of ACI 318-05 [5 .3. l].

The CTF must withstand the loads associated with the weights of each of its components, including the weight of the HI-TRAC CS transfer cask with the loaded MPC stacked on top during the canister transfer, and the weight of the transport cask with the loaded MPC staged on the CTF fo undation slab. The CTF shall be capable of withstanding lateral loading in a seismic event as determined by the provisions of Chapter 8 of ASCE 4 [4.3.4].

4.3.5.2 Thermal Page 275 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY l~lFORMAT ION The allowable temperatures for the CTF structural steel components are based on the maximum temperature for material properties and allowable stress values provided in Section II of the ASME Code. The allowable temperatures for the structural steel and shielding components of the CTF are provided in Table 4.4.1.

4.3.5.3 Shielding The CTF provides shielding to maintain occupational exposures ALARA in accordance with 10CFR20 [7.4. l] . Dose rates for a set ofreference conditions are reported in Chapter 7. These dose rates are used to perform a generic occupational exposure estimate for MPC transfer operations, as described in Chapter 11.

4.3.5.4 Confinement The CTF does not perform any confinement fun ction.

4.3.5.5 Criticality Control The CTF does not perform any criticality control fun ction.

4.3.6 Applicable Earthquake Loadings for the HI-STORE CIS Facility Guided by the adj udication i n the ASLB proceedings on the PFS, LLC docket [4.3.1], the Safe Shutdown Earthquake (SSE) or Design Basis Earthquake (DBE) for the HI-STORE CIS facility has been set to bound the 10,000 year return earthquake, which is discussed in Subsection 2.6.2.

Similarly, the Operating Basis Earthquake (QBE) has been set to bound the 1,000 year return earthquake for the site. For additional conservatism and to overcome any potential uncertainty or future adjustments to the s ite seismological data, a Design Extended Condition Earthquake (DECE) has also been defined for the site, which has a ZPA value that is two-thirds greater than the DBE.

The response spectra of the bounding earthquakes are defined by the Regulatory Guide 1.60 spectra pegged to the respective ZPA values identified in Table 4.3.3. The generation of acceleration time histories, if required, shall meet the criteria specified in SRP 3.7.1 [5.4.1], which has been used to support safety analyses for HI-STORM deployments at numerous nuclear plant sites.

The DBE applies to the HI-STORM UMAX system which will serve to store the Canisters for a relatively long duration (depending on the need and licensing duration granted by the USNRC). In Chapter 5, however, the DECE is conservatively used to inform the structural evaluation of the HI-STORM UMAX system a t the HI-STORE site.

The OBE applies to the Short-Term Operations required to load the arriving Canisters at HI-STORE. All equ ipment configurations, such as the stack-up at the Canister Transfer Facility and that at the HI-STORM UMAX VVM or the Vertical Cask Crawler (VCT) holding the HI-TRAC CS transfer cask by its straps (Figure 4.5.2), are subject to seismic qualification under the Page 276 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATIOf~

Operating Basis Earthquake. However, the seismic calculations in Chapter 5 for Short-Term Operations conservatively use the DBE as input.

Following the universally practiced "lift and set" rule at nuclear power plants, transient activities such as upending of a cask, attaching of slings or installation of fasteners, are treated as transient activities that are not subject to a seismic qualification . For clarity of application, any activity that spans less than a work shift is deemed to be seismic-exempt.

Page 277 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY llqfiORMAl"IOlq Table 4.3.1 Loadings Excluded from Further Consideration in the Qualification of Storage System and Ancillaries at the HI-STORE SAR Internal Design All canisters brought to the HI-STORE site in the HI-STAR 190 transport Pressure cask from operating at-plant ISFSis must meet the transport cask heat load limit, which is much lower than the acceptable limit defined in Chapter 2 of the HI-STORM UMAX FSAR [1.0.6]. The associated internal design pressure shall therefore always be less than its design basis pressure. The canister internal pressure is incorporated by reference from the HI-STORM UMAX FSAR [1.0.6], Paragraph 2.3.2. 1. The HI-TRAC transfer cask and HI-STORM UMAX VVM are not capable of retaining internal pressure due to their open design, and therefore no analysis is required.

Lightning Lightning is considered to be innocuous to the HI-STORM UMAX ISFSI because of its underground configuration. It is therefore excluded from consideration in both the HI-STORM UMAX and HI-STORE CIS design loadings. The evaluation of the HI-STORM UMAX VVMs related to lightning is incorporated by reference from the HI-STORM UMAX FSAR

[1.0.61, Section 2.3. 1.

Snow and Ice The latitude of the ELEA site makes heavy snow accumulation and the comparative low magnitude of snow loading removes snow as a Design Basis Load (DBL) a priori from further consideration High Winds Regulatory Guide 1.76 [2.7. l], ANSI 57.9 [2.7.2], and ASCE 7-05 [4.6.1]

provide the wind data used to define the Design Basis Wind in the HI-STORM UMAX FSAR. The diminutive profile a nd heavy weight of the closure lid (over 17 tons) makes the HI-STORM UMAX facility immune from any kinematic movement under very high or tornadic wind conditions. The wind conditions at the ELEA site are considered to be bounded by the HI-STORM UMAX FSAR Design Basis Wind. The HI-STORM UMAX systems performance under high wind conditions is incorporated by reference from the HI-STORM UMAX FSAR [l.0 .6],

Section 2.3.2.7 Tornado Borne The Design Basis Missiles (DBMs) analysis in the HI-STORM UMAX Missiles FSAR show large margins of safety and are considered to bound the HI-STORE CIS facility conditions. Therefore, a repetitive analysis in this SAR is unnecessary. The HI-STORM UMAX tornado borne missile analysis is incorporated by reference from the HI-STORM UMAX FSAR

[l.0.6], Section 2.4.2.

Page 278 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMAT ION Table 4.3.1 Loadings Excluded from Further Consideration in the Qualification of Storage System and Ancillaries at the HI-STORE SAR Flood As shown in Table 4.3.2, the Design Basis Flood used to qualify the VVM in the HI-STORM UMAX FSAR exceeds the most severe projection of flood at the ELEA site. Therefore, flood is eliminated from consideration as a meaningful loading event for HI-STORE CIS. The HI-STORM UMAX system design basis flood evaluation is incorporated by reference from the HI-STORM UMAX FSAR [1.0.6], Section 2.4.7.

Non-Mechanistic Because the HI-STORM UMAX VVM is situated underground, a tip-over Tip-over event is not a credible accident for this design. It has been excluded in the HI-STORM UMAX safety analysis for the same reason.

Explosion An explosion event has not been postulated as a Design Basis Load (DBL) for the HI-STORE ISFSI. However, the HI-STORM UMAX VVM is evaluated for a design basis explosion pressure per Table 2. 3. 1 of [1.0.6].

In addition, the canisters are evaluated for a Design Basis external pressure, under accident conditions, per Table 2.2.1 of [1.3.7).

Page 279 of 689 Revision OC May 2018

A TTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATIOM Table 4.3.2 Environmental Data for the Licensing Basis in the HI-STORM UMAX Docket and the HI-STORE Site for Different Service Conditions HI-STORM Site Specific UMAX Service Condition Item Data for HI-General STORE CIS License Data Temperature (defined as annual 62 deg. F 80 deg. F.

Normal Condition of average) (Table 2.7. 1)

Storage Ambient pressure corresponding to 670 mm Hg 760 mm Hg elevation above sea level (See Note 1)

Off-normal temperature Off-Normal Condition (defined as the minimum of the 72- 9 1 deg. F 100 deg. F.

of Storage hour average of the ambient (Table 2.7.1) tem perature at an ISFSI site.)

Accident Condition (maximum Accident Condition of 108 deg. F average ambient temperature over a 125 deg. F Storage See Chapter 2 24-hour period)

Maximum & minimum 3-day 90 deg. F 9 1 deg. F Short Term Operations average ambient temperature 0 deg. F 0 deg. F 4.8 inches (See Chapter Maxim um Flood Peak height of the flood water 125 feet 2, site Height (faulted States) above the ISFSI pad considered "flood dry")

Note 1: Ambient air pressure at 3500 ft elevation above sea level Page 280 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY l~lFORMATION Table 4.3.3 Applicable Earthquake and Long Term Settlement data for the Certified HI-STORM UMAX System and the HI-STORE CIS Facility HI-STORM HI-UMAX Generic STORE

Data Comment License Value CIS Site (see Note 1) Value

150 lb/ft3 reference dry See Licensing Drawings in density Chapter 1 for details on

4,500 psi concrete pad thickness.

minimum concrete Grade 60 Rebar. R ebar is Same as ISFSI Pad and SFP compressive #11@9" (each face, each the value concrete density strength @ :'S direction) certified concrete compressive 28 days l in the HI-strength

60,000 psi Compressive strength, STORM rebar yield strength minimum rebar allowable bearing stress and UMAX concrete cover on rebar yield strength reference dry density values docket.

minimum for ISFSI structures are also concrete cover applicable to the plain on rebar per concrete used in the HI-subsection STORM UMAX Closure 7.7.l of ACI- Lid 318(05)

Depth averaged density of 120 lb/ft3 120 lb/ft3 Required for shielding and 2 subgrade in Space A (see minimum mfoimum structural analysis Figure 4.3.1)

Depth averaged density of 110 lb/ft3 110 lb/ft3 Required for shielding 3 subgrade in Space B (see minimum minimum analysis.

Figure 4.3.1)

Depth averaged density of 120 lb/ft3 4 subgrade in Space C (see 120 lb/ft3 nominal Not required for shielding.

nominal Figure 4.3.l)

Depth averaged density of This space will contain 120 lb/ft3 5 subgrade in Space D (see 120 lb/ft3 nominal native soil. Not required for nominal Figure 4. 3.1) shielding.

1300 Strain compatible 1300 ft/sec This space will typically ft/sec 6 effective shear wave minimum . . contain CLSM or lean mrn1mum velocity in Space A concrete.

Page 281 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMATIOM Table 4.3.3 Applicable Earthquake and Long Term Settlement data for the Certified HI-STORM UMAX System and the HI-STORE CIS Facility HI-STORM HI-UMAX Generic STORE

Data Comment License Value CIS Site (see Note 1) Value Strain compatible 450 ft/sec 780 ft/sec Space will contain native 7 effective shear wave . . . .

mm1mum mrn1mum soil.

velocity in Space B Strain compatible 485 ft/sec 980 ft/sec Space will contain native 8 effective shear wave minimum minimum soil.

velocity in Space C Strain compatible 980 ft/sec 485 ft/sec Space will contain native 9 effective shear wave .. minimum minimum soil.

velocity in Space D, V Density of plain concrete 150 Used in shielding 10 in the Closure Lid 150 lb/cubic feet lb/cubic calculations (nominal) feet Reference compressive Used in analysis of 11 strength of plain concrete 4,000 psi 4,000 psi mechanical loadings on the in the Closure Lid Closure Lid Min imum compressive Used in tornado missile 12 strength of SES in Space 1,000 psi 1,000 psi impact analysis and SSI A (see F igure 4.3. 1) analysis Two orthogonal horizontal and one vertical ZPAs for 0.1 5,0.15, 5% Damped Reg. Guide 13 -

10,000 -year return 0.1 5 1.60 spectra [4.3.2]

earthquake (DBE)

Two orthogonal horizontal and one vertical ZP As for 0.10, 0.10, 2% Damped Reg. Guide 14 1000- year return

- 0.10 1.60 spectra [4.3.2]

earthquake (OBE)

Two orthogonal horizontal and one vertical ZP As for 0.25,0.25, 5% Damped Reg. Guide 15 Design Extended - 0.25 1.60 spectra [4.3.2]

Condition Earthquake (DECE)

Page 282 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HObTeC PROPRIETARY INFORMA'flON""

Table 4.3.3 Applicable Earthquake and Long Term Settlement data for the Certified HI-STORM UMAX System and the HI-STORE CIS Facility HI-STORM HI-UMAX Generic STORE

Data Comment License Value CIS Site (see Note 1) Value The HI-STORM UMAX CoC uses the Newmark summation limit to indicate the severity of an earthquake event. The Newmark 100-40-40 response summation Newmark Summation of for a 3-D earthquake s.i te is 16 the ZPAs at the Grade at 1.3 0.45 defined as: A=

the HI-STORE site a,+0.4a2+0.4a3, where a,, a2 (DECE)(Note 2) and a3are the site's ZPAs in three orthogonal directions and a,2:a22'.a3 This approach is consistent with Reg. Guide 1.92

[4.3.3].

Note 1: The HI-STORM UMAX ISFSI design data is reproduced from Table 2.3.2 of the HI-STORM UMAX FSAR [1.0..6].

Note 2: The Newmark summation, A, is the weighted scalar that defines the severity of an earthquake consisting of three orthogonal (vectorial) accelerations. The magnitude of A is used to compare the relative severity of earthquakes.

Page 283 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY llqfiORMA'f'IOlq Table 4.3.4 Structurally Significant Loadings (SSL) for HI-TRAC CS Structural Affected part or Acceptance Loading Description of Loading Interfacing structure criterion Case SSL-1 Dead weight of the loaded Lifting trunnions NUREG-0612 HI-TRAC CS [l.2.7]

SSL-2 Site's OBE while the loaded Threaded anchors fastening ASME Section III cask is mounted on a HI- the cask to the CEC structure Subsection NF STORM UMAX VVM embedded in the ISFSI pad [4.5.1] stress and substrate & shell limits for Level B structure of the cask body service condition.

loaded as a canti lever beam SSL-3 Site's OBE while the loaded Threaded anchors fastening ASME Section III cask is mounted on the CTF the cask to the CTB slab & Subsectio n NF surface and anchored to its shell structure of the cask [4.5.1] stress Threaded Anchor Locations body loaded as a cantilever limits for Level B (TAL) beam service condition.

SSL-4 Missile from an extreme Threaded anchors fastening ASME Section III environmental phenomenon the cask to the CEC structure Subsection NF striking the cask while it is embedded in the ISFSI pad stress limits for mounted on the ISFSI pad and substrate & shell Level D service structure of the cask body condition & the loaded as a cantilever beam canister must be retrievable (not jammed inside the cask due to excessive diametral deformation)

Page 284 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION Table 4.3.5 Thermally Significant Loadings (TSL) for HI-TRAC CS Thermally significant Acceptance Description of condition Ref Figure loading Criterion Condition Loaded Canister in HI-TRAC CS with its TSL- 1 Figure 6.4.2 Shield Gate closed (constricted ventilation)

Collapse of the Cask Transfer Building Further (CTB) causing significant blockage of the described in TSL-2 top ventilation by the corrugated sheet metal Subsection See Table from the roof 6.5.2 4.4.1 Further described in TLS-3 Enveloping fire Subsection 6.5.2 Page 285 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMAT ION Table 4.3.6 Governing Structural and Thermal Loadings for HI-STAR 190 during Short Term Operations Loading Loading Acceptance Description ID type Criterion The cask's movement under the OBE must The OBE strikes while the cask loaded Structurally be limited such that it SSL- 1 with the canister is in the CTF cavity (see significant does not impact the Figure 3. 1.lg/h) internal shell of the CTF The max imum fuel cladding temperature The cask is seated in the CTF cavity Thermally must remain below TSL- 1 which limits its heat rejection capacity Significant the Short-Term (see Figure 6.4. 1)

Operation limit (Section 4.4)

The maximum fuel cladding tern perature Thermally The CTB roof collapses while the cask is must remain below TSL-2 significant inside the CTF cavity (see Figure 6.4. 1) the Accident condition limit (Section 4.4)

Page 286 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETAR'1' llqfiORMAilOlq

_ _______ ~________.......

TOP O F GRAOE

~ *

-SPACE A 8PA.CEC SPACED TOP OF GRADE

- 100 FT FIGURE 4.3.1: SUB-GRADE AND UNDER-GRADE SPACE NOMENCLATURE Note 1: Space A is the lateral subgrade space in and around the VYMs which is refilled with CLSM or lean concrete after the construction of the SFP. Space B is the lateral subgrade that extends around the ISFSI. Space C is the under-grade below the SFP. Space D is the under-grade surrounding Space C. P is the distance between the outside VVMs and the edge of the ISFSI pad.

Note 2: As indicated by the title, this figure is provided to show the nomenclature for the various spaces around a HI-STORM UMAX ISFSI. This fi gure is not intended to provide specific dimensions or layout of the site- specific design in this SAR.

Page 287 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION 4.4. ACCEPTANCE CRITERIA FOR CASK COMPONENTS 4.4.1 Stress and Deformation Limits In the ASME Code, plant and system operating conditions are commonly referred to as normal, upset, emergency, and faulted. Consistent with the term ino logy in NRC documents, this SAR utilizes the terms normal, off-normal, and accident conditions.

The ASME Code defines four service conditions in addition to the Design Limits for nuclear components. They are referred to as Level A, Level B, Level C , and Level D service limits, respectively. Their definitions are provided in Paragraph NCA-2142.4 of the ASM E Code. The four levels are used in this SAR as foll ows:

i. Level A Service Limits are used to establish allowables for normal cond ition load combinations.

11. Level B Service L imits are used to establish allowables for off-normal conditions.

111. Level C Service Limits are not used.

1v. Level D Service Limits are used to establish allowables for certain accident conditions.

The ASME Code service limits are used in the structural analyses for defin ition of allowable stresses and allowable stress intensities, as applicable. Allowable stresses and stress intensities of materials required for structural analyses are tabulated in Section 4.5. These service lim its are matched with normal, off-normal, and accident condition loads combinations in the foll owing s ubsections.

The following definitions of terms apply to the tables on stress intensity limits; these definitions are the same as those used throughout the ASME Code:

Sm: Value of Design Stress Intensity listed in ASME Code Section II, Part D, Tables 2A, 2B and 4 Sy: Minimum yie ld strength at temperature Su: Minimum ultimate strength at temperature The fo llowing stress limits are applicable to the SSCs at the HI-STORE CIS fac ility:

i. Canisters: The MPC confinement boundary is required to meet Section Ill, Class l ,

S ubsection NB stress intensity limits. Because the MPCs (canisters) are certified to loads in their native docket [1.0.6] that bound those at the HI-STORE site, it is not necessary to re-perform their stress qualifications. Accordingly, the stress intensity limits for the M PC are not presented in this SAR.

ii. HI-STORM UMAX CEC and Closure Lid: The applicable Code for stress a nalysis is ASME Section III, Subsection NF. Because the HI-STORM UMAX structure has been qualified to loads tha t uniformly bo und those at the HI-STORE site, it is not necessary to re-qualify the HI-STORM UMAX structure to the site specific loads in this SAR.

Page 288 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOL.TeC PROPRleTARY ll'>IFORMATIOl'>I 111. Load bearing ancillaries: All structurally significant ancillaries are qualified to ASME Section III Subsection NF. The stress limits for the different service conditions are listed in Table 4.4.2. Appendix 4.A provides a summary of specific stress categories extracted from the Code for NF structures 1v. Lifting and handling equipment: The applicable codes and req uirements are provided in Section 4.5.

v. Special handling devices: ANSI N14.6 [1 .2.4] applied. Detailed requirements are provided in Section 4.5.

4.4.2 Thermal Limits The thermal acceptance criteria for all components are identical to the design criteria described in Section 4.3.

4.4.3 Dose Limits The off-site dose for normal operating conditions to any real individual beyond the controlled area boundary is limited by 10CFR72.104(a) for normal conditions and 10CFR72.106 for accident conditions (including contributions from all Short-Tenn operations) at the HI-STORE CTS facility.

Table 4.4.3 provides the numerical dose limits.

Page 289 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY l~lFORMATION Table 4.4.1: Permissible Temperature Limits for HI-TRAC CS and CTF Materials (Note 4)

Short Term Operations, Deg. F. Accident ITEM Notes Condition, Deg. F.

(Note 1) 300 650 Shielding Concrete Note 3 (section average) (local maximum)

All steel weldments in casks and structures used at 600 700 Note 2; Note 3 HI-STORE Note 1: Short term operations include all activities in the CTB and at the ISFSI to effectuate canister transfer and onsite translocation.

Note 2: For accide nt conditions that involve heating of the steel structures and no mechanical loadi ng (such as the blocked air duct accident), the permissible metal temperature of the steel parts is defined by Table lA of ASME Section II (Part D) for Section III, Class 3 materials as 700°F Note 3: For the ISFSI fire event, the local temperature limit of concrete is l 100°F (HI-STORM 100 FSAR Appendix l.D [1.3.3]), and the steel structure is required to remain physically stable (i.e., so there will be no risk of structural instability such as gross buckling, the maximum temperature shall be less than 50% of the component' s melting temperature and the specific te mperature limits in this table do not app ly).

Concrete that exceeds 1100°F shall be considered unavailable for shielding of the overpack.

Note 4: The temperature limits of MPC components and its contents including fuel cladding under short-term operations are provided in Table 2.3.7 of the HI-STORM UMAX FSAR [l.0.6].

Page 290 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY l~lFORMATION Table 4.4.2: Stress and Acceptance Limits for Different Loading Conditions for the Primary Load Bearing Structures in the Steel Weldments of Casks (Adapted from Table 2.2.12 of HI-STORM FW FSAR (1.3.7])

STRESS DESIGN+

OFF-NORMAL ACCIDENT CATEGORY NORMAL Primary Membrane, Pm s 1.33* S Primary Membrane, Pm, plus Primary l.S*S 1.995-S See Note 1 Bending, Pb Shear Stress 0.6-S 0.6-S (Average)

Note 1: Under accident conditions, the cask must maintain its physical integrity, the Joss of solid shielding (lead, concrete, steel, as applicable) sh all be minimal and the Canister must remain recoverable.

Definitions:

S = Allowable Stress Value for Table lA, ASME Section II, Part D.

Sm = Allowable Stress Intensity Value from Table 2A, ASME Section II, Part D Su= Ultimate Stress Page 291 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLT EG PROPRIETARY INFORMAT ION Table 4.4.3: Radiological Site Boundary Requirements from 10CFR72 (Reproduced from Table 2.3.1 of HI-STORM FW FSAR [1.3.7])

MINIMUM DISTANCE TO BOUNDARY OF 100 CONTROLLED AREA (m)

NORMAL AND OFF-NORMAL CONDITIONS:

-Whole Body (mrem/yr) 25

-Thyroid (mrem/yr) 75

-Any Other Critical Organ (mrem/yr) 25 DESIGN BASTS ACCIDENT:

-TEDE (rem) 5

-DDE + CDE to any individual organ or tissue (other 50 than lens of the eye) (rem)

-Lens dose equivalent (rem) 15

-Shallow dose equivalent to skin or any extremity 50 (rem)

Page 292 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMATIOM Table 4.4.4 HI-STAR 190 Materials Temperature Limits Short-Term Temperature Accident Temperature Component Limits<a> Limits<a>

oc (OF) oc (OF)

Fuel Basket 500 (932)<b) 500 (932)<b)

DFC 570 (1058)(b) 570 (1058)<b)

Basket Shims and 500 (932)<b) 500 (932)Cb)

Solid Shim Plates MPC Shell 427 (800)<b) 427 (800)<b)

MPC Lid 427 (800)<b) 427 (800)Cb)

MPC Baseplate 427 (800)Cb) 427 (800)Cb)

Containment Shell 232 (450)<c) 371 (700)<d) 371 (700) (Structural Containment Bottom 232 (450)<c) Accidents)<d) and Top Forgings 788 (1450) (Fire Accident<e) 371 (700) (Structural Closure Lid 232 (450)<c) Accidents)Cd) 788 (1450) (Fire AccidentCe) 371 (700) (Structural Remaining Cask 232 (450)<c) accidents)

lf=ORMATIOl'>I welding shall comply with [4.5.3] or [4.5.4]. The VCT shall be manufactured in accordance with the provisions of [4.5.5]. Slings shall comply with the provisions of [4.5.6]. 4.5.3.3 Structural The following structural requirements apply to the components comprising the HI-STORE CIS facility VCT:

1. All materials used in the design of the overhead beam and lifting towers shall be ASTM approved or equal and shall be consistent with the ITS category of the part.

11. Prevention of a cask or canister drop is afforded by design conformance with NUREG-0612 [1.2.7] and ANSI Nl4.6 [l.2.4] combined with enhanced safety margins and the use of redundant drop protection features, such as hydraulic check valves and a fai l-safe electrical control system;

m. The VCT vehicle frame shall be designed in accordance with applicable industry standards such as ASME Section III, Subsection NF, for Class 3, li near-type supports or equivalent, or AISC [4.5.9];

1v. T he overhead beam, lifting attachments, and MPC downloader pulley/pins and/or other attachments shall be designed in accordance with ANSI Nl4.6 [l.2.4] and the applicable guidance of NUREG -0612 [l.2.7], Section 5. 1.6. The safety factor shall be based on the lower of l/61h the yield strength or 1110th the ultimate strength ;

v. Jacks shall be designed in accordance with ASME Section III, Subsection NF, for Class 3, Linear-Type Supports [4.5.1) and ASME B30. 1 [4.5.8] with design safety factors consistent with the guidance of NUREG-0612 [1.2.7], Section 5.1.6 (l)(a) for the specific load lifted. Multi-stage jacks may have several rated capacities based on the extension stage. The jacks' rated capacity shall be coupled with the load based on the jack configuration for the lift of the load.

vi. The applicable Design Basis dead weight and seismic loadings on the VCT are listed in Table 4.5.3. The VCT shall be shown to not tip-over under any specified service condition. The vehicle's lateral and transverse center of gravity shall be lower than the HI-TRAC's lateral and transverse center of gravity while transporting a loaded HI-STORM. Tip-over shall assume a 7% transverse grade in all modes. A national consensus standard such as ASCE 43-05 [5.4.5] shall be used for stability evaluation. The seismic restraints and their attachment points on the VCT frame shall be designed to meet the Level D stress limits of ASME Subsection NF. 4.5.3.4 Functional Requirements The VCT shall be operated and controlled by means of a control panel. The control panel shall be suitably positioned to allow for easy access and operator visibility during cask engagement, lifting, movement, and lowering. The control panels shall be enclosed or suitably protected from weather conditions. From the operator's chair, the operator shall be able to see all gauges and indicators necessary to accurately monitor the condition of both the power source and the hydraulic system at all times. The VCT shall be equipped with a dead man's throttle. Page 299 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROPRIETARY l~lFORMATIOl'>I The VCT shall be equipped with an emergency stop switch tethered to the rear of the vehicle by means of a retractable cord reel. The emergency stop switch shall be easily and sagely carried and operated by ground personne l walking behind or to either side of the VCT. The VCT shall be equipped with fl ashing movement warning lights and audible alarm with a minimum 30' range. The VCT shall be capable of being towed and secured against movement in the event that it becomes inoperable during transit. The design shall ensure that any electrical malfunction in the control system, motors, or power supplies will not lead to an uncontrolled lowering of the load. Portable fire extinguisher(s) meeting the requirements of NFPA 10 [4.5.7, 4.5.12]. A catch pan or a double wall fuel tank with a hose connection to route spills away from the VCT shall be mounted beneath the fuel tank. The VCT shall be equipped with auxiliary power receptacles. Voltage, frequency, amperage ratings, and receptacle shall be specified by Holtec to meet site specific requirements. 4.5.3.5 Thermal The VCT does not operate in an elevated temperature environment. The design temperature of the VCT is conservatively specified in Table 4.5.3 to be well above the maximum ambient temperature in the CTB, on the VCT haul path, and the ISFSI pad. 4.5.3.6 Shielding The VCT does not provide a shielding function. 4.5.3.7 Confinement The VCT does not provide a confinement fun ction. 4.5.3.8 Criticality Control The VCT does not perform a ny criticality control function. 4.5.3.9 Material Failure Modes All materials used in the design of the overhead beam and lifting towers shall be ASTM approved or equal and shall be consistent with the ITS category of the part. The material properties and allowable stress values for all structural steel members shall be taken from the applicable national consensus standard. Acceptance criteria for the Charpy testing requirements for the overhead beam, lifting towers, cask transporter lift points and MPC downloader system load bearing components shall be per ASME Section III, Subsection NF [4.5.1) or ANSI N14.6 [1.2.4]. The lowest service temperature used for developing the test parameters for Charpy testing shall be equal to 0°F for all the components mentioned above. Lateral expansion will be per Table NF-233 l (a)-3 and required Cv energies shall be extrapolated from Fig. NF-2331(a)-2 for Class 3 M ateria ls. Page 300 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROF'RIETAR ( llqfiORMATIOM Fatigue failure modes of primary structural members whose failure may result in the uncontrolled lowering of the load shall be evaluated. A minimum safety factor of 2 on the number of permissible loading cycles (1000 loading cycles) for critical members shall apply. 4.5.3.10 Environmental Conditions The ambient conditions for the VCT are summarized in T able 4.5.3. The design of the VCT shall preclude materials that may degrade under the radiation from casks during the service life. 4.5.4 Miscellaneous Ancillaries Miscellaneous ancillaries are those weldments that are no t used in a load lifting function and do not contain or in contact with fissile material. Such ancillaries do not render a confinement or criticality function. Certain ancillaries, however, are used to reduce crew dose such as tungsten screens and lead blankets. S uch non-structural ancillaries are also called "accessories" because their design is guided by ALARA , not by any regul ato ry regimen. The miscellaneous ancillaries are subject to mechanical loadings under any operating modes shall meet the following design criteria:

1. T he Design loads and associated applicable to the ancillary under normal and accident conditions (if any) shall be defined based on its function and application.

11. ASME Section III Subsectio n NF Class 3 is designated as the governing code fo r purposes of stress analysis of the anci llary. Specifically, Subsection NF shall be used to demonstrate:

a. Compliance with the Code stress limits

b. Absence of the risk of brittle fracture at low service conditions (See Table 2. 7. l )

c. Absence of elastic instability effects such as buckling

d. Absence of the risk of fatigue failure 111. T he load rating and maximum/minimum operating temperature for the ancillary shall be marked on the ancillary.

The stress and strength tables for common materials used in the manufacturing of ancillaries have been extracted from (1. 3.3] and are provided in this sub-section. Page 301 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY l~lFORMAT ION Table 4.5.1 Design Basis Loadings on the Cask Crane inside the CTB Item Value Comment Bounds the weight of all Design Basis Dead Load 200 tons heavy loads lifted by the crane The seismic motion is applied Operating Basis Earthquake See Table 4.3.3 at the elevation of the CTB (QBE) Slab Conservative upper bound on Reference temperature 150 Deg. F. the maximum ambient temperature Page 302 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEG PROPRIETARY l~lFORMATION Table 4.5.2 Design Parameters for the CTB Crane Specification Specification Description Component Type per Main Ho ist: Type I ASME NOG-1-201 5 Aux iliary Ho ist: Type II [3.0.1] Gantry: Type I Trolley: Type I Service Factor Main Hoist, Gantry, and Trolley: To meet or exceed minimum requirements as provided in ASM E NOG-01 [3.0.1]; Auxiliary Ho ist: CM AA 70 [4.5.2]: CM AA Class D M aterial of Construction Carbon steel frame, commercial winch and trolley components. Main H oist Capacity 200 ton minimum A uxiliary H oist 20 tons Hook Type Duplex (sister) hook with p in eye Crane Speed (reference) 45 feet /min (infinitely variable speed control with minimum 30:l speed range) Trolley Speed (reference) 35 feet/ min (infi nitely vari able speed control with minimum 30:1 speed range) Main Hoist Speed 5 feet/min (infinitely variable speed control with minimum 100:1 (reference) speed range) Auxiliary Hoist Speed 20 feet/min (infinitely variable speed control with minimum (re ference) 100:1 speed range) Operator Controls R adio Control - To operate on Frequencies as allowed by local codes. Pendent backup with quick disconnect and full length festoon. M ain H oist Reeving Single Failure Proof reeving - True Vertical Lift Single o r Double reeving. If double reeving is used, ropes must A uxiliary H ois t Reeving be equalized using an equalizer sheave or bar. Motor Controls Variable F requency Drives with infinite s peed control. Page 303 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL.TeC PROPRleTARY ll'>IFORMATIOl'>I Table 4.5.2 Design Parameters for the CTB Crane Specification Specification Description General Additional Safety 1. Overload protection for critical loads and maximum capacity Devices of each hoist. Critical load overload protection shall be field adjustable. Approximate values are provided in this document.

2. Slack Rope protection (underload) for critical loads with over-ride for lowering of the load. Settings should be field adjustable. Approx imate values are provided in this document.

3. Over Speed protection for critical loads.

4. Gantry end of travel limit switches with slowdown and stop.

5. Trolley end of travel limit switches with slow down and stop.

6. Audible alarms

7. Visual alarms (lights)

8. Fail-Safe Emergency Stop (pendant, radio control, and operating floor)

Gantry Service Platform Walkway/Service Platform mounted to one side of the crane along the entire length of the span. An entry way to be coordinated with the crane access point is to be provided for safe personnel access to the platform. All electrical control enclosures shall be serviceable from the platform. Trolley Service Platform Walkway/Service Platform to allow inspection and service to hoist and trolley components. Access to the platform is to be provided from the gantry platform for safe personnel access. Gantry Bumpers Energy absorbi ng bumpers sized to decelerate and stop the while traveling without power at 40% of the rated load speed at a rate of deceleration not to exceed an average of 0.91 m/s 2 (3 ft/sec 2) . Trolley Bumpers Energy absorbing bumpers sized to decelerate and stop the while traveling without power at 50% of the rated load speed a t a rate of deceleration not to exceed an average of 1.4 m/s2 ( 4. 7 ft/sec2). Lighting LED Gantry Crane Lighting for operators and others working under the crane. As needed by Manufacturer to meet hook coverage Runway Rail and End requirements, including all fastening hardware, splices, and end-stops stops. Page 304 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION Table 4.5.2 Design Parameters for the CTB Crane Specification Specification Description Power 3 phase, 380V, 50 Hz. Power Disconnect Floor Mount Power Disconnect lockable in the open position Runway Electrification Sliding Double Shoe Collectors and Buss Bar Coatings ASME NOG-01 [3.0.1]; Service Level II Page 305 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY llqfiORMAT IOM Table 4.5.3 Design Basis Conditions and Loadings on the Vertical Cask Transporter Item Value Comment Bounds the weight of the loaded HI-Design Basis Dead Load 200 tons TRAC CS along with the associated lifting hardware Bounding weight per HI-STORM UMAX Maximum Loaded MPC 110,000 lbs FSAR [1.0.6] Table 3.2. 1 Operating Basis Earthquake The seismic motion is applied at the See Table 4.3.3 (OBE) elevation of the Haul Path slab Upper bound on the maximum ambient Design Temperature 150 Deg. F. temperature Design Life 20 years Normal life expectancy of the VCT Maximum permitted service 125 Deg. F Limiting environmental temperature temperature Minimum permitted service 0 Deg. F. Limiting environmental temperature temperature Design Basis Relative humidity range at Relative humidity range 0 to 100% the s ite Maximum design basis incline or grade in the haul 10% path Used to size the engine and transmission system of the VCT Maximum design basis lateral 7% grade Page 306 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLT EG PROPRIETARY INFORMAT ION Table 4.5.4: Design and Level A Stress Code: ASMENF Material: SA516, Grade 70, SA350-LF3, SA203-E Service Conditions: Design and Level A Item: Stress Classification and Value (ksi) Temp. (Deg. F) Membrane plus s Membrane Stress Bending Stress -20 to 650 17.5 17.5 26.3 700 16.6 16.6 24.9 Notes:

1. S = Maximum allowable stress values from Table IA of ASME Code,Section II, Part D.

2. Stress classification per Paragraph NF-3260.

3. Limits on values are presented in Table 4.4.2.

4. Table reproduced from [1.3.3), Table 3. 1.10 Page 307 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Table 4.5.5: Level B Allowable Stress Code: ASME NF Material: SA516, Grade 70, SA350-LF3, and SA203-E Service Conditions: Level B Item: Stress Classification and Value (ksi) Temp. (Deg. F) Membrane plus Membrane Stress Bending Stress -20 to 650 23.3 34.9 700 22.l 33.l Notes:

1. Limits on values are presented in Table 4.4.2 with allowables from Table 4.5.4.

2. Table reproduced from [1.3.3], Table 3.1.11 Page 308 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATION Table 4.5.6: Level D Str ess Intensity Code: ASMENF Material: SAS16, Grade 70 Service Conditions: Level D Item: Stress Intensity Classification and Value (ksi) Temp. (Deg. F) Sm Pm Pm+ Pb -20 to 100 23.3 45.6 68.4 200 23. 1 41.5 62.3 300 22.5 40.4 60.6 400 21.7 39. 1 58.7 500 20.5 36.8 55.3 600 18.7 33.7 50.6 650 18.4 33.1 49.7 700 18.3 32.9 49.3 Notes:

1. Level D allowable stress intensities per Appendix F, Paragraph F-1332.

2. Sm = Stress intensity values per Table 2A of ASME,Section II, Part D.

3. Table reproduced from (1.3.3), Table 3. 1.12 Page 309 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 l:iOLTEC PROPRleTARY INFORMAT ION Table 4.5.7: Design and Level A Stress Code: ASMENF Material: SA36 Service Conditions: Design and Level A Item: Allowable Stress Classification and Value (ksi) Temp. (Deg. F) Membrane plus s Membrane Stress Bending Stress -20 to 650 14.5 14.5 2 1.8 700 13.9 13.9 20.9 Notes:

1. S = Maximum allowable stress values from Table l A of ASME Code,Section II, Part D.

2. Stress classification per Paragraph NF-3260.

3. Table reproduced from [1.3.3], Table 3. 1.19 Page 310 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Table 4.5.8: Level B Allowable Stress Code: ASMENF Material: SA36 Service Conditions: Level B Item: Allowable Stress Classification and Value (ksi) Temp. (Deg. F) Membrane plus Membrane Stress Bending Stress -20 to 650 19.3 28.9 700 18.5 27.7 Notes:

l. Table reproduced from [ 1.3.6, Table 3. 1.20]

Page 311 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION Table 4.5.9: Level D Str ess Intensity Code: ASMENF Material: SA36 Service Conditions: Level D Item: Stress Intensity Classification and Value (ksi) Temp. (Deg. F) Sm Pm Pm+ Pb -20 to 100 19.3 43.2 64.8 200 19.3 37.0 55.5 300 19.3 36.0 54.0 400 19.3 34.7 52.1 500 19.3 32.8 49.2 600 17.7 30.0 45.0 650 17.4 29.5 44.3 700 17.3 29.2 43.8 Notes:

1. Level D allowable stress intensities per Appendix F, Paragraph F-1332.

2. Sm = Stress intensity values per Table 2A of ASME,Section II, Part D.

3. Table reproduced from (1.3.3), Table 3. 1.21 Page 312 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMAT IOM ORI\IE SYSTEM TRAN SPORTER MAI N FRPM E FIGURE 4.5.1: VCT MAJOR COMPONENTS Page 313 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL'fEC PROPRIETARY INFORMAT ION FIGURE 4.5.2: VCT CARRYING A HI-TRAC TRANSFER CASK Page 314 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC F'~OF'RIETARY INFORMAT ION LIFTING ATTACHMENT DOWNLOAD ER PULLEYS DOWNLOAD ER SLINGS FIGURE 4.5.3: ILLUSTRATIVE VIEW OF THE VCT OVERHEAD BEAM AND CANISTER DOWNLOADER PULLEY SYSTEM Page 315 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOL'fEC PROPR:IE'fAR:'1' INFORMATION 4.6 DESIGN CRITERIA FOR THE CASK TRANSFER BUILDING (CTB) 4.6.1 Design Features of the CTB The Cask Transfer Building (CTB) is a NITS structure at the HI-STORE CIS fac ility. It serves as a weather enclosure for the cask handling equipment, facilities and structures, all of which are floor mounted. The CTB Crane, summarized in Section 4.5, is a gantry crane mounted on a set of rails founded on the CTB 's slab. The layout of the equipment and ancillaries in the CTB is provided in Figure 3. 1.2 of Chapter 3. Chapter 10 contains the summary of the operations that are envisaged to occur in the CTB. The CTB is a conventional sheet metal building consisting of a thick load bearing concrete slab mentioned above and a set of knee-high concrete walls which support the steel frame that serves as the backbone for the build ing. Corrugated sheet metal panels are fastened to the steel frame to create the lateral enclosure system. An overhead truss provides the framework to support the roof, also made of corrugated sheet metal. The CTB is designed to the provisions of [4.6. 1] and New Mexico's state and local Building Codes. The building steel (wall and roof structures) design is informed by the load combinations and criteria in IBC-2015 [4.6.4] and ASCE 7- 10 [4.6.2]. While the CTB renders no safety fu nction, it houses safety-significant equipment. Therefore, under an extreme environmental phenomenon, such as high wind, it is necessary to postulate that its roof collapses and falls on the ITS SSCs below. Table 4.6. 1 provides loading data for designing the CTB walls and roof structure; this data is used in the bu ilding coll apse evaluation in Chapter 5. 4.6.2 CTB Slab The CTB is founded on a thick reinforced concrete slab whose essential design data is summarized in Table 4.6.2. The CTB slab is designed to the following governing dead and live loads: (i) The live load from the railroad car wheels carrying the loaded transport cask (ii) The live load from the CTB Crane carrying the transport or the HI-TRAC CS cask (ii i) The live load from the loaded VCT (Figure 4.5.2) The CTB slab is designed to meet the strength require ments of ACI 3 18-05 [5.3. 1] for the following governing load combinations: Load Combination # 1: 1.40 Load Combination # 2: 1.20 + l.6L Load Combination # 3: 1.20 + L + E where D is the dead load of the CTB slab including long-term settlement effects, Lis the live load acting on the CTB slab (including weight of VCT, CTB Crane, etc.), and Eis the OBE for the site. Page 316 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Table 4.6.2 provides the essential design data for the CTB slab which is used in Chapter 5 to demonstrate its compliance with ACI-318 using bounding values of loadings (live and seismic). Page 317 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY l~lFORMAT ION Table 4.6.1 Reference Design Basis Loading Data for the CTB Item Value Comment Used to size the wall and roof structures in Chapter 5; based on IBC Ultimate Design Wind Speed, V u11 ll5 mph 20 15 Risk Category II building classification Nominal Design Wind Speed, Y asd 90mph Reference Weight of a CTB Roof U sect in the safety analysis of the ITS Truss that may fall on the ITS 32,400 lb equipment from collapse of the CTB in equipment Chapter 5 Used in the safety analysis of the ITS Design Basis Height of the CTB 66 feet equipment from collapse of the CTB in Roof Truss above CTB floor (20 meters) Chapter 5 Page 318 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMATIOM Table 4.6.2 Reference Design Data for the CTB Slab Item Reference value Minimum Compressive strength of concrete 4,500 psi Min Slab thickness 36 inches Size of re-bars in the two orthogonal directions #11 Re-bar nominal spacing 10 inch Minimum concrete cover on the re-bar assembly (both faces) 3 inch Minimum thickness of the e ngineered fill (or mud mat) 12 inch undergirding the slab Page 319 of 689 Revision OC May 2018 ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY INFORMATION 4.7

SUMMARY

OF DESIGN CRITERIA The Design Criteria set down in this chapter seek to ensure that during any condition of storage (normal, off-normal or accident) and during canister transfer operations, the following metrics of safety will be observed:

i. The confinement boundary is not breached.

11. There is no risk of exceeding the neutron multiplication factor limit of 0.95 including all uncertainties and biases.

111. The temperature of the used fuel remains below the limit set forth in ISG- 11 , Rev. 3 [4.0. l]

which insures that the fuel will not undergo any significant degradatio n in storage.

1v. The stresses in the primary structural members rema in within the applicable ASME code limits under every condition of storage.

v. T he accreted site boundary radiation dose from the storage system meets the 72.104 &

10CFR 72.106 limits for the normal and accident conditions, respectively.

v1. The occurrence of an accidental load drop event is rendered non-credible by the use of single failure proof lifting and handling devices.

vu. There is no risk of brittle fracture of a primary load bearing member in the storage system under all storage scenarios.

viii. There is no risk of fatigue failure in a load bearing member under all applicable storage scenarios.

1x. There is no risk of structural instability (buckling), large deformation or similar non-linear behavior in any primary load bearing member during any (normal, off-normal and accident) condition of storage.

The above criteria are fulfilled either by reference to the HI-STORM UMAX FSAR [l .0.6] or by the safety analyses performed in support of this SAR. For the latter case, the justification for relying on the safety analysis in [1.0.6] is provided.

In particular, the information presented in this chapter shows that every loading germane to long term storage of Canisters in the HI-STORM UMAX VVM at a HI-STORM UMAX ISFSI, as described in the HI-STORM UMAX FSAR [1.0.6], eit her equals or bounds its site-specific counterpart for the HI-STORE CIS ISFSI. Likewise, the structural margins of safety in the short-term operations involving the HI-STAR transfer cask have been quantified in the HJ-STORM UMAX FSAR for a much stronger seismic event than the Design Basis Earthquake (10,000 year return earthquake) applicable to the HI-STORE site. Finally, the Design Criteria set down in Chapter 4 of this SAR for the non- certified SSCs such as the vertical cask transporter, gantry crane and special lifting devices are identical to those specified for such components in other HI-STORM dockets [l.3.3, l.3.7].

Therefore, the safety analyses for all aspects of safe deployment and storage of HI-STORM UMAX at the HI-STORE s ite, including structural, criticality, thermal and confinement are Page 320 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY llqfiORMAilOlq substantially pre-empted by the qualifications in the HI-STORM UMAX FSAR making a re-evaluation for HI-STORE unnecessary. The only exceptions are:

1. The site boundary dose qualification which must be performed to demonstrate compliance with the 10CFR72.104 dose limits under the maximum fuel inventory scenario, i.e., when every storage location in the ISFSI is occupied.

11. The temperature of the fuel within the stored cani ster at the HI-STORE ISFSI will meet the normal storage condition limit ofISG-11, Rev. 3. This analysis is required because the high altitude of the ISFSI (Table 2.7. 1) reduces the air ventilation rate. The maximum heat load, however, is limited by the rating of the transport cask which is substantially Jess than the thermal capacity of HI-STORM UMAX licensed by the USNRC (Docket# 72-1040).

Therefore, the ISG temperature limit is expected to be met with a large margin.

Nevertheless, to support the safety case, this margin is quantified in Chapter 6.

In addition, a new transfer cask, named HI-TRAC CS has been introduced in this docket. Whi le the design of this transfer cask is similar to the other HI-TRAC models certified in other HI-STORM dockets, viz. [1.0.6, 1.3.3, 1.3.7], there are sufficient physical differences to wanant a safety analysis of HI-TRAC CS to be performed. The applicable design criteria for such analyses are prov ided in this chapter.

Finally, all ancillaries must meet the design criteria presented in Section 4.5.

Page 321 of 689 Revision OC May 2018

A TTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY IMFOR MATIOM APPENDIX 4.A: STRESS LIMITS FOR ASME SECTION III, SUBSECTION NF LINEAR STRUCTURES AND PLATE & SHELL TYPE STRUCTURES (b)(4)

Page 322 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATION (b)(4)

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION (b)(4)

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC F'~OF'RIETARY INFORMATION (b)(4)

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY llqFO~MATION 4.A.2 STRESS LIMIT CRITERIA FOR PLATE AND SHELL STRUCTURES (b)(4)

Page 326 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC F'~OPRIE I ARV INFORMATION (b)(4)

Page 327 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION CHAPTER 5: INSTALLATION AND STRUCTURAL EVALUATION*

5.0 INTRODUCTION

The HI-STORE CIS fac ility util izes the subterranean canister storage system referred to as HI-STORM UMAX certified in NRC Docket #72-1040 [1.0.6]. As the safety determination in this chapter shows, from the structural standpoint, the HI-STORM UMAX design can be adopted in its entirety from its native docket for the HI-STORE CIS facility without the need for any modification . The basis for this adoption, as elaborated in this chapter, is supported by the existing structural qualifications of the HI-STORM UMAX system that have been previously reviewed by the NRC and which un~formly bound all HI-STORE CIS site-specific loadings.

However, while the safety analyses for HI-STORM UMAX can be adopted for HI-STORE, that is not the case for the ancillary systems, structures and components (SSCs) needed to operate the facility. These ancillaries are listed and their operational roles are summarized in S ubsection 1.2.7. In this chapter, the structural safety qualification of each ancillary envisaged to be used at HI-STORE CIS, showing its compliance with its Design Criteria (presented in Chapter 4), is documented. The computed design margin for the ancillary SSCs under their respecti ve design basis loads along with the safety analyses in the HI-STORM UMAX FSAR for the certified storage system underpins the safety case for the HI-STORE site.

The HI-STORM UMAX system as licensed in Docket # 72-1040 allows for a variable depth canister storage cavity to accom modate canisters of different heights. At the HI-STORE CIS site, all the storage cavities will be built to the same fixed depth, which is within the design limits of the licensed HI-STORM UMAX system. The structural qualification of HI-STORM UMAX in Docket# 72-1040 is based on the tallest and heaviest MPC-37 canisters (South Texas) because they define the bounding inertia loads. The Licensing Drawings in Section 1.5 of this SAR contain the depictions of the fixed depth HI-STORM UMAX cavity adapted from Docket #72-1040. For structural purposes, the deepest cavity to store the longest and heaviest canister defines the governing configuration. In Table 5.0.1 , a comparison of the Design Basis Loads (DBLs) in its generic FSAR [l.0.6] and their site specific loading counterparts is presented to demonstrate that the Design Basis structural loads bound the site specific loads (SSLs) in every instance.

Therefore, fresh qualifying analyses for the storage system at the HI-STORE insta llation, in addition to those in [5.4.7], are not necessary.

The bounding weights for the various dry cask storage components and ancillary eq uipment used at the HI-STORE CIS facility are listed in Table 5.0.2.

Finally, to facilitate convenient access to the referenced material, a list of sections germane to this chapter is provided in a tabular form. Table 5.0.3 provides a listing of the material adopted in this chapter by reference from other licensed dockets.

All references are placed within square brackets in this report and are compiled in Chapter 19 of this report.

Page 328 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC PR:OPR:IETAR:Y IMFORMATIOM Table 5.0.1: Comparison of DBLs for HI-STORM UMAX System and Site-S oecific Loads for HI-STORE CIS Facility Load Category Design Basis Value Site-Specific Value Top of the Grade (Ground surface) spectra per Figure 2.4.1 of [1.0.6] with horizontal ZPA, aH, and vertical ZP A, av scaled as fo llows:

Top of the Grade spectra aH = l.Og corresponding to 5% damped av = 0.75g RG 1.60 earthquake [4.3.2]

Earthquake scaled to 0.25g (bounding) in and foundation surface pad three orthogonal directions spectra per Figure 2.4.2 of (see Table 4.3.3)

[l.0.6] with horizontal ZPA, aH, and vertical ZP A, av of:

a1-1 = 0.93g av= 0.71 g Consistent with NRC Regulatory Guide 1.76 Tornado Per Table 2.3.4 of [1.0 ..6]

[2.7. 1], ANSI 57.9 [2.7.2],

and ASCE 7-05 [4.6.1]

Floodwater depth less than 1 Flood Floodwater depth of 125 feet.

foot Snow Load 100 psf See Chapter 2 Page 329 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HObTeC PROPRleT/1.RY ll'>IFORMATIOl'>I Table 5.0.2: Bounding Weights for Cask Components and Ancillary Equipment Component Bounding Weight, !bf Loaded MPC 110,000 HI-TRAC CS Transfer Cask (b)(4)

- Empty

- Loaded with MPC HI-STAR 190 Transport Cask

- Empty w/o Impact Limiters 261,000

- Loaded w/o Impact Limiters 371,000

- Loaded w/ Impact Limiters 414,800 (b)(4)

HI-TRAC CS Lift Yoke Transport Cask Lift Yoke Transport Cask Horizontal Lift Beam --

Transport Cask Tilt Frame MPC Lift Attachment MPC Lifting Device Extension HI-TRAC CS Lift Links (set of 2)

YCT Notes:

1) All structural analyses presented in Chapter 5 use the bounding weights per this table as input. Higher values may be used for additional conservatism.

2) Assumed based on standard tracked crawler design used at various nuclear plants in U.S.

Page 330 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION Table 5.0.3: Material Incorporated by Reference in this Chapter Information Source of the Location in this Technical Justification of Applicability to HI-Incorporated by Information SAR where STORM UMAX at HI-STORE CIS Reference Material is Incorporated MPC-37 and MPC-89 Section 3.4 Subsection 5.1.4 The canister is identical to the one described in the HI-Structural Evaluation HI-STORM FW FSAR STORM FW FSAR and originally approved in the

[1.3.7] referenced FSAR.

HI-STORM UMAX Paragraph 3.4.4.1 HI- Paragraph 5.3.1.4 The ISFSI Pad and SFP are identical to that described ISFSI Pad and SFP STORM UMAX FSAR in HI-STORM UMAX FSAR and originally approved Structural Evaluation [1.0.6] in the referenced FSAR. Also, the Design Basis Loads for the HI-STORM UMAX bound the site-specific loads applicable to the HI-STORE site as shown in Table 5.0.1.

HI-STORM UMAX Paragraph 3.4.4.1 HI- Paragraph 5.4.1.4 The HI-STORM UMAX VVM is identical to that VVM Structural STORM UMAX FSAR described in HI-STORM UMAX FSAR and originally Evaluation [1.0.6] approved in the referenced FSAR. Also, the Design Basis Loads for the HI-STORM UMAX bound the site-specific loads applicable to the HI-STORE site as shown in Table 5.0.1.

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ATTACHMENT 2 TO HOL TEC LETTER 5025025 I !OLTEC PROPRIETARY l~lFORMAT ION 5.1 CONFINEMENT STRUCTURES, SYSTEMS, AND COMPONENTS The only confinement SSC that is utilized at the HI-STORE CIS facility is the Multi-Purpose Canister (MPC). There are two types of MPCs that are permitted to be stored at the HI-STORE site, namely MPC-37 and MPC-89, both of which have been previously licensed by the NRC as part of the HI-STORM FW dry storage system (Docket # 72-1032). The structural design basis for MPC-37 and MPC-89, which are used to store PWR and BWR fu el, respectively, are described in complete detail in Chapters 2 and 3 of the HI-STORM FW FSAR [1.3.7]. A brief summary of their structural design basis is provided below.

5.1.1 Description of Structural Design The MPC enclosure vessels are cylindrical weldments with identical and fixed outside diameters.

Each MPC is an assembly consisting of a honeycomb fuel basket, a baseplate, a canister shell, a lid, and a closure ring. The number of SNF storage locations in an MPC depends on the type of fuel assembly (PWR or BWR) to be stored in it. The required characteristics of the fuel assemblies to be stored in the MPC are limited in accordance with Section 4.1 of the SAR.

The MPC enclosure vessel is a fully welded enclosure, which provides the confinement for the stored fuel and radioactive material. The MPC baseplate and shell are made of stainless steel.

The lid is a two-piece construction, with the top structural portion made of Alloy X. The confinement boundary is defined by the MPC baseplate, shell, lid, port covers, and closure ring.

Drawings for the MPCs are provided in Section 1.5.

The MPC-37 and MPC-89 fuel baskets are assembled using interlocking Metamic-HT panels, as shown in the Licensing Drawings in Section 1.5.

5.1.2 Design Criteria The MPC is classified as important-to-safety. The MPC structural components include the fuel basket and the enclosure vessel. The MPC enclosure vessel is designed and fabricated as a Class 1 pressure vessel in accordance with Section III, Subsection NB of the ASME Code, with certain necessary alternatives, as discussed in Section 2.2 of [ 1.3. 7]. The MPC fuel basket is a non-Code Compliance with the ASME Code, with respect to the design and fabrication of the MPC, and the associated j ustification are discussed in Section 2.2 of [ 1.3.7]. The MPC design is analyzed for all design basis normal, off-normal, and postulated accident conditions, as defined in Section 2.2 of [l.3.7], which bound the conditions at the HI-STORE site.

5.1.3 Material Properties The MPC shell, baseplate and lid are made of stainless steel (Alloy X, see Appendix l .A of

[l.3.7]). The properties for Alloy X are listed in Table 3.3.l of the HI-STORM F W FSAR

[l. 3.7]. The minimum strength properties for Metamic-HT, which is used to fabricate the fuel baskets, are provided in Table 1.2.8 of the HI-STORM FW FSAR [1.3. 7].

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMA'flON 5.1.4 Structural Analyses The structural analyses for the MPC for all design basis normal, off-normal, and postulated accident conditions are documented in Chapter 3 of the HI-STORM FW FSAR [ 1.3. 7] and further supplemented by the seismic response analysis of the MPC inside the HI-STORM UMAX presented in Subparagraph 3.4.4.1.2 of the HI-STORM UMAX FSAR [1 .0.6).

The fatigue evaluations for the HJ-STORM FW and HI-STORM UMAX Systems, which are found in Subsection 3.1.2.5 of their respective FSARs, remain valid for the proposed 40-year storage term at the HI-STORE CIS Facility. This is because the passive nature and the large thermal inertia of these storage systems protect the MPC enclosure vessel from significant stress cycling. In fact, the amplitude of the stress cycles is well below the endurance limit of the stainless steel MPC, which means that the MPC has infinite fatigue life under long-term storage conditions.

Moreover, as shown in Table 6.3.l of the HI-STORE SAR, the maximum MPC heat loads and the ambient temperature conditions applicable to the HI-STORE CIS Facil ity are less demanding than the conesponding values for which the HI-STORM UMAX System is certified. This reduces stress amplitudes in the MPC at the HI-STORE CIS Facility and ensures that the ASME Code required fatigue evaluations that were originally performed for the UMAX and FW systems remain valid for 40 years of storage at the HI-STORE CIS Facility.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC PROPRIETARY INFORMATION 5.2 POOL AND POOL CONFINEMENT FACILITIES There are no pools at the ID-STORE CIS facility.

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ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATIOM 5.3 REINFORCED CONCRETE STRUCTURES The HI-STORE CIS facility includes the following reinforced concrete structures:

HI-STORM UMAX ISFSI Pad and Support Foundation Pad (SFP)

Cask Transfer Building (CTB) Slab

Canister Transfer Facil ity (CTF) Foundation Each of these components is discussed in more detail, including their description, design criteria, material properties, and struc tural analyses, in the fo llowing subsections.

5.3.1 HI-STORM UMAX ISFSI Pad and Support Foundation Pad 5.3.1.1 Description of Structural Design The HI-STORM UMAX ISFSI pad and Support Foundation Pad (SFP) are integral parts of the HI-STORM UMAX underground dry storage system, which has already been li.censed in accordance with 10CFR72 requirements under NRC Doc ket# 72-1040. As described in Section 1.2 of this SAR, the structural performance objectives for the ISFSI pad are to provide a riding surface for the cask transporter and to serve as a missile barrier. The SFP is the fou ndation mat for the HI-STORM UMAX structure, and it also serves as the resting surface for the VVM array.

As shown on the Licensing Drawing in Section 1.5, the SFP is a continuous concrete pad of uniform thickness, whereas the ISFSI pad fills the interstitial space between the VVM at the top of grade level.

5.3.1.2 Design Criteria The SFP and the ISFSI pad are categorized as important-to-safety (ITS) structures as indicated in Table 4.2.1. ACI 318-05 (5.3. l] is specified as the reference code for the design qualification of the SFP and the ISFSI pad using the load combinations specified in Table 2.4.3 of (1.0.6].

5.3.1.3 Material Properties The ISFSI pad and SFP are reinforced concrete structures with their properties defined in Table 2.3.2 of the HI-STORM UMAX FSAR [1.0.6).

5.3.1.4 Structural Analysis The seismic and structural qualification of the HI-STORM UMAX storage system, including the ISFSI pad and SFP, is performed in Chapter 3 of [1.0.6]. As shown in Table 5.0. 1 above, the design basis loads analyzed in the HI-STORM UMAX FSAR completely bound the site-specific loads applicable to the HI-STORE site, and therefore no new structural analysis is required to qualify the ISFSI pad or the SFP for this application.

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ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMATIOM 5.3.2 Cask Transfer Building Slab 5.3.2.1 Description of Structural Design The Cask Transfer Building (CTB) slab is a reinforced concrete slab, which serves as the structural foundation for the railway and the CTB Crane. provides a riding surface for the VCT inside the CTB, and acts as laydown area for the HI-TRAC CS and other ancillary equipment.

The general layout and key dimensions of the CTB slab are shown on the Licensing Drawing in Section 1.5.

5.3.2.2 Design Criteria The structural design criteria for the CTB slab, including the governing load combinati.ons, are provided in Subsection 4.6.2 of this SAR.

5.3.2.3 Material Properties The material properties for the CTB slab are summarized in Table 5.3.1.

5.3.2.4 Structural Analysis The analysis of the CTB slab is carried out using classical solutions for a slab on grade, which are obtained from [5.3.2], to determine the internal forces and moments acting on the CTB slab for the governing load combinations in Subsection 4.6.2.

The analysis of the slab considers the live loads associated with the freestanding HI-TRAC CS, the VCT, the CTB crane, the tilt frame (loaded with HI-STAR 190 with impact limiters), and the loaded rail car. The load acting on the CTB slab due to the CTB crane and the rail car are applied as concentrated forces at the wheel locations. The YCT load is applied as a uniform distributed pressure over the footprint area of its tracks/wheels. The load on the tilt frame assemibly is also applied as a unifo rml y distributed pressure.

For the seismic load combin ation, the weight of each component (e.g., VCT) is amplified by the vertical ZPA for the Design Basis Earthquake (DBE), which is given in Table 4.3.3. The use of the ZPA value is justified since the DBE is a low-intensity earthquake that does not cause any of the above mentioned equipment to rock/uplift (i.e., no incipient tipping).

The calculated results for each load combination are compared with the ACI Code compl iant section capacities to demonstrate the structural adequacy of the CTB slab. All calculated safety factors for the CTB slab are greater than 1.0 as shown in Table 5.3.2. The complete details of the CTB slab analysis are provided in the Structural Calculation Package [5.4.6].

5.3.3 Canister Transfer Facility Foundation 5.3.3.1 Description of Structural Design The Canister Transfer Facility (CTF) is a below-ground structure used to carry out ver tical MPC transfers from the transport cask to the HI-TRAC CS (or vice versa). The design enables a transport cask to be lowered into the CTF cavity (see Figure 3. l .1 (g)). With the transport cask in place, the HI-TRAC CS is then positioned above the CTF cavity opening and anchor bolts are installed to secure the HI-TRAC CS to the CTB slab at the CTF location, after which the MPC Page 336 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEC F'~OF'RIETARY INFORMAT ION can be vertically lifted from the transport cask into the HI-TRAC CS using the VCT. The general layout and key dimensions of the CTF are shown on the Licensing Drawing in Section 1.5.

At the base of the CTF cavity is a reinforced concrete slab that acts as the supporting surface for the transport cask during transfer operations. T his below-grade slab is referred to as the CTF found ation, and its construction is identical to the CTB slab w ith respect to thickness, strength, and reinforcement details.

5.3.3.2 Design Criteria The design criteria for the CTF foundation, which is an ITS component, are the same as the criteria for the CTB slab, which are provided in Subsection 4.6.2.

5.3.3.3 Material Properties The material properties for the CTF foundation are identical to those for the CTB slab, which are given in Table 5.3.l.

5.3.3.4 Structural Analysis The results for the structural analysis of the CTB slab, which are discussed above in Paragraph 5.3.2.4, are also bounding for the CTF foundation for the following reasons:

a) The construction of the CTB slab and the CTF foundation are identical in terms of their thickness, reinforcement details, and minimum stre ngth properties.

b) The bounding weight of a loaded HI-TRAC CS (which rests vertically on the CTB slab),

used in the structural evaluation [5.4.6], is greater than the bounding weight of a loaded HI-STAR 190 transport cask without impact limiters (which rests vertically on CTF fo undation). See Table 5.0.2 for bounding weight comparison.

c) T he contact footprint of the HI-TRAC CS alignme nt shield ring is smaller than that of the HI-STAR 190 bottom forging. The outer diameter is nearly equal but the alignment shield ring is an annular ring whereas the HI-STAR 190 bottom forging is a solid cylinder.

Based on the above, the minimum calculated safety factor for the CTB slab given in Table 5.3.2 is also a lower bound safety factor for the CTF foundation.

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL'fEC PROPR:IE'fAR:'1' INFORMAT ION Table 5.3.1: Material Properties for CTB Slab & CTF Foundation Description Value Min. concrete compressive strength 4,500 psi Min. rebar yield strength 60 ksi Rebar size and spacing See Licensing Drawing Table 5.3.2: Key Results of CTB Slab Analysis Ite m Max. Demand Capacity Safety Factor Bendin g moment in CTB slab 14,680 28,679 1.95 (kip-ft)

Shear force in CTB slab (kip) 2,011 3,899 1.94 Bearing load on CTB slab (kip) 304 383 1.26 Punching shear in CTB slab (kip) 304 1,093 3.60 Notes:

1) Reported values are worst-case results from all three load combinations (see Subsection 4.6.2).

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ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOL.TeC PROPRleTARY l~lFORMATION 5.4 OTHER SSCs IMPORTANT TO SAFETY The HI-STORE CIS facility includes the following other SSCs that are classified as important to safety:

HI-STORM UMAX Vertical Ventilated Module (VVM)

HI-TRAC CS

Cask Transfer Building Crane

Transport Cask Lift Yoke

MPC Lift Attachment

Special Lifting Devices Each of these components is discussed in more detail, including the ir description, design criteria, material properties, and struc tural analyses, in the fo llowing subsections.

5.4.1 HI-STORM UMAX VVM 5.4.1.1 Description of Structural Aspects The HI-STORM UMAX VVM is a central component of the HI-STORM UMAX dry storage system, which has been previously licensed in accordance with 10CFR72 requirements under NRC Docket# 72-1040. The VVM provides for storage of the MPC in a vertical configuration inside a subterranean cylindrical cavity entirely below the top-of-grade (TOG) of the ISFSI pad.

The VVM is comprised of the Cavity Enclosure Container (CEC) and the Closure Lid, which are both shown on the Licensing Drawing in Section 1.5. A full description of the VVM, including its subcomponents, is provided in Section 1.2 of the HI-STORM UMAX FSAR [1.0.6]. The HI-STORM UM AX VVM is licensed as a variable height system in [l.0.6]. For the HI-STORE CIS facility, however, there will be one uniform depth for all VVMs as shown on the Licensing Drawing in Section 1.5. The HI-STORM UMAX FSAR also provides for multiple design options with respect to the seismic restraints and the closure lid design. The specific set of options selected for the HI-STORE CIS fac ility are shown on the Licensing Drawing in Section 1.5. This design variant of the HI-STORM UMAX, which is to be deployed at the HI-STORE CIS facility, is referred to as the HI-STORM UMAX Version C.

5.4.1.2 Design Criteria To serve its intended function, the HI-STORM UMAX VVM, including the CEC and Closure Lid, shall ensure physical protection, biological shielding, and allow the retrieval of the MPC under all conditions of storage (10 CFR 72. 122(1)). Because the VVM is an in-ground structure, drops and tip-over of the VVM are not credible events and, therefore, do not warrant analysis.

The design bases and criteria for the VVM are fully defined in Chapter 2 of the HI-STORM UMAX FSAR [l.0.6]. The load cases germane to establishing the structural adequacy of the VVM pursuant to 10 CFR 72.24(c) are compiled in Table 2.4.l of [1.0.6].

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOL'fEC PROFR:IE'fAR:'1' INFORMAT ION 5.4.1.3 Material Properties The material properties for the VVM are provided in Section 3.3 of the HI-STORM UMAX FSAR [1.0.6] in conjunction with the Licensing Drawing in Section 1.5.

5.4.1.4 Structural Analysis The design basis structural analyses for the VVM for all applicable normal, off-normal, and accident loadings are presented in Chapter 3 of the HI-STORM UMAX FSAR [ 1.0.6]. As shown in Table 5.0.1 above, the design basis loads analyzed in the HI-STORM UMAX FSAR completely bound the site-specific loads applicable to the HI-STORE site, and therefore minimal structural analyses are required to qualify the VVM for this application.

The only loading event for the VVM that is not generically analyzed in the HI-STORM UMAX FSAR is a postulated earthquake during MPC transfer operations at the VVM, wherein the HI-TRAC CS is vertically stacked on top of the VVM and securely fastened in place at four anchor bolt locations. The analysis of this stack-up configuration is performed herein using the time history analysis method implemented in LS-DYNA [5.4.2]. The finite element model used for this analysis is shown in Figure 5 .4. 1.

(b)(4)

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMAT IOM 5.4.2 HI-TRAC CS 5.4.2.1 Description of Structural Aspects The HI-TRAC CS is a steel and concrete transfer cask, which is used for all on-site canister transfers. It has a cylindrical body delimited by carbon steel inner and outer shells with densified concrete occupying the space between the shells. The HI-TRAC CS has two trunnions near the top of the cask for lifting, and two rotation trunnions near its base for upending (or down ending) the cask. The bottom lid of the HI-TRAC CS, which is also referred to as the shield gate, is split into two hal ves such that they can be slid open in a symmetric manner to allow the MPC to pass through the opening (see F igure l.2.3a). A complete description of the HI-TRAC CS is provided in Subsection 1.2.4.

5.4.2.2 Design Criteria The design criteria for the HI-TRAC CS, which is an ITS component, are fully provided in Subsection 4 .3.3.

The structural steel components of the HI-TRAC CS are designed to meet the stress limits of Section III, Subsection NF of the ASME Code [4.5.1] for all operating modes. The embedded trunnions for lifting and handling of the transfer cask are designed in accordance with the requirements of NUREG-0612 [1.2.7] for interfacing lift points.

T able 4 .3.4 lists the loading scenarios for HI-TRAC CS for wh ich its structural qualification must be perfonned.

5.4.2.3 Material Properties The fabrication materials for the HI-TRAC CS are the same as those for the HI-STORM FW and the HI-TRAC VW. Therefore, the material properties for the HI-TRAC CS can be obtained from the summary tables in Section 3.3 of the HI-STORM FW FSAR [1.3.7], which are sourced from the Section II, Part D of ASME Code [4.6.3].

5.4.2.4 Structural Analysis The loads on the HI-TRAC CS that are structurally significant are listed in Table 4.3 .4, and the structural analysis for each of these loads is described below.

5.4.2.4.1 Lifting Analysis (b)(4)

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ATTACHMENT 2 TO HOL TEC LETTER 5025025 HOLTEC F'~OF'~IETAFH INFO~MATIOI~

(b)(4)

The results for the above lifting analyses are summarized in Table 5.4.2, which shows that all calculated stresses are less than their applicable stress limits. The complete details of the HI-TRAC CS lifting analysis are provided in the Structural Calculation Package [5.4.6].

5.4.2.4.2 Seismic Analysis at CTF The seismic analysis of the HI-TRAC CS while it is mounted atop a HI-STORM UMAX VVM is discussed in Subsection 5.4. 1.4, and the results are summarized in Table 5.4.1. The anchorage design used to secure the HI-TRAC CS to the CTF is the same design used to anchor the HI-TRAC CS at a HI-STORM UMAX VVM location. The only difference between stack-up configurations at the CTF versus the HI-STORM UMAX VVM is the anchor bolts used to secure the HI-TRAC CS are longer for the latter confi guration. The longer free length of the bolts introduces more flexibility into the system, which in turn may lead to larger rocking displacements and internal loads acting on the stack under seismic conditions. In light of this, plus the fact that the stack-up analysis for the HI-STORM UMAX YYM is conservatively performed using the most limiting earthquake condition (i.e., DECE), the results for the HI-TRAC CS in Table 5.4.1 are also bounding for the stack-up configuration at the CTF.

5.4.2.4.3 Tornado Missile Analysis When the HI-TRAC CS is in use at the HI-STORE site, it is potentially exposed to tornado generated missiles. Although the threat of a tornado is relatively low at the HI-STORE site (see Section 2.3), the HI-TRAC CS is conservatively analyzed for the same tornado missiles as previously analyzed for the HI-STORM FW system and the HI-STORM UMAX syste m. These bounding tornado missiles are listed in Table 2. 7 .2.

(b)(4)

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ATTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY INFORMATIOM The complete details of the tornado missile analysis are provided in the Structural Calculation Package [5.4.6).

5.4.2.4.4 Seismic Stability Analysis of Freestanding HI-TRAC CS The general stability of a freestanding HI-TRAC CS (empty and fully loaded) under the SSE is evaluated for the possibility of incipient tipping and sliding, where simple dynamic equations are formulated based on force and moment equilibrium. Tab]e 5.4.7 summarizes both the bounding parameters used as input to the seismic stability analysis and the results. As seen from the table, the cask does not uplift or slide under the SSE event. A similar analysis has also been performed for the HI-STAR 190, and the results are likewise summarized in Table 5.4.7.

5.4.2.4.5 CTB Collapse Analysis As discussed in Section 4.6. 1, the walls and roof structure of the CTB are designed to meet the requirements of IBC [4.6.4) and ASCE 7-10 [4.6.2], and they are des ignated as not important to safety (NITS). This means that they are not designed to withstand seismic or tornado loads.

Therefore, HI-TRAC CS (as well as HI-STAR 190) has been structurallv analvzed to evaluate the damage due to a potential building collapse. l(b)(4)

(b)(4)

The complete details of the CTB collapse analysis are provided in the Structural Calculation Package (5.4.6).

5.4.2.4.6 Fatigue Evaluation The HI-TRAC CS will be used repeatedly at the HI-STORE CIS facility to transfer canisters from arriving transport casks to VVM storage cavities. As a result, the HI-TRAC CS will be subject to both thermal and mechanical cyclic loading, which must be evaluated from a fatigue life standpoint. A fatigue life evaluation for all load bearing members of HI-TRAC CS has been performed in [5.4.6], and the results are presented in Table 5.4.8. The maximum stress in the trunnions is conservatively set at the allowable stress limit per [l.2.7] times a stress Page 343 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 I IOLTEC PROPRIETARY IMFORMAT IOM concentration factor of 4.0 for the material. The use of stress concentration factor of 4.0 is consistent with HI-STAR 100 SAR [ 1.3.5]. The maximum stress in all other load bearing members of HI-TRAC CS, designed to stress limits in [4.5. l], is conservatively set at the ultimate strength of the material. The fatigue life of all load bearing materials is calculated by comparing the maximum stress value with the material cycle life curves defined in Appendix I of ASME Code [ 17.3.2]. A safety factor of 2.0 on the permissible loading cycles is imposed for additional conservatism per Subsection 4.5.3.9.

5.4.3 Cask Transfer Building Crane 5.4.3.1 Description of Structural Aspects The Cask Transfer Building (CTB) Crane consists of a gantry crane, trolley, and hoist(s). The CTB Crane is electrically driven and rides on crane rail s, which are mounted to the CTB slab in the Cask Receiving Area. The trolley rides on crane rails mounted to the top of the crane girders and has at least one electric wire rope hoist for load lifting. The hoist hook will be used to lift various loads and shall interface with the required rigging and below the hook lifting devices as req uired for the process. Figure 3.1.1 (b-c) is an illustration of the CTB Crane loading/unloading a transport package to/from a transport vehicle.

5.4.3.2 Design Criteria The CTB Crane shall be a single failure proof load handling device designed and built in accordance with the provisions of ASME NOG- 1 [3.0. 1]. The design criteria and operational requirements for the CTB Crane are further discussed in Subsection 4.5.2 of this SAR.

The applicable Design Basis loadings on the CTB Crane are set down in Table 4.5.1.

5.4.3.3 Structural Analysis The structural analysis of the CTB Crane shall demonstrate compliance with the applicable requirements of ASME NOG- 1 for the specified loadings in Table 4.5. 1.

5.4.4 Transport Cask Lift Yoke 5.4.4.1 Description of Structural Aspects The Transport Cask Lifting Device is used to lift the HI-STAR 190 transport cask inside the CTB. As shown on the Licensing Drawing in Section 1.5, the Transport Cask Lifting D evice has two lift arms that connect to the pair of lifting trunnions on the HI-STAR 190 and a main strongback assembly that connects to the CTB Crane hook.

5.4.4.2 Design Criteria The design criteria that apply to lifting devices are fu lly described in Section 4.5. The Transport Cask Lift Yoke is a non-redundant special lifting device, which is designed to meet the increased safety factors per ANSI Nl 4.6 [1.2.4].

5.4.4.3 Material Properties As shown on the Licensing Drawing in Section 1.5, the major structural components of the Transport Cask Lift Yoke are the strongback plates, the lift arms, the actuator plates, the main Page 344 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOL TEC LETTER 5025025 I IOLT EG PROPRleTARY IMFORMATIQN pins, and the actuator pins. The strongback plates, lift arms, and actuator plates are fabricated from high-strength alloy steel (A5 14 or equivalent). The main pins and actuator pins are fabricated from hardened nickel alloy bar material (SB-637 N07718). The minimum strength properties for these components are obtained directly from the applicable ASTM specification or from Section II, Part D of the ASME Code [4.6.3].

5.4.4.4 Structural Analysis The load bearing members of the Transport Cask Lift Yoke are analyzed using a combination of formulae from ASME BTH- 1 [5.4.3] and strength of materials principles. The lifted load considered in the analysis is equal to the bounding weight of the loaded HI-STAR 190 transport cask from Table 5.0.2. The lifted load and the self-weight of the lifting device are further amplified by 15% to account for dynamic effects in accordance with the guidance in CMAA-70

[4.5.2] for low speed lifts. The results of the structural analysis for the Transport Cask Lift Yoke are summarized in Table 5.4.4, which shows that all calculated safety factors are greater than 1.0.

The complete details of the structural analysis of the Transport Cask Lift Yoke are provided in the Structural Calculation Package [5.4.6].

5.4.5 MPC Lift Attachment 5.4.5.1 Description of Structural Aspects The MPC Lift Attachment is a one-piece lifting device (or lug) that is bolted directly to threaded anchor locations on the top surface of the MPC closure lid using a total of eight bolts (see Licensing Drawing in Sectio n L. 5). The MPC Lift Attachment allows raising or lowering of the MPC during canister transfer operations using either the CTB Crane or the VCT.

5.4.5.2 Design Criteria The design criteria that apply to lifting devices are full y described in Section 4.5. The MPC Lift Attachment is a non-redundant special lifting device, which is designed to meet the increased safety factors per ANSI N14 .6 [ l.2.4].

5.4.5.3 Material Properties As described above, the MPC Lift Attachment consists of the lifting lug and eight attachment bolts. The lifting lug is fabricated from an alloy steel forging (A336-F6NM). The attachment bolts are fabricated from ha rdened nickel alloy bar material (SB-637 N07718). The minimum strength properties for these components are obtained directly from the applicable ASTM specification or from Section II, Part D of the ASME Code [4.6.3].

5.4.5.4 Structural Analysis The load bearing members of the MPC Lift Attachment are analyzed using strength of materials principles together with form ulae from ASME BTH-1 [5.4.3]. The lifted load considered in the analysis is equal to the bounding weight of a loaded MPC from Table 5.0.2. The lifted load and the self-weight of the lifting device are further amplified by 15% to account for dynamic effects in accordance with the guidance in CMAA-70 [4.5.2] for low speed lifts. The results of the structural analysis for the MPC Lift Attachment are summarized in Table 5.4.5, which shows that all calculated safety factors are greater than 1.0. The complete details of the structural analysis of the MPC Lift Attachment are provided in the Structural Calculation Package [5.4.6].

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A TTACHMENT 2 TO HOLTEC LETTER 5025025 HOLTEG PROPRIETARY l~lFOR MATION 5.4.6 Other Special Lifting Devices 5.4.6.1 Description of Structural Aspects In addition to the Transport Cask Lift Yoke and MPC Lift Attachment discussed in the preceding subsections, there are other special lifting devices that will be used to connect the cask or canister to the CTB Crane or VCT at the HI-STORE CIS fac ility. These other special lifting devices include:

HI-TRAC CS Lift Yoke

HI-TRAC CS Lift Link

Transport Cask Horizontal Lift Beam

MPC Lifting Device Extension All special lifting devices that will be used at the HI-STORE CIS facility are shown on the Licensing Drawings in Section 1.5.

5.4.6.2 Design Criteria The design criteria that apply to lifting devices are fully described in Section 4.5. Special lifting devices are designed to meet the increased safety factors per ANSI N l 4.6 [1.2.4].

5.4.6.3 Material Properties The fabrication materials for the special lifting devices listed above are specified on the Licensing Drawings in Section 1.5. The minimum strength properties for these materials are obtained directl y from the appl icable ASTM specification or from Section II, Part D of the ASME Code [4.6.3] in accordance with the Licensing Dra wings.

5.4.6.4 Structural Analysis 5.4.6.4.1 Lifting Analysis The load bearing members of special lifting devices are analyzed using a combination of methods, including the finite element approach, formulae from ASME BTH- 1 [5.4.3], and strength of materials principles. T he lifted loads considered in the analyses are eq ual to the bounding weights of the loaded HI-STAR 190 transport cask, the loaded MPC, or the loaded HI-TRAC CS from Table 5.0.2, as applicable. The lifted load and the self-weight of the lifting device are further amplified by 15% to account for dynamic effects in accordance with the guidance in CMAA-70 [4.5.2] for low speed lifts. The minimum calculated safety factors for the special lifting devices, other than the Transport Cask Lift Yoke and the MPC Lift Attachment, are summarized in Table 5.4.6. The complete details of the stmctural analysis of the special lifting devices are provided i n the Structural Calculation Package [5.4.6].

5.4.6.4.2 Fatigue Evaluation T he special lifting devices will be used repeatedly at the HI-STORE CIS fac ility to transfer canisters from arriving transport casks to VVM storage cavities. As a result, the special lifting devices will be subject to both thermal and mechanical cyclic loading, which must be evaluated from a fatigue life standpoint. A fatigue life evaluation for all special lifting devices has been Page 346 of 689 Revision OC May 2018

ATTACHMENT 2 TO HOLTEC LETTER 5025025 AOL I EC PROPRIE I ARV 11\iFOR.MATIOI\J performed in [5.4.6], and the results are presented in Table 5.4.9. The maximum stress in the special lifting devices is conservatively set at the allowable stress limit per [1.2.4] times a stress concentration factor of 4.0 for the material. The use of stress concentration factor of 4.0 is consistent with HI-STAR 100 SAR [1.3.5]. The fatigue life of all load bearing materials is calculated by comparing the maximum stress value with the material cycle life curves defined in Appendix I of ASME Code [17.3.2]. A safety factor of 2.0 on the permissible loading cycles is imposed for additional conservatism per Subsection 4.5 .3.9.

Page 347 of 689 Revision OC May 2018

NRC-2019-000246 - Resp 2 - Final, Agency Records Subject to the Request Are Enclosed. Part 9 of 19
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ML19346E421
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1.0 INTRODUCTION

2.0 INTRODUCTION

3.0 INTRODUCTION

3.1 DESCRIPTION

4.0 INTRODUCTION

SUMMARY

5.0 INTRODUCTION

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